Cyberbullying in Context: Embedding Equity, Evidence and Education in European Policy
Submission to the European Commission Call for Evidence on Cyberbullying
September 2025
Authors: This submission was compiled on behalf of DCU Anti-Bullying Centre by Prof. James O'Higgins Norman and Dr. Alan Gorman. A full list of members of the Centre can be found on www.dcu.ie/antibullyingcentre
How to cite this report:
O’Higgins Norman, J. & Gorman, A. (2025). Cyberbullying in Context: Embedding Equity, Evidence and Education in European Policy: Submission to the European Commission Call for Evidence on Cyberbullying. DCU Anti-Bullying Centre. Dublin. Ireland.
ISBN 978-1-911669-91-3
DCU Anti-Bullying Centre
DCU Anti-Bullying Centre (ABC) is a research centre located at Dublin City University (DCU), Ireland.
The core mission of the Centre is to be a future focused and globally connected European centre of excellence for research and education on bullying and online safety. The Centre hosts the UNESCO Chair on Bullying and Cyberbullying and the International Journal of Bullying Prevention. The work of the Centre has been funded by grants from the Government of Ireland, the European Commission, Research Ireland, and several philanthropic and industry donations. Members of the Centre are drawn from all five faculties of DCU and from a number of other universities and take pride in our ethical practice in conducting research, and the positive social impact our research has on tackling bullying and promoting online safety.
Introduction
We welcome the European Commission’s initiative to develop an EU Action Plan against Cyberbullying.
The rise of digital technologies has created new contexts in which children and young people interact, alongside new forms of aggression that are often poorly understood.
To be effective, the Action Plan should avoid framing cyberbullying as an isolated digital problem. Instead, it must be situated within the broader continuum of bullying that spans both offline and online environments, and
the societal norms that underpin these behaviours.
Our submission is rooted in the UNESCO Whole Education Approach to Bullying and Cyberbullying (2020), which stresses that bullying is not merely an individual behaviour but a damaging social process shaped by schools, communities and wider social norms. This framework is particularly relevant for the European Union, where cross-country harmonisation of definitions, policies and educational practices can amplify the impact of coordinated action.
The Problem of Bullying Offline and Online
Bullying, whether offline or online, remains one of the most persistent threats to the wellbeing of children and young people across Europe. It undermines learning, mental health and social inclusion, with consequences that can persist into adulthood.
Research consistently shows that certain groups are disproportionately targeted, reflecting wider patterns of social inequality. Children from minority ethnic or religious backgrounds, LGBTQ+ youth, and those with
disabilities experience elevated risks of bullying victimisation (Craig et al., 2009; Modecki et al., 2014; Zych, Farrington & Ttofi, 2019; Smyth and Darmody, 2025). On the other hand, having contact with unknown people
online, excessive Internet use, and sensation seeking has been found to be positively associated with engaging in bullying behaviour online (Wachs et al. 2021). These patterns demonstrate that bullying is not isolated
behaviour but an individual, contextual and structural problem that reflects and reinforces societal prejudices, both in schools and in digital spaces.
We recommend that the EU Action Plan adopt UNESCO and World Anti-Bullying Forum’s inclusive definition of bullying which states that:
“…bullying is a damaging social process that is characterized by an imbalance of power driven by social (societal) and institutional norms. It is often repeated and manifests as unwanted interpersonal behaviour among students or school personnel that causes physical, social, and emotional harm to the targeted individuals or groups, and the wider school community.”
(O’Higgins Norman, 2024).
This definition matters because it explicitly situates bullying in societal and institutional contexts, rather than reducing it to individual acts. Bullying reflects and reproduces broader social hierarchies, stereotypes and systemic inequalities. Recognising those dynamics aligns policy with lived realities: marginalised learners are more likely to be targeted, and school climate and institutional practices can enable or constrain harmful behaviour (Craig et al., 2009; Modecki et al., 2014; O’Higgins Norman et al., 2025).
Cyberbullying should be treated within this same lens. It is bullying through electronic means, embedded in the same social processes as offline bullying. Digital technologies can amplify reach, persistence and visibility; however, the underlying dynamics of power, exclusion and harm are fundamentally linked to offline relationships and school/community contexts (O’Higgins Norman, 2024; Livingstone & Smith, 2014).
A substantial body of research demonstrates that most young people who are bullied online are also bullied offline. Wolke, Lee & Guy (2017) argue that cyberbullying rarely occurs in isolation; online victimisation almost always co-occurs with in‑person bullying. Recent reviews and cross-national surveys confirm that offline bullying remains more prevalent than cyberbullying across Europe (Livingstone & Smith, 2014; Smahel et al., 2020).
The ESRI study of bullying in Ireland (Smyth & Darmody, 2025) further shows that offline bullying is more common than cyberbullying and that interventions are more effective when both are addressed together. Crucially, the ESRI finds that teaching children a shared language of bullying, equipping them with clear words and concepts to describe their experiences, leads to higher reporting rates and greater agency.
Additional evidence indicates that offline victimisation often predicts online victimisation (e.g., Pichel et al., 2021), underscoring the importance of integrated prevention strategies that cut across school, home and online settings.
An effective EU Action Plan must navigate a principled balance between children’s (digital) right to be safe and their right to participate (CRC, General Comment No. 25, 2021). Measures that focus exclusively on protection, such as blanket restrictions on platform access, risk undermining young people’s freedom of expression, civic engagement and opportunities to develop digital resilience, not to mention an unintended negative impact on student-teacher relations and the culture within schools (Reynolds et al., 2025).
A (digital) rights-based approach requires that children are not only shielded from harm but also empowered as active participants in shaping safer digital environments. This principle is anchored in the UN Convention on the Rights of the Child, including Article 12 (right to be heard) and Article 13 (freedom of expression). Children and young people should be given meaningful opportunities to co‑design prevention strategies, contribute to awareness campaigns and hold institutions and platforms accountable. Furthermore, youth social norms can limit the effectiveness of the interventions so there is also a need to involve youth in platform decisions regarding AI design (Milosevic et al. 2023)
The UNESCO Whole Education Approach provides a roadmap for systemic action. Applied at EU level, it implies coordinated measures across four interlocking dimensions:
Policy and legislation: Harmonise definitions across Member States using UNESCO’s framework and align obligations with the Digital Services Act (2022/2065), which requires platforms to assess and mitigate systemic risks to minors, increase transparency and provide researcher access to data.
Learning environments: Integrate bullying and cyberbullying education into curricula with an emphasis on self-efficacy, empathy, digital literacy and peer‑led initiatives. Establish youth panels to shape school policies and national strategies so that the voices of children and young people are systematically included.
Capacity building: Train teachers, school leaders and parents to recognise and respond to bullying using a shared language and clear protocols; invest in Safer Internet Centres and helplines so that support is accessible and evidence‑based.
Community engagement: Build strong school‑community partnerships that involve families, youth workers and civil society organisations in prevention and intervention. Particular attention should be paid to groups at higher risk of victimisation.
Social media, gaming and technology companies must play their part, but regulation should complement, not replace, education. Under the Digital Services Act (2022/2065), platforms have obligations to provide accessible reporting, mitigate systemic risks and publish transparent risk assessments. The Action Plan should reinforce these duties while ensuring that regulation does not unnecessarily restrict children’s access to online spaces.
Effective solutions will come from shared responsibility, schools and communities providing education and empowerment, platforms ensuring safety and transparency, and policymakers creating frameworks that hold both accountable.
Recent international health research shows that cyberbullying continues to affect a significant minority of young people. According to the HBSC International Report, Vol. 2, about 15% of adolescents across 44 countries and regions in Europe, Central Asia, and Canada reported being cyberbullied in the 2021/22 survey cycle (Cosma, Molcho, & Pickett, 2024). Parents, educators, and policy makers have genuine concerns about the role of smartphones and social media in the lives of children and young people and are searching for policies and solutions that might address this problem. In this context, the public debate on cyberbullying in Europe, as elsewhere, often gravitates toward smartphone bans.
However, research shows why this approach may be problematic. One major study did find that restrictive school phone policies reduced phone/social media use during school hours (by about 0.67 hours for phones and 0.54 hours for social media). It also found no evidence that these policies improved overall mental wellbeing, academic outcomes, physical activity, sleep, or other health/education measures compared to schools without such bans (Goodyear, 2025). Furthermore, smartphone bans may have unintended negative consequences for the rights and agency of children and youth as well as overall relationships within schools and communities (Reynolds et al., 2025; Ombudsman for Children, 2025).
While bans might temporarily reduce in-class distractions, they do little to address the relational and cultural factors that drive bullying. More fundamentally, phone bans risk positioning technology as the cause of bullying, rather than a medium through which it manifests (Gorman & O’Higgins Norman, 2025). This misdiagnosis leads to misplaced solutions. In practice, bans can create adversarial dynamics, with teachers forced into policing roles, confiscating devices, and negotiating constant boundary disputes. Far from reducing bullying, this may generate new flashpoints of conflict between staff and students.
We have documented how governments and policymakers adopt such measures because they are highly visible, easily communicated, and politically saleable (Gorman & O’Higgins Norman, 2024). They allow policymakers to demonstrate action without engaging with the complexity of bullying. In this sense, phone bans exemplify a broader trend of policy by optics, where interventions are adopted for symbolic value rather than empirical validity. This is why we argue that the European Action Plan must explicitly resist the allure of low-hanging fruit. The Commission’s leadership is needed to set clear expectations that policies must be grounded in evidence, not political expediency
Our research consistently shows that professional learning is a decisive factor in determining whether anti-bullying policies have an impact in schools. The DCU Anti-Bullying Centre has designed and delivered professional learning for teachers and leaders, including workshops for the Department of Education and training for schools across the country (O’Higgins Norman et al., 2023). Our evaluations indicate that when professional learning is sustained, dialogic, and practice-based, it significantly enhances teacher confidence, improves consistency across staff, and fosters a stronger school culture (Feijóo et al., 2024).
Key features of effective professional learning include:
- Sustained engagement: ongoing coaching, mentoring, and communities of practice, rather than one off workshops.
- Active learning methods, such as role-playing, case study analysis, and structured reflection, enable teachers to rehearse responses.
- Collaborative practice: opportunities for staff to build collective responsibility, not isolated learning.
- Contextualisation: aligning professional learning with the realities of each school’s demographic, culture, and challenges.
- Equity focus: embedding awareness of diversity, vulnerability, and marginalisation.
We also emphasise that professional learning must extend beyond classroom teachers. Principals, deputy principals, guidance counsellors, special needs assistants, and ancillary staff all have roles to play. Furthermore, parents must be supported as partners in prevention and response. The implication for the European Action Plan is clear: professional learning must be a core requirement, not a discretionary extra. Member States should be expected to fund and deliver structured programmes for all staff and parents. The EU can support this by incentivising professional learning and disseminating models of good practice.
In our studies of school principals, we found that leaders often entered their roles with heroic images of leadership shaped by anticipatory socialisation but were quickly confronted with the realities of managing diversity and conflict (Gorman & O’Higgins Norman, 2024). Many expressed a lack of preparation for addressing equity in their leadership practice. This gap has direct implications for bullying: without explicit attention to power, diversity, and inclusion, schools can unwittingly perpetuate inequities in their responses (Skinner et al., 2014). European policy must recognise this. Equity cannot be treated as an optional add-on. It must be embedded in leadership development, policy frameworks, and funding structures (Grissom et al., 2021; Yoon & Bauman, 2014). Our research demonstrates that when equity is placed at the heart of leadership, schools are better equipped to address bullying in all its forms (Foody et al., 2018; Gorman & O’Higgins Norman, 2024). The Action Plan should therefore make equity-oriented leadership a central pillar of European strategy.
In some systems, policies are centrally mandated, with schools instructed to adopt standardised templates that often feel disconnected from their day-to-day realities. In others, schools are left largely to their own devices, tasked with developing local responses but given little in the way of guidance, resources, or professional learning. Neither approach is sufficient. A more balanced model is required, one that recognises schools as professional communities capable of developing their own anti-bullying policies while also ensuring that they are not left isolated in doing so (Gorman & O’Higgins Norman, 2024; Maguire et al., 2010). Schools are best placed to recognise the dynamics of their communities, the cultural and linguistic diversity of their student populations, and the patterns of behaviour that characterise their local contexts. Empowering them to design their own policies fosters a sense of ownership and authenticity, allowing staff, students, and parents to view these policies as living documents rather than externally imposed requirements.
Yet, empowerment without support risks fragmentation in local policymaking. Schools cannot be expected to build comprehensive responses to cyberbullying if they must do so in a vacuum. Professional autonomy must therefore be accompanied by coherent frameworks of assistance that connect local efforts with national and European strategies. These frameworks should not dictate practice but rather enable it, providing evidence-based models that schools can adapt, professional learning opportunities that strengthen capacity, and national/regional infrastructures that offer coaching and feedback. In this way, empowerment and support become mutually reinforcing.
Cyberbullying is not an isolated digital threat but part of a broader social process of bullying rooted in societal and institutional norms. By embedding the UNESCO Whole Education Approach, grounding action in evidence and balancing the rights of children to both safety and participation, the European Union can deliver an Action Plan that protects and empowers. Such a plan will reduce harm while promoting resilience, solidarity and inclusion, values central to the European project.
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