Securing the Metaverse:
Addressing Harms in
Extended Reality
Shannon Pierson
July 2023
Minderoo Centre for Technology and Democracy
The Minderoo Centre for Technology and Democracy is an
independent team of academic researchers at the University of Cambridge, who
are radically rethinking the power relationships between digital technologies,
society and our planet.
DOI: doi.org/10.17863/CAM.99564
Table
of Contents
Visions
for Metaverse Governance.
7
What is
Extended Reality? Augmented, Mixed, and Virtual Reality. 8
Section I: Metaverse platform governance. 9
Content
Moderation Obstacles in Social VR.. 10
Generative
AI Applications in XR..
17
Online
Safety Bill’s Applicability to XR.. 20
Section II: Biometric Data. 22
Section III: Cybersecurity. 29
Abuse of
Immersive Learning.
32
Section IV: Conclusion & Recommendations. 35
How do we secure the metaverse? This report from Shannon
Pierson, an affiliate at the Minderoo Centre for Technology and Democracy at
the University of Cambridge, explores ways to tackle harms presented by the
advancement of extended reality (XR) technologies.
Thanks to Shannon’s extensive research into online harms at
scale on social media platforms, this report maps how to address the harms
presented by XR.
From the governance of interconnected, persistent
computer-generated worlds, to the biometric data privacy concerns they present,
and cybersecurity obstacles in XR technology today, this report signals what
problems lie ahead for a fully realised metaverse.
At the Minderoo Centre for Technology and Democracy, at the
University of Cambridge, we study how digital technology is transforming
society to ensure democratic accountability over the increasing power of tech
across the globe.
Our research is anchored in creating ways to build capacity in
how we as a society can hold tech power systems to account, to create a just
future.
We hope that this report will be useful to a wide range of
different stakeholders in scrutinising metaverse developments, and address how
we can use regulatory and legislative power today, to protect against the
entrenchment of harmful metaverse developments that could impact us and future
generations.
Prof. Gina Neff
Executive Director, Minderoo Centre for Technology and Democracy
Advancements in extended reality (XR) technologies are bridging
the gap between the physical and virtual world and propelling the concept of a
“metaverse”—a network of interconnected, persistent computer-generated
worlds—closer to fruition.
Applications of XR systems are poised to disrupt and transform
the global digital economy, with some forecasting the metaverse to grow into a
£3.975 trillion industry by 2030.1[1] Beyond gaming, XR and metaverse
technologies have the potential to revolutionise various industries: including
education and training, healthcare, entertainment, and the future of work and
personal productivity.
The breadth and intimacy of the personal information collected
by XR devices is unlike anything yet seen in another consumer-grade product. Emerging
Social VR platforms remain largely unmoderated virtual spaces rampant with
toxicity and online abuse.
Currently, few guardrails are in place to ensure that the
development of XR technologies progresses responsibly and prioritises user
safety and privacy. Policymakers must begin considering regulation that
addresses the risks of these products and services before they enter the
mainstream.
If left unaddressed, these problems will become entrenched into
metaverse infrastructure and business models in ways that will be difficult, if
not impossible, to untangle.
This report provides an assessment of possible harms and
suggests policy recommendations to mitigate them. We examine the governance,
biometric data privacy, and cybersecurity obstacles in XR technology today in
order to signal what problems lie ahead for a fully realised metaverse.
From our findings we propose interventions to improve user
safety and privacy within metaverse platforms and technologies. For the UK, we
suggest ways to use the Online Safety Bill and existing privacy, security and
consumer protection laws to address harms in metaverse mediums.
Our report is structured as follows:
Section I: Metaverse
Platform Governance
Findings:
∙€€€€€ Platforms’
moderation tools do not sufficiently protect users — particularly children and
marginalised groups — from harms that are pervasive in Social VR. As a result,
Social VR spaces do not uniformly enforce their rules.
∙€€€€€ Social
VR platforms fail to enforce age restrictions and ensure age-appropriate spaces
for children separated from adults. Children frequently encounter and
experience bullying, sexist and racist hate speech, simulated sexual
interactions, and sexual harassment.
∙€€€€€ Generative
AI will scale content creation in the metaverse and make it easier for bad
actors to create immersive experiences that harm, mislead and manipulate.
Recommendations to improve metaverse platform governance:
∙€€€€€ Policymakers
must establish expectations that companies actively monitor Social VR
environments.
∙€€€€€ Expand
the definition in the UK’s Online Safety Bill for what qualifies as ‘content’
with respect to XR.
∙€€€€€ Regulators,
including the UK’s Ofcom, should be proactive about metaverse technologies.
Section II: Biometric Data
Findings:
∙€€€€€ Involuntary
biometric responses tracked by XR devices can divulge sensitive personal
information, including data that can indicate medical conditions, sexual
orientation, and identity.
Recommendation to protect people in the metaverse:
∙€€€€€ Existing
privacy, security and consumer protection laws need to be re-evaluated and
updated to ensure that they apply across metaverse devices and experiences.
Section III: Cybersecurity
Findings:
∙€€€€€ Cybercriminals
have begun exploiting the emerging metaverse’s non-fungible token (NFT) market
to profit from investment fraud scams, money laundering schemes, and the
exchange of illicit materials.
∙€€€€€ XR
devices share many of the same cybersecurity vulnerabilities that other
consumer-grade devices, including IoT devices, have and may require better
authentication mechanisms and stronger encryption.
Recommendations to address cybersecurity risks:
∙€€€€€ Governments
and industry must commit to embedding security and privacy by design into
metaverse products and services.
Applications of extended reality (XR) systems open up a world of
exciting possibilities in the Web 3.0 digital economy. XR technology has the
potential to revolutionise various industries: including education and skills
training, healthcare, entertainment and gaming. XR systems provide
opportunities to reshape the future of work and enhance personal productivity.
Today, few guardrails exist to ensure that the development of XR
technologies progresses responsibly and prioritises user safety and privacy.
The breadth and intimacy of the personal information collected by XR devices is
unlike anything yet seen in consumer products.
Emerging Social Virtual Reality (VR) platforms remain largely
unmoderated, resulting in toxic virtual spaces rampant with online abuse.
Policymakers must begin considering regulation that addresses
the risks of these products and services before they enter the mainstream.
If these problems become entrenched into metaverse
infrastructure and business models it will be difficult, if not impossible, to
untangle and deal with them.
This report cuts through the hype and dismissals surrounding XR
technologies and Social VR platforms to provide an assessment of the harms
manifesting today and recommendations to mitigate them.
We present a status report on the governance, data privacy, and
cyber-security challenges in XR technology today to signal what problems lie
ahead for a fully realised metaverse. We propose possible interventions for
policymakers and technology companies to design safer systems.
The term ‘metaverse’ describes a vision for the future of the
internet: a network of interconnected, persistent computer-generated worlds
facilitated by and accessed through virtual reality (VR) and augmented reality
(AR) devices.[2]
In the metaverse, users can enter three-dimensional, immersive
virtual spaces and interact with one another in real time to socialise, play,
collaborate, and exchange digital goods.[3] The metaverse is live and never
switches off, and users can navigate seamlessly between worlds.
Many technological hurdles must be overcome before these visions
for the metaverse are fully realised.[4] While the metaverse may be years away,
technology companies like Meta, ByteDance, Microsoft, Tencent, Apple, HTC, and
others have invested hundreds of billions of pounds into developing XR technology.
They are currently carving out portions of the emerging XR
market by buying up XR hardware and software companies and securing XR patents.[5] McKinsey forecasts that the metaverse
will grow into a £3.975 trillion industry by 2030.[6]
The metaverse is often described as the next iteration of the
internet. Companies like Apple and Meta push forward the notion that mixed
reality (MR) headsets could eventually replace smartphones.[7]
Looking beyond the hype, the metaverse continues to be defined
and take shape as the technology matures and adoption increases.
Still, it remains to be seen how the metaverse will be
constructed and governed. Some visions for the metaverse see it consisting of
decentralised ownership similar to Web 3.0 technologies. Today’s powerful
platform companies could coalesce industry power in the hands of a few
corporate entities.
There are three competing models for how metaverse platforms
will be arranged and governed in the future: centralised, multiverse, and
decentralised. These directions will have implications for what levers
companies and policymakers have for governing and regulating metaverse
technologies.
Centralised
One entity exclusively owns, operates, and governs a centralised
enclosed network of virtual worlds.
The central entity owns all user-generated content and collects
and stores user-interaction data.
Users cannot control or own pieces of the virtual environment
themselves.
Multiverse
Multiple entities own, operate, and govern separate but
interconnected networks of virtual worlds.
Each world is enclosed and has its own governing structure,
economy, and unique user experience.
Decentralised
Users collectively own, operate, and govern a decentralized
interconnected, interoperable network of virtual worlds through blockchain
technology.
There is no central authority enforcing rules, but users who own
digital property in the form of non-fungible tokens (NFTs) have decision-making
power over their respective domains.
Extended Reality (XR)
Umbrella term for any technology that alters reality by adding
digital elements to the physical world environment to any extent
Augmented Reality (AR)
View of the physical with an overlay of digital elements
Mixed Reality (MR)
Blend of the physical with digital or virtual elements where
physical and digital elements can interact
Virtual Reality (VR)
View of a fully-immersive digital environment
Today, there are precursors to a fully functional, persistent,
and cross-platform metaverse.[9] These are Social VR platforms, which
are XR apps focused on social networking and social gaming experiences. Social
VR platforms like Horizon Worlds, Roblox, VRChat, and Rec Room provide a
glimpse of the governance and moderation obstacles that lie ahead for a fully
realised metaverse.
Evaluation of the harms and governance challenges manifested in
Social VR today can offer perspective on and lessons for regulators thinking
ahead to how to regulate the metaverse to come.
When considering how the Online Safety Bill applies to metaverse
platforms, it is important to understand what distinguishes Social VR from the
traditional social media platforms the legislation was written for. Social VR
is distinct from social media, and user-generated content and online harassment
manifest very differently in these respective mediums.
What constitutes user-generated content in Social VR is far more
diverse and complex compared to what we have seen previously on social media.
One reason is that the content in Social VR is
three-dimensional, not two-dimensional. Social VR content can include avatar
skins, virtual objects, virtual worlds, and user-made games.
Social VR users actively experience a fully immersive content
environment where they can interact directly with content and other people by
walking around in and exploring virtual worlds. Social VR is all about user
activity, which occurs synchronously and involves actions taken by players
(i.e., jumping, waving, dancing).
User interaction in Social VR is physical, as user avatars can
enter each other’s personal space and virtually touch each other in ways that
can trigger physiological and emotional responses in users.[10]
XR headsets and haptic gear, which are wearable devices that
provide tactile feedback to simulate the sensation of touch, engage users’
senses in order to give players the illusion of presence in virtual
environments, and the perception that an avatar body is their own.[11]
In Social VR, users’ physical actions are translated into
virtual simulations, enabling them to ‘touch’ and affect virtual objects and
other users. The illusion is further supported by the integration of immersive
details like spatial audio, haptic touch, and non-verbal communication cues
(i.e., representing a user’s facial expressions on their avatar).[12]
Part of what makes VR so convincing is that simulations elicit
physiological responses, making experiences like standing before a virtual
cliff heart-pounding or climbing through an enclosed virtual space feel
claustrophobic.
However, the immersive nature of XR can make perceived threats
to one’s physical safety feel physically and psychologically real.[13]
This ‘physicalised nature’ of Social VR has created new
immersive forms of online harassment.[14] Harassment in XR manifests in the form
of simulated physical behaviours intended to disturb or violate the personal
space of other players. Harassment can involve trolling behaviour, where users
deliberately irritate a target enough to make them leave a virtual space by
circling or stalking them, blocking their view, or screaming in their vicinity.
More extreme cases of harassment can involve simulated touching
and violence, or enactment of self-harm or suicide.[15]
User-to-user verbal communication occurs primarily over voice
chat and, therefore, is audio and not text-based. Many gamers prefer using
voice chat during live multiplayer games, however it is a notorious vector for
toxic and violent speech.[16] Voice chat use in VR creates pathways for online harassment, as
users in public virtual spaces often overhear hate speech, verbal attacks, or
yelling and screaming occurring in their avatar’s vicinity. While users can
mute or block aggressors individually, racially-charged insults and hate speech
cannot be unheard, and affect users in the nearby area.
Repeated exposure to hate speech communicated via the voice chat
feature represents a collective harm as it makes virtual spaces unwelcoming for
marginalised groups, and research has shown it may reduce our ability to
empathise with others.[17]
Case Study: Cyberbullying and Hate
Speech
Bullying
and hate speech are pervasive in Social VR. Racism, homophobia, antisemitism,
and other forms of online hate thrive in these largely unmoderated, unmonitored
public virtual social spaces.
Conversations
occur in real-time over voice chat, uncensored and without leaving a lasting
record. The lack of rule enforcement, the anonymity afforded by the platforms,
and toxic gaming culture embolden users to spread toxicity uninhibited.[18]
Social VR
is consequently a hotbed for online vitriol, where virtual public spaces are
made uninhabitable for women, Black, Asian and minority ethnic (BAME), and
other marginalised communities.[19] Users are targeted with identity
attacks based upon their voice and their avatar’s presented gender and
ethnicity.
A Channel 4
Dispatch investigation into abuse on Social VR platforms found extreme sexist,
racist, and homophobic hate speech to be prevalent on VRChat.[20] Hate speech and openly racist and antisemitic
conversations were a commonplace feature of public virtual rooms. An
investigator posing as a thirteen-year-old easily accessed adult-only spaces
and became the target of racialized harassment and slurs.
The hate
speech was so casual and omnipresent that investigators gradually became
desensitised to its severity.
Case Study: Virtual Sexual Harassment
Across the
internet, women are subject to disproportionate amounts of online abuse, which
is often gendered and sexualised in nature.[21] Sexual harassment and abuse against
women has already become a widespread problem in Social VR.
Women
commonly experience simulated groping and other unwanted sexual interactions
and communication. Some Social VR users report experiencing up to three
instances of gendered and sexualised harassment a week.[22]
VR brings
women’s bodies into virtual environments via female-presenting avatars and
female users’ voices. Women’s gender makes them targets for unwanted sexual
attention and interactions with other users in Social VR spaces.
This
manifests in the form of verbal threats to women’s physical safety, including:
∙€€€€€ Descriptions
of rape and sexual violence
∙€€€€€ Unwanted
virtual touching
∙€€€€€ Non-consensual
simulated virtual sexual acts
For
example, a beta tester for Horizon Worlds reported that a stranger groped her
avatar's body in a public plaza while surrounding avatars egged on the
harassment.[23]
A BBC investigative reporter posing as a thirteen-year-old girl on VRChat
received sexual propositions from adults and encountered real voices yelling
aggressive rape threats in her vicinity.[24]
Sexual
harassment in VR can cause non-trivial psychological harm to users.[25] Some women who have experienced
‘virtual sexual assault’ report feeling disoriented and that the abuse was
physically happening to them.[26] Gendered and sexualised harrassment in
VR is immersive and visceral, given that players’ bodies and minds can often
react to virtual stimuli in VR as they would to physical stimuli.[27]
This harm
may be compounded with the addition of haptic body gear, which enables users to
have a more immersive experience in VR. For example, a forty-three-year-old
woman experienced her avatar’s chest being groped in the first-person shooter
game Population One while wearing a haptic vest. The haptic device provided
vibration feedback to her body and made the harassment feel physically real.[28]
Social VR’s immersive, live medium complicates policing Social
VR platforms. All conversations and physical interactions between users are
synchronous, unfiltered, and ephemeral — meaning interactions happen quickly
and are not often represented by a lasting digital record.
This medium makes it more difficult for platforms to monitor and
detect abuse, as well as prevent hate speech and harassment in the metaverse
environments they host. The policy frameworks and content moderation regimes
developed over the years to govern social media platforms and enforce community
guidelines at scale have not translated seamlessly to virtual worlds.
The automated methods typically used to moderate content on
social media, such as natural language processing (NLP), machine learning
models, and image and video recognition software, are text, image, and
video-based methods not directly applicable to immersive environments.
For example, hate speech-detection models are text-based.
However, the lack of a text-based, searchable digital record of verbal or
non-verbal interactions between users makes it challenging for companies to
monitor and moderate abuses at scale.
Automated monitoring and moderating of verbal communication in
Social VR would require reliable audio-based language classification models,
which are still under development.[29] Some social VR platforms have begun
integrating voice moderation software capable of:
∙€€€€€ Detecting
and contextualising toxic speech spoken in real-time
∙€€€€€ Escalating
it to immediate action
∙€€€€€ Identifying
the worst offenders[30]
However, not all platforms use this intervention because it is
costly and slow, given the great deal of computing power required to perform it
and the large data processing costs.[31] Also, live voice chat moderation tools
to date have low accuracy.[32]
Social VR platforms police their platforms and enforce rules
primarily through human moderation.[33]
VR moderation strategies generally involve stationing human
moderators in public virtual spaces and rely on user reporting to flag abusive
user interactions and user-generated content. Human moderators then manually
review reports on a case-by-case basis for platform codes of conduct
violations.[34]
Other VR moderation approaches allow for community moderation,
where users adjudicate violations and vote to eject users for violating
standards.[35]
Dependence on user reporting creates other obstacles. Reporting
abusive behaviour is often a burden for users, placing the onus on targets and
parents to detect and report abuse during or after the harm has already been
inflicted.
Reporting instances of bullying, hate speech, and sexual
harassment often requires written descriptions and screenshots or video
recordings of the interaction and abuser(s) user IDs — which users may not have
documented mid-attack.[36] While it varies from platform to platform, targets often never
receive word back on the outcome of their reports.[37]
These interventions offer spotty moderation coverage at best and
are not operable at scale. This means Social VR spaces routinely fail to
uniformly enforce their rules across the platform. Moreover, the human
moderation approach is reactive rather than proactive and preventative.
Generally, this approach is unsustainable for long-term growth.
Copy-pasting interventions deployed for social media to the
Social VR platforms does not work perfectly. Therefore, Social VR companies
must tailor policy frameworks and pioneer scalable moderation techniques to
spatial mediums to govern their platforms — and the future metaverse —
effectively.
One positive intervention taken by Social VR platforms is the
introduction of opt-in safety features for users to stave off harassment
themselves. For example, Meta introduced a personal boundary tool for Horizon
Worlds after beta testers complained about experiencing virtual sexual
harassment.[38]
These affordances are helpful and preventative, and represent a
step in the right direction. However, they can only be one piece of a platform
content moderation strategy. These tools cannot replace active monitoring and
moderation.
Should the metaverse take a decentralised model shape,
decentralised metaverse platforms governed by decentralised autonomous
organisations (DAOs) may not have the resources to effectively govern and
enforce rules at scale in a substantive, coordinated way.
This may present challenges to regulators as there would be no
entity that could be held to account for duty of care responsibilities of the
Online Safety Bill. Policymakers must consider this possibility and how the
legislation will apply in this case.
Generative AI will scale content creation in the metaverse.
While it is time and labour-intensive to build VR experiences today, the
integration of Generative AI in metaverse platforms will speed up the creative
process for users.
Social VR platforms are developing Generative AI tools that
enable users to use voice or text inputs to instantly generate virtual worlds
and objects, as well as design avatars.[39] For example, in 2022, Horizon Worlds
showcased a prototype of Builder Bot, a Generative AI tool capable of spawning
virtual worlds and objects via voice commands.[40]
Another example, Social VR platform SIMULACRA released an AI tool
that allows users to customise their virtual apartments and avatar apparel via
text commands.
These features aim to make Social VR platforms more attractive
to users and encourage adoption.[41]
Companies must consider how Generative AI tools in XR will be
misused to generate illegal content or immersive harmful virtual experiences en masse.
For example, Generative AI applications in VR would make it
easier to generate and disseminate child sexual abuse material (CSAM) and
terrorism content.[42]
Another example, cybersecurity experts have raised alarms about
Generative AI's capacity to cheaply produce convincing misinformation in the
form of images, video, and audio at scale. Some scholars anticipate that the
technology will revolutionise influence operations and disrupt elections.[43]
Pairing Generative AI with XR democratises access to
misinformation production tools capable of creating compelling misinformation
experiences, or mis-experiences, intended to mislead or confuse audiences at
scale.[44]
XR companies do not provide sufficient protection for children
in Social VR.
Social VR platforms, which are primarily advertised towards and
utilised by children, often fail to to enforce age restrictions and ensure
safe, age-appropriate spaces for children. Approximately six per cent of
children between the ages of five and ten years old use VR headsets regularly.[45]
Children easily circumvent platform age restrictions by lying
about their age or using an older family member’s XR device.[46] For example, human moderators in
Horizon Worlds do not enforce their 18+ age restriction and remove children who
can be easily identified by their voices, instead deferring to the age
associated with their Meta accounts.[47]
Social VR platforms are currently falling short of their
obligations to perform age verification that would come into force under the
Online Safety Bill.[48]
There are little to no barriers for children to access VR social
spaces intended for adults. In these largely unmoderated spaces, children can
be approached by adults and are exposed to uncensored bullying, sexist and
racist hate speech, simulated sexual interactions, and sexual harassment.
Conversely, children can harass adults in these spaces as well.
Researchers found that underage users also perpetuate
harassment. Children troll adults in Social VR by following them around,
screaming or repeating expletives or insults at them, and blocking their view
or path till they become frustrated and leave the room.[49]
Due to the lack of consistent monitoring and moderation across
Social VR platforms, users often have to manage harassment on their own.
Parents are often unaware of available parental monitoring tools, find them
overly complex and labour-intensive, and lack the time or interest to activate
and monitor them.[50]
Parental monitoring tools do not sufficiently protect children
throughout their experiences using VR. Better monitoring and moderation would
improve Social VR experiences for everyone.
Case Study: Child Sexual Exploitation in
VR
Social VR
is shaping up to be a new pathway for online child sexual exploitation. An
investigation by ActiveFence observed how child sexual predators and sextortion
scammers capitalise on the anonymity and access to children afforded by VR
social spaces.
Some
tactics used by predatory adults included targeting children based on their
voices to elicit sex, drawing children away from other players in lobbies or
into private rooms to be alone, and inviting them to continue conversations
off-platform on instant messaging apps like Discord.[51]
Adults
violated children’s personal space by groping their virtual bodies and
simulating sex with children’s virtual avatars.
ActiveFence
also found instances of adults attempting to move conversations with minors
off-platform or to meet in real life, as well as adults offering money to
minors or issuing threats to acquire real photos from children.
Grooming in
Social VR can translate to offline exploitation. For example, US authorities
arrested a twenty-five-year-old man from Florida after he groomed and kidnapped
a thirteen-year-old girl in Utah using VRChat in March 2022. They met virtually
and played games together for a month over VRChat until he convinced the child
to meet in person.[52]
Metaverse
apps exchanging virtual assets may impede the detection of the possession of
child sexual abuse material. In 2023, UK authorities discovered eight examples
of VR devices being used to store and view CSAM.[53]
The proponents of the UK’s Online Safety Bill push for the UK to
be the safest place in the world to be online. However, the metaverse will
challenge any such claim.
The Online Safety Bill establishes responsibilities for platform
companies to adequately protect children and adults from encountering illegal
content in social media environments. While the legislation does not explicitly
address the topic of XR technology and was not drafted with the metaverse in
mind, Social VR platforms are liable as user-to-user service providers to its
duty of care obligations — particularly to ‘mitigate and manage the risks of
harm to individuals’.[54]
The Online Safety Bill defines content as ‘anything communicated
by means of an internet service, whether publicly or privately, including
written material or messages, oral communications, photographs, videos, visual
images, music and data of any description’.[55]
This definition addresses social media environments, where users
publish and passively interact with two-dimensional text, image and video-based
content. However, this definition does not encompass the full range of
user-to-user interactions and immersive experiences that can take place within
XR-enabled virtual environments.[56]
Because the Online Safety Bill was tailored to Web 2.0
internet-based social media applications, some adjustments may be necessary for
it to be fully applicable to Web 3.0 metaverse technologies. Under its present
definition of ‘content’, the bill does not provide full coverage for the
user-generated content nor user activity possible in metaverse virtual social
settings.[57]
An amendment to the Online Safety Bill expanding the definition
to address content in the XR medium is necessary to oblige metaverse companies
to better protect users from harmful immersive experiences.
The definition for content should include:
∙€€€€€ User-generated
avatar skins and accessories
∙€€€€€ Virtual
objects
∙€€€€€ Virtual
rooms and worlds
∙€€€€€ Interactive
games and activities
∙€€€€€ Any
user-generated content created using Generative AI
In 2021, Meta’s Chief Technology Officer Andrew Bossworth stated
publicly that content moderation ‘at any meaningful scale is practically
impossible’ on VR platforms.[58]
While this sentiment speaks to the complexity of preventing
harmful behaviour in XR mediums, policymakers cannot allow XR companies to
abdicate responsibility for the harms playing out on their platforms, which are
largely inhabited by children.
The metaverse needs active monitoring, moderation, and
maintenance by the platforms. Human moderation techniques will not be
sufficient, given the overwhelming quantity and variety of environments and
experiences. Rather, companies will need to innovate harm-prevention safety
features and scalable techniques for monitoring and moderation capable of
objurgating on harm and preserving user privacy.
XR headsets and haptics are an amalgamation of a variety of
motion and biosensors. XR devices collect extensive biometric, motion, and
environmental data to facilitate convincing, interactive simulations and
virtual environments in real-time. The breadth and intimacy of the biometric
data collected by XR devices are hitherto unseen in another consumer-grade
product.
XR products on the market today are outfitted with sensors that
generate metrics on pupil dilation and reactivity, heart rate, gaze direction,
hand and head movements, facial expressions, galvanic skin responses, and some
even measure the brain's electrical activity.
Biometric responses tracked throughout gameplay can divulge
personal information far beyond what a user would reasonably expect to reveal
when putting on an XR headset.
For example, eye-tracking measurements can indicate medical
conditions such as ADHD, depression, and personality disorders.[59]
Users may be divulging sensitive information about their health
status that they may not yet be aware of. Additionally, pupil reactivity and
skin conductance can reveal information about arousal and sexual orientation.[60]
VR companies have begun utilising these signals to measure
headset users' cognitive load while performing virtual tasks[61] as well as their attention level and
direction.[62]
XR-enabled emotion recognition systems are being developed,
where machine learning algorithms consider facial expression, vocal inflection,
and vital sign data collected by XR headsets to predict users' internal
emotional states.[63]
These measurements may give XR companies a window into our thoughts, feelings,
and desires without our awareness.
XR devices collect the same biosignals as medical devices used
in healthcare yet are not held to the same strict regulatory guidelines for
processing, deriving diagnostics from, and protecting biometric data.[64]
Such data collection and processing could be ground-breaking for
healthcare applications of XR technology. But, for gaming, productivity, or
workforce applications, these data present users with more risks than benefits.
Such data can present the potential for harms to the user if not properly
safeguarded and de-identified.
For example, third parties could make inferences from basic
gameplay data to discriminate against people for medical conditions, race,
sexual orientation, and other sensitive categories of personal data.
It is nearly impossible to de-identify XR data because the body
motion data is inherently identifiable.[65] XR devices depend on a constant stream
of data about users’ physical movements and surroundings to facilitate
simulations and translate users’ movements into virtual worlds.
Motion data, the most fundamental data stream in XR devices, can
compromise a user’s identity.[66] Research from the Stanford Virtual
Human Interaction Lab shows that body motion data collected in VR can be easily
re-identified to individuals after de-identification and is as personally
identifiable as a faceprint, fingerprint, or voice print.[67]
In a study from the University of California Berkeley, users
were uniquely identified from a pool of over 50,000 people with a 94 per cent
accuracy from just 100 seconds of motion data generated playing Beat Saber, the
most popular VR game on the market.[68]
This data de-identification problem has profound implications
for users’ privacy rights and the applicability of privacy laws like the General
Data Protection Regulation (GDPR).
Companies may be unable to ensure the de-identification of XR
data, which may render corporate adherence to GDPR data de-identification
requirements meaningless for XR data.[69]
Motion data may make it impossible for players to remain
anonymous in the metaverse.
Another concern is consent. Users cannot reasonably consent to
the persistent tracking and monetization of their involuntary biometric
responses throughout gameplay. XR companies inadequately inform users about the
extent of data capture and processing by XR devices and third-party apps.
Users are unaware of what this sensitive information could
potentially reveal about themselves. Moreover, some uses of this data are too
complex and opaque for users to provide informed consent for.[70]
Users lack a real choice to ‘opt out’ of data collection in
metaverse technologies, as extensive biometric and biometrically-inferred data
is mandatory for XR device functionality. Moreover, users cannot be expected to
‘opt out’ of XR technology entirely either to protect their individual privacy,
as this technology may become a primary conduit for information and content.[71]
Integrating a consent-based model like GDPR to uphold data
privacy rights may not work when applied to XR and metaverse technologies. XR
may require a different solution to protect user information.
Alternatives to consent-based models that preserve privacy
should be considered. Some alternatives include privacy-by-design, minimising
data collection to only what is necessary to deliver the XR experience, and
on-device data processing and storage.[72]
These protocols, while a start, will not solve the metaverse’s
privacy problems, given that biometric data can indicate identity.
This means that how existing privacy laws apply to XR data is
not well-defined.Existing laws do not cover the range of biometric data and
biometrically-inferred data categories being collected by XR devices.[73]
XR developers find it difficult to comply with regulations due
to their legal ambiguity in relation to XR.Regulators should clarify how
existing privacy laws apply to XR products to guide XR companies as they build
out XR technology and platforms.[74]
Policymakers should re-evaluate existing privacy laws, such as
GDPR, reviewing consent mechanisms and how they apply. Regulators must ensure
that privacy laws’ definitions for personal data include biometrically-inferred
data, as well as encompassing new data types generated by XR systems that could
indicate identity — namely, motion and heartbeat data.[75]
Regulators should require companies to engineer
privacy-by-design to enable the use of XR without exposing personal
information, as well as restrict the categories of biometrically inferred data
XR companies may share with third-parties.
The companies investing the most in XR technology are Big Tech
giants for whom digital advertising makes up the vast majority of their
revenue, or who predict significant gains in advertising revenue in the coming
years.
For example, Meta and HTC are introducing AI-generated targeted
ads tailored to user interests, inferred from eye-tracking data, in VR.[76]
Another example, Apple announced its first mixed-reality (MR)
headset, Vision Pro, in June 2023, and secured patents on XR technology capable
of detecting the cognitive state of users — states such as curiosity, fear,
attention level, remembering a past experience — and predicting user behaviour
based upon biofeedback data from MR devices.[77] Apple doubled the size of its ad
business staff in 2022 and is expected to expand its ad business to £24.11
billion by 2026.[78]
This phenomenon is called biometric psychography, a concept
coined by US attorney Brittan Heller to describe the use of a person’s
behavioural and anatomical reactions as an ‘involuntary like button’ to
generate insights into their likes, dislikes, preferences, interests, and
motives for the purpose of targeted advertising and to recommend relevant
content.[79]
Previously only possible in small marketing research lab
settings given the extensive biometric sensors required to perform it, XR
technology enables neuromarketing research at an unprecedented detail and
scale. It can predict consumer behaviour and affinities better than traditional
methods of marketing research.[80]
Policymakers must consider how biometric psychography techniques
in the metaverse may be used to influence or manipulate users’ emotions and
decision-making. Companies recording XR users’ brain activity and emotional
responses to elements of virtual experiences without their knowledge or
consent, in order to generate insights about users and better target products,
is ethically questionable.[81]
Sale and sharing of users’ neurological and anatomical response
data to third-party entities, such as political campaigning agencies or
governments, could be used to influence or manipulate users and worsen existing
problems with digital political campaigning.[82]
The use of biometric psychography techniques for political
advertising could gather insights on voters’ neurological responses to
candidates and messages and potentially enable customised political campaigns
designed to elicit desired reactions.
Biometric psychography paired with Generative AI opens pathways
for the creation of highly persuasive and personalised political adverts,
disinformation, and influence operations.[83]
An unregulated global trade of XR data could pose a national
security risk similar to that of Chinese short-form video app TikTok should XR
companies with ties to Beijing fail to handle this data responsibly.
Chinese tech companies are juggernaut competitors in the
emerging XR market. For example, Bytedance’s Pico is the second most popular VR
headset brand on the global market, after Meta's Oculus.[84] Chinese companies Tencent, Baidu,
Huawei, SenseTime, OPPO, and Ping An Group are among the world's top ten filers
of VR and AR patent applications.[85]
Currently, companies take shelter under the rationale that the
data collected is necessary to facilitate convincing virtual simulations and
improve product performance. However, XR devices pose a threat to privacy and
anonymity online because basic data streams from XR devices are inherently
sensitive and cannot be untethered from identity.
Identifying individuals moving throughout the metaverse may
create new privacy breaches, such as identity theft or blackmail. If a person’s
activity in XR, biometric signals, biometrically-inferred qualities, or
attention analytics were linked to their real-world identity, there could be
consequences for users’ privacy, cybersecurity, and personal reputation.
Policymakers and law enforcement must consider how threat actors
will exploit XR and metaverse technologies, as well as urge XR companies to
integrate security-by-design into their products.
The extent of data flow within the metaverse, along with this
data’s diverse applications, pose an escalating risk and expand the cyber
attack surface for users. Cybersecurity risks have emerged in the physical
hardware of XR devices, as well as within the metaverse’s market for
non-fungible tokens (NFT) digital assets.
We can expect these vulnerabilities to be exploited if metaverse
companies do not resolve them and build in security protocols at the outset to
protect users.
Immense volumes of sensitive data flow through XR devices,
making device integrity vital to preserving users’ privacy and information
security. XR headsets and haptic add-ons must be resilient to malware attacks,
distributed denial-of-service (DDoS) attacks, and hacking, as these events may
compromise user privacy and open the door to the theft of personal information.
XR headsets contain a wide assortment of motion and biosensors,
like other consumer-grade devices, including Internet of Things (IoT) devices.
IoT devices are notorious for having cybersecurity
vulnerabilities because they often lack robust security measures.[86] Too often, such devices are not
designed with security in mind.
They often have inadequate encryption and lack sufficient
authentication mechanisms.
It is becoming apparent that XR devices share many of the same
cybersecurity gaps that IoT devices have. In 2022, researchers identified cyber
vulnerabilities in the motion sensors in the Oculus Quest and HTC VIVE Pro VR
headsets.
The built-in accelerometer and gyroscope did not require any
permission to access, so researchers developed a proof-of-concept eavesdropping
attack which enabled them to intercept voice commands and spy on users
throughout gameplay and meetings.
Access to speech content could allow people to steal sensitive
information communicated by users in voice chat or voice commands, such as
passwords and credit card information, potentially leading to user account
breaches, digital avatar and identity theft, and fraud.[87]
Non-fungible tokens (NFTs) will likely become an important
component of the commercialisation of the metaverse. An NFT is a one-of-a-kind
cryptographic token recorded on a blockchain representing a virtual item, such
as a piece of artwork or virtual real estate.
NFTs are purchased via pseudonymous and irreversible
cryptocurrency transactions conducted without intermediaries and with little to
no supervision from authorities.Cybercriminals are increasingly using
cryptocurrency as a payment medium in organised crime and as investment fraud
currency.[88]
The metaverse has attracted a flurry of NFT investors. In 2022,
investors spent nearly £1.75 billion in cryptocurrency on virtual land in the
metaverse.[89]
Major brand-name companies, like Adidas, Nike, Coca-Cola,
McDonald’s, and high fashion brands like Gucci and Dolce and Gabbana, have
launched NFT ventures.
By opening virtual stores and selling collectable items and
avatar apparel, these brands have generated millions in NFT revenue and royalties.[90]
For example, Adidas has generated £8.8 million in NFT sales,
plus £3.82 million in royalties. International celebrities like Snoop Dogg and
Paris Hilton have purchased virtual land on decentralised Social VR platforms
and opened themed virtual worlds for users to meet and buy themed NFT objects
and avatar skins in the likeness of the celebrities.[91]
However, we are beginning to see this unregulated and
unmonitored market be exploited by cybercriminals seeking to profit from
investment fraud scams, money laundering schemes, and the exchange of illicit
materials.[92]
Five US state law enforcement agencies filed actions against a
Russian organisation soliciting American investors and selling fraudulent NFTs
in the metaverse casino Flamingo Casino Club.[93]
Phishing websites impersonating official metaverse brands often
trick private individual investors into divulging login credentials to their
metaverse cryptocurrency wallets, which cybercriminals access and drain of all
assets.[94]
With no centralised authority overseeing irreversible
transaction processes, users are vulnerable to exploitation without sufficient
recourse or support from XR companies and Social VR platforms. Companies offer
little to no support for recovering funds when people investing in metaverse
assets are robbed, beyond reporting to the authorities.
The metaverse’s NFT market is presently a proverbial ‘wild west’
in dire need of regulation to protect users from attacks from fraudsters and to
cut off covert pathways for illegal activity.
XR companies should establish best practices and ethical
standards to protect consumers and enhance trust. This should be inclusive of
erecting resolution mechanisms and refund policies for NFT transactions, as
well as systems for detecting, thwarting, and prosecuting ongoing scams and
attacks.
XR-enabled immersive learning is revolutionising education and
skill training by providing hands-on virtual learning experiences. However, the
misuse of XR's immersive learning capabilities by dangerous individuals and
organisations poses a national security risk.
XR applications in corporate training have translated to faster
learning and improved skills retention.[95] Immersive learning tools train
firefighters, pilots, and construction workers for incidents that would be
costly or dangerous to recreate. The UK and US militaries use the technology to
train soldiers to use equipment and weaponry, develop combat and survival
skills in battle scenarios, and deliver battlefield medical treatment.96[96]
Immersive learning is a powerful, cost-effective delivery tool
for skills training. However, malicious actors may repurpose it in the future
to plot and train to commit acts of violence offline. While this is a
prospective risk that has yet to manifest, expressions of violent extremism
have begun cropping up on metaverse platforms. For example, white supremacists
created and circulated video game re-enactments of terrorist attacks by far-right
extremists on Social VR platform Roblox.[97]
Researchers have discovered first-player shooter games on Roblox
that simulated the 2019 Christchurch mosque shootings in New Zealand, the 2019 El
Paso mass shooting in the US, and the 2011 car bombing and mass shooting in
Utøya, Norway.[98]
Roblox has removed these games and implemented new policies to
address this problem. Still, covert links to new versions continue circulating
within white supremacist Discord channels and dark web groups.
The Online Safety Bill requires Social VR platforms to monitor
and remove illegal terrorism content and swiftly act to secure their platform
to prevent further misuse of affordances.
Regulators must ensure that the new XR companies and metaverse
platforms entering the mainstream understand their obligations under the law to
devote sufficient resources to proactively detecting and removing illegal XR
content.
Moreover, regulators should specify precisely what sufficient
resources entail in the XR medium.
Case Study: Online Extremism &
Dangerous Organisations
There is
growing concern from US, UK, and EU security agencies about pathways to online
radicalisation in online gaming.
While there
is no causal link between violent video games and offline violence, there is
evidence of right-wing extremist, radical Islamic, and ethnonationalist groups
increasingly using online video gaming platforms to target gaming communities
to share propaganda, recruit, and mobilise vulnerable youths and young adults.[99]
Social VR
platforms provide channels for extremist groups and dangerous organisations to
convene, build community, and reinforce in-group beliefs in an immersive way.
Violent extremist groups and dangerous organisations may exploit the
affordances of Social VR to spread their ideology, recruit, and train a
distributed audience on how to commit violence.
Moreover,
bad actors may leverage VR technologies to produce and disseminate propaganda
material that gamifies and glorifies violence to young audiences.
For
example, Roblox hosts ISIS-themed servers where users roleplay as ISIS
militants. The servers host first-person shooter game recreations of conflict
zones in Iraq and Syria, where users can fight ISIS enemies with other players
online.
In February
2023, Singapore’s Internal Security Agency detained two teenage boys who became
radicalised on the ISIS Roblox servers for engaging in terrorist activities,
such as plotting suicide bombings and stabbings.[100]
The young
men pledged allegiance to ISIS and roleplayed as ISIS leaders in the server.[101]
XR companies are developing products and platforms where users
are insufficiently protected from harm and exploitation. Users are unable to
reasonably consent to the extent of biometric data collection taking place.
Social VR platforms and technologies are struggling to enforce their community
guidelines and protect users uniformly at scale.
In their current form, Social VR platforms make guaranteeing
child safety more difficult and creating welcoming spaces for all more
challenging. XR devices gather data that make preserving users’ privacy and
cybersecurity exceptionally challenging.
We can no longer assume that Big Tech will self-regulate
effectively without some level of government oversight.[102] Policymakers should not assume that the
XR industry will voluntarily adopt trusted norms that prioritise the safety and
privacy of users.
We should not leave the safety of children navigating the
metaverse to chance.
To become resilient and applicable to an XR-enabled future, the
UK’s Online Safety Bill and other existing privacy laws require re-visiting to
specifically address the unique risks inherent in XR technologies and metaverse
platforms.
It is vital that regulators be proactive in addressing the risks
of XR technologies now, rather than waiting for the harms outlined in this
report to affect users en masse.
Government and industry will need to collaborate now to envision, innovate, and
deploy solutions for the future.
Below we outline our recommendations for policymakers and
industry to accomplish this.
Recommendations to improve
metaverse platform governance:
1. Expand the UK’s Online Safety
Bill’s definition for what qualifies as content with respect to XR
An updated
definition of what qualifies as content is needed in the Online Safety Bill to
encompass the full range of user-to-user interactions and immersive experiences
possible within XR-enabled virtual environments.
The
definition for content should include:
∙€€€€€ User-generated
avatar skins and accessories
∙€€€€€ Virtual
objects
∙€€€€€ Virtual
rooms and worlds
∙€€€€€ Interactive
games and activities
∙€€€€€ Any
user-generated content created using Generative AI
Regulators
should require XR companies to develop effective responses to address
intersectional harassment and abuse directed toward women, Black, Asian and
minority ethnic (BAME), and other marginalised communities using XR.
Moreover,
Ofcom should encourage XR companies to consider designing in small moments of
friction into gameplay that discourage or prevent users from harmful or illegal
behaviour and breaking platform rules.[103]
2. Regulators, including the UK’s
Ofcom, should be proactive about metaverse technologies
Ofcom
should be proactive about metaverse technologies and regulators should devote
resources and attention to evaluating whether XR companies understand and
adequately fulfil their duty of care obligations under the Online Safety Bill,
enforce age assurance, and actively monitor for illegal content.
Ofcom
should clarify for industry how the Online Safety Bill's definitions for
harassment apply in a three-dimensional medium to the behaviours or
interactions possible in Social VR.
3. Policymakers must establish
expectations that companies actively monitor Social VR environments
Policymakers
should provide clarification on what the expectations outlined in the Online
Safety Bill are for active monitoring and moderation in persistent, live
metaverse environments rather than trusting companies to define this for
themselves. Policymakers can require companies to adopt content monitoring and
hybrid moderation strategies that prioritise safety at scale and reduce the
reporting burden placed on people who have experienced abuse.
Policymakers
also should require Social VR platforms to establish Trust and Safety teams
specialising in the XR medium to compose governance policy and moderation
strategies tailored to the spatial medium.
Recommendation to protect
consumer data in the metaverse:
4. Existing privacy, security and
consumer protection laws need to be re-evaluated to ensure that they apply
across metaverse devices and experiences
Policymakers
must ensure the protection of biometric and biometrically-inferred data
generated from XR devices to safeguard human rights to privacy, as well as
establish obligations to protect users’ cybersecurity. Regulators should also
ensure that privacy laws’ definitions for personal data encompass the new data
types generated by XR systems that may be indicative of identity — namely
motion and heartbeat data.
Policymakers
should consider expanding the transparency reporting disclosure requirements of
the Online Safety Bill to include reporting on data breaches, cyber
vulnerabilities in products, incidents of financial fraud related to
transactions of virtual assets, and biometric and biometrically-inferred data
categories collected. Disclosures should also provide detailed information on
data anonymisation procedures and ethical review processes in place before XR
user data is shared with third-party entities.
We
recommend legislators strengthen existing consumer protection laws to include
provisions that specifically cover NFTs and other digital assets in metaverse
environments. This could include establishing requirements for platforms to
provide clear and accurate information about the NFTs being sold, and creating
penalties for fraud and misrepresentation. Federal authorities should be given
more powers to tackle the use of Web 3.0 technologies to trade illicit or
fraudulent materials.
Companies
should adopt robust policies and implement measures that ensure their products
and services protect and uphold human rights.
5. Governments and industry must
commit to embedding security and privacy by design into metaverse products and
services
Given the
inherent sensitivity of the data collected by XR devices, XR companies must
prioritise security-by-design in their products. Regulators should consider
incorporating cybersecurity requirements into the duty of care obligations of
the Online Safety Bill, ensuring that all hardware and software must be
routinely updated with the latest security patches.
Regulators
must implore companies to practise privacy-by-design and minimise the amount of
personal information they gather. Additionally, lawmakers should re-evaluate consent
mechanism requirements and assess their applicability to the XR medium.
Additionally,
regulators should ensure that privacy laws’ definitions for personal data
encompass the new data types generated by XR systems that may be indicative of
identity. Regulators should require companies to engineer privacy by design to
enable the use of XR without exposing personal information, and as well as
restrict the categories of biometrically inferred data XR companies may share
with third-parties.
Before the widespread adoption of XR technologies, regulators
have a limited window of opportunity to act to ensure its development
progresses responsibly and prioritises user safety and privacy.
The regulatory choices we make today can help prevent the
entrenchment of harmful metaverse developments that could be difficult, if not
impossible, to untangle in the future.
I am profoundly grateful to the following individuals and
organizations for their invaluable contributions and unwavering support
throughout the completion of this project.
First and foremost, I would like to express my deepest gratitude
to the XR and Trust & Safety industry experts who provided invaluable
feedback on the contents of this report: Jeremy Bailenson from Stanford
University, Alex Leavitt, and Sam Gilbertfrom the University of Cambridge’s Ben
Institute for Public Policy. Their expertise and insights significantly
enriched the quality of this work.
I would like to extend my heartfelt thanks to Gina Neff, Jeremy
Hughes, Irene Galandra Cooper, and the entire team at the Minderoo Centre for
their generous support, mentorship, and guidance throughout this project. Their
expertise and encouragement were instrumental in shaping the direction and
scope of my research. Moreover, I am sincerely grateful to the Minderoo
Foundation for their support and funding, without which this project would not
have been possible.
Special recognition goes to Annie Searle, Dr. Megan Aleah Ward,
and especially Dr. Jessica Beyer from the University of Washington. Their
nurturing guidance and unwavering support fueled my interest and passion in
cybersecurity policy.
I would also like to express my gratitude to Nina Jankowicz and
Alexa Pavliuc for their role in cultivating my interests in Trust & Safety.
Their mentorship and guidance over the years have been invaluable.
Lastly, I want to extend my deepest appreciation to my family
for their unwavering support, encouragement, and belief in me throughout my
academic and professional journey.
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Minderoo Centre for
Technology and Democracy
Address:
Alison Richard Building, 7 West Road, Cambridge, CB3 9DT
www.mctd.ac.uk
minderoo@crassh.cam.ac.uk
Report
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