Abstract
Many jurisdictions have introduced offences specifically tailored to address the range of behaviours that constitute intimate image abuse. These offences are designed to provide better protection for victims by facilitating the reporting, policing and prosecution of intimate image abuse. Based on a thematic analysis of 15 in-depth, semi-structured interviews with legal and service provider stakeholders, this article explores perceptions about whether the four new offences enacted in Hong Kong in 2021 have improved the policing of intimate image abuse. Themes explored include the factors that impact victims’ willingness to report and those that shape police responses to complaints of intimate image abuse. A key finding is that while there is a perception that police responsiveness to complaints of intimate image abuse has improved since the enactment of the new offences, there is still room for improvement. An implication of this research is that there is a need for greater training and education of the police. Such training should cover not only the content of the new law and how to gather evidence to support prosecution, but also the nature of intimate image abuse and how police can engage effectively and sympathetically with complainants.
Introduction
The need for a criminal law response to Intimate Image Abuse (IIA) has been increasingly recognised over the last two decades with evidence revealing the significant harm that can be caused by behaviours such as non-consensually observing, recording, creating, distributing and threatening to distribute images of intimate parts and acts (Bloom, 2016; Crofts, 2024; McGlynn & Rackley, 2017; Powell et al., 2020; Salter & Crofts, 2015). A range of names have been used to refer to these behaviours, including, for example, “revenge pornography”, “non-consensual pornography”, “up-skirting” and “down-blousing”. These labels are problematic because they do not appropriately reflect the harms, motivations and culpability of perpetrators (Citron & Franks, 2014; Powell et al., 2020; McGlynn & Rackley, 2017). Some therefore prefer the term “image-based sexual abuse” (McGlynn & Rackley, 2017; Powell et al., 2020). Here the term “intimate image abuse” is used because, in the words of the Law Commission for England and Wales (2021, para 1.15), “this is an inclusive term which encompasses first, the nature of the images … and secondly, the range of harmful behaviours demonstrated by perpetrators” (see also, Caletti & Summerer, 2024).
Despite growing recognition that intimate image abuse is deserving of criminalisation, research has shown that there have been low levels of police investigation and prosecution of IIA (Henry et al., 2018; McGlynn et al., 2019). This has been explained by police having a poor understanding of the nature and seriousness of IIA and a lack of knowledge about what offences were applicable (Henry et al., 2018; McGlynn et al., 2019). Lack of police responsiveness, as well as victim-blaming attitudes among the police and the public, have also meant that victims have been uncomfortable or unwilling to report, or saw no use in reporting, IIA to the police (Bothamley & Tully, 2018; Henry, 2024; Huber, 2025; Short et al., 2017).
In order to overcome these difficulties and to better protect victims of IIA, many jurisdictions have adopted IIA-specific offences (Crofts, 2024). The introduction of specific criminal offences should, arguably, improve legal responsiveness as police and prosecutors can more readily connect the harmful behaviour to the relevant charges (Welsh, 2025). These offences also send a powerful symbolic message to police that IIA is to be taken seriously. Moreover, specific offences present a clear social message that IIA is not acceptable and that focus ought to be on the harmfulness and culpability of the perpetrator's behaviour rather than blaming and/or responsibilising victims (Bothamley & Tully, 2018; Crofts, 2024; McGlynn & Rackley, 2017). As such the communicative effect of new offences can help decrease the stigma around IIA and victim-blaming attitudes (Huber, 2025; Welsh, 2025). This can lead to increased rates of reporting and improvements in police responses. Research from various jurisdictions is, however, showing that despite the creation of specific offences there are still ongoing issues in relation to policing IIA (Henry et al., 2018; Huber, 2025; McGlynn et al., 2019).
With these issues in mind, the research reported in this article explores the impact that the adoption of four new IIA offences in Hong Kong in 2021 has had on the policing of IIA. Methodologically, insights into this research question were gained through in-depth, semi-structured interviews with 15 stakeholders from legal and service provider backgrounds. A range of themes were identified through a thematic analysis of these interviews, including factors that are perceived to impact on victims’ willingness to report and shape police responses to complaints about IIA. A significant implication of this research is that there is a need for greater training and education of the police about the nature of IIA and the forms it can take. Such training should also address the laws that apply, what evidence should be gathered and how to deal effectively and sympathetically with complainants. These findings are valuable not only for Hong Kong but also for other jurisdictions that are developing or amending laws and strategies to better protect victims of IIA and ensure that police respond appropriately when such abuse is reported to them.
Background on the policing of intimate image abuse
Over recent decades the varied and emerging ways that IIA can be perpetrated through new technologies and the harms that it can cause have been increasingly researched and better understood (Bates, 2017; Law Commission, 2021; McGlynn et al., 2019, 2021; Powell et al., 2022; Henry & Powell, 2015; Rackley et al., 2021; Salter & Crofts, 2015). Recognising the forms that IIA can take and impacts that it can have, it is now generally accepted that culpably causing harm to victims by engaging in such behaviours should be subject to a criminal penalty (Bloom, 2016; Crofts, 2024; Kirchengast & Crofts, 2019; McGlynn & Rackley, 2017; Powell et al., 2020; Salter & Crofts, 2015). Accordingly, many jurisdictions have introduced specific offences designed to better protect victims of IIA rather than trying to shoehorn the behaviours into pre-existing offences. Despite this, research from various jurisdictions has shown that many cases of IIA are not reported and, even when they are, there has frequently not been a consistent or adequate response by police (Henry et al., 2018; McGlynn et al., 2019; Powell & Henry, 2018). This leaves many victims of intimate image abuse feeling frustrated, unsupported and let down (Huber, 2025).
A key explanation for inadequate police responses is the ongoing lack of awareness about the nature of IIA and relevant laws (Henry et al., 2018; Huber, 2025; McGlynn et al., 2019; Welsh, 2025). Research by Bond and Tyrrell (2021) found that 78% of police officers in England and Wales had an average or patchy understanding of IIA, and 5.9% had no knowledge at all. More recent research by Huber (2025) indicates that stakeholders felt that police in England and Wales still do not know much about the legislation and nature of the relevant offences. Similarly, the Law Commission (2021, para 1.41) reported that a common theme they identified was the difficulty in identifying offences that could apply.
Even where the police do find appropriate offences, difficulties in identifying the perpetrator and collecting evidence, especially where there are jurisdictional issues, such as an overseas perpetrator or uncooperative international service provider, have been noted to hinder police action (Powell & Henry, 2018). Investigation can also be made more difficult because police may not be in touch with technological developments and the continually emerging ways technology can be used to perpetrate IIA (Powell & Henry, 2018). A lack of resources allocated for investigation and evidence gathering has also been noted to contribute to the view that IIA cases are too difficult to prosecute (McGlynn et al., 2019).
Aside from patchy knowledge about IIA, relevant laws and evidence gathering difficulties, it has also been found that there is a tendency among police to see such behaviours as not serious, particularly because of the perception that online crimes are not as “real” as offline crimes (Huber, 2025). Powell and Henry (2018, p. 301) note that this “minimisation of digital forms of abuse, violence and harassment perhaps stems from a fixation on corporeal or bodily forms of harm, as opposed to harms that are structural, social, emotional or psychological” (see also Bailey & Dunn, 2024). Relatedly, research also reveals that harm minimisation and victim-blaming attitudes by police are still a significant issue (Huber, 2025; McGlynn et al., 2019), and these have been linked to low reporting rates (Henry et al., 2018). Such attitudes can lead to police not seeing the need for intervention, instead proposing that the matter can be resolved by the victim taking precautions, such as taking a break from online interactions (Huber, 2025; Jane, 2017). It should be noted, however, that these issues were not found to be consistent across all police forces and that differences have been observed in relation to the size and workload of various forces (Huber, 2025; Law Commission, 2021, para 1.41).
Unsurprisingly, research from the United Kingdom has shown that victims of IIA have often had negative experiences when reporting to the police (Huber, 2025; McGlynn et al., 2019). For example, a Law Commission of England and Wales consultation paper (2021) has found that victims may be reluctant to report to the police because of feelings of shame and self-blame. Such feelings that can be worsened “especially if the victim is forced to disclose the image which caused them so much shame and humiliation” (Law Commission, 2021, para 5.24). This may explain why around two-thirds of victims who call the Revenge Porn Helpline in relation to the non-consensual sharing of their intimate images do not go on to report the matter to the police (Law Commission, 2021, para 1.46). When victims have reported, they relate feeling that the police did not deal with them sympathetically and this “amplified their feelings of shame and embarrassment” (Law Commission, 2021, para 5.25; see also McGlynn et al., 2019). Even if their case is not dismissed victims’ distress may be compounded by being “advised not to delete images in case they are needed as evidence” (Law Commission, 2021, para 5.25). Feelings of frustration among victims have also been noted to arise from a lack of appropriate communication and not being kept updated on the progress in their case (Huber, 2025).
There has been no research specifically on the policing of intimate image abuse in Hong Kong. More generally, research reports that the Hong Kong Police Force (HKPF) has been regarded as one of the most respected police services in the world (Adorjan et al., 2021; McCarthy et al., 2023; Sinclair & Ng, 1997). This is largely the result of changes to the colonial style of governance, social reforms and concerted efforts to stamp out corruption in the 1970s (Chan & Lau, 2016). These reforms were designed to improve the legitimacy of the colonial government in the face of the anti-colonial protests of the 1960s (Adorjan & Lee, 2017; Chan & Lau, 2016). However, in recent years, the level of trust in the police among the public had fallen in Hong Kong (Ho & Li, 2025; Hong Kong Public Opinion Research Institute, 2020). This can be explained by recent events that “placed the HKPF in highly visible public order situations” (McCarthy et al., 2023, p. 96). This includes protests that have arisen as a result of the socio-political changes resulting from the return of Hong Kong to China in 1997 (McCarthy et al., 2023). However, a survey of the public in 2024 has shown improvements in feelings of safety and confidence in the police in Hong Kong (Hong Kong Police Force, 2024a).
Against this background, the current project aimed to investigate stakeholder perceptions of whether the enactment of four new offences in 2021 has improved police responses to complaints of IIA in Hong Kong. These offences were enacted later than many other common law countries had adopted such offences. This meant that the Hong Kong provisions were informed by emerging best practice in other jurisdictions (Crofts, 2025). The first offence, termed “voyeurism”, found in section 159AAB of the Crimes Ordinance (Cap 200), covers surreptitiously observing or recording images of another person in circumstances giving rise to a reasonable expectation of privacy. Installing or operating equipment to facilitate the above behaviours is also voyeurism.
The second offence, “unlawful recording or observation of intimate parts”, found in section 159AAC of the Crimes Ordinance (Cap 200), is designed to address behaviours colloquially referred to as up-skirting and down-blousing. It applies where a person records an image showing an intimate part of an individual in circumstances where the intimate part would not ordinarily be visible. It must be shown that the perpetrator acted with disregard for whether the subject consented (knowing the subject did not consent or being reckless as to the lack of consent) and acted dishonestly or for a sexual purpose.
The final two offences relate to distributing intimate images. The first, in section 159AAD of the Crimes Ordinance (Cap 200), applies to the publication of intimate images obtained through one of the previous two offences, where the perpetrator knows or is reckless as to whether the image originates from the commission of an offence, and they disregard whether the subject consents to the publication. The second publication offence, found in section 159AAE of the Crimes Ordinance (Cap 200), concerns publication or threatened publication of an intimate image without the consent of the subject, where the perpetrator disregards the subject's lack of consent regarding publication and intends to cause humiliation, alarm or distress to the subject or is reckless as to the likelihood of causing such harm.
Methodology
This research project aimed to understand perceptions of how IIA is policed in Hong Kong, in particular, whether the offences introduced in 2021 are improving the policing of IIA. Semi-structured interviews were chosen as a way to gather in-depth insights from stakeholders who could have important and varied perspectives on the research question (Britten, 1995). Stakeholders were selected using a range of methods, including reviewing policy documents and searching webpages, to identify those who may have experience with cases of IIA. Additionally, a snowball technique was adopted, whereby those who agreed to take part in the project were asked for recommendations about other potential participants (Noy, 2008). A large number of rejections were received, with the primary reason being a lack of knowledge of, or experience with, IIA cases. The police research unit was invited to take part in this project, but declined for operational reasons. This may be the result of police feeling under-staffed and so lacking the time to participate in academic research (Ho & Li, 2025). It may also be because police perceive that their image has recently been tarnished by “disinformation and unsubstantiated allegations” in social media (Ho & Li, 2025) and so are more cautious about external engagements. This presented a limitation because there was no opportunity to balance perceptions of policing with the perspectives of the police themselves.
In total a sample of N = 15 stakeholders (seven practising lawyers, six NGO workers, one magistrate and one from an independent statutory body) took part in this project in 2024. A set of indicative open-ended questions were developed (Britten, 1995) based on a literature review of the types of issues that had arisen in research on this topic in other jurisdictions. This meant that specific aspects of the research question could be addressed while giving stakeholders space to explore themes they saw as relevant that may not have been anticipated when forming the questions. The interviews (n = 13) were undertaken in English with a research assistant present who could communicate in Chinese (Mandarin and Cantonese). Two stakeholders provided written answers. In accordance with ethical procedure approved by the Human and Artefacts Ethics Sub-Committee of City University of Hong Kong, the interviews were recorded and transcribed anonymously before being analysed. The stakeholders were identified according to their experience as either Legal Professionals (“LP”) or Service Providers (“SP”) and numbered to preserve anonymity.
Adopting a thematic analysis, the transcripts and written answers were coded inductively and thematically by both a research assistant and the researcher independently for intercoder or interrater reliability (Braun & Clarke, 2006). As coding progressed, sub-themes and themes were identified, with those which were repeated identified as key themes. Some studies suggest that data saturation (i.e., the point at which information is repeated rather than new information being added (Saunders et al., 2018)) occurs with 9‒17 interviews (Hennink & Kaiser, 2022). Others suggest this can occur with as few as six interviews (Guest et al., 2006). The number of participants in this study was at the higher end of this range, and from a coding perspective, saturation began to occur after only a few interviews. The themes that were identified, and which are explored below, relate to perceived influences on victims’ willingness to report, factors impacting police responses (including the availability of offences; the ease of identifying the perpetrator, gathering evidence and resourcing; perceptions about IIA and variance among police). In the following quotes from stakeholders are reported directly from the transcript and only lightly edited to replace filled pauses, which do not affect the meaning of what was said (such as “um”, “ah”, and “like”), with ellipses to improve readability (Powers, 2005).
Findings
Victims' willingness to report to police
A starting point in action being taken on IIA is whether the victim is willing and comfortable to make a complaint to the police. Stakeholders noted that a significant impediment to reporting to the police was victims’ feelings of shame, fear of stigmatisation and victim-blaming: Some victims fear … their image related to … sexual activities will get … known by other people, especially if they are in a profession. [SP1] Maybe the victim is a bit shameful and … they don't want to go to the authorities … because oftentimes, it's not usually the victim that reports the case. It may be a family member or social worker, or a school teacher. [LP4] I think most victims in Hong Kong prefer not to report their cases. … They just think that, … I'm so stupid … sending those images to them. So … think it's their own fault … especially for those with a traditional mind … and not only that … if a woman says that … I've been … blackmailed because … that guy used my nude photographs to blackmail me, the society may say, well, you deserve it. … So if you do not have the support of the society, … if I were the victim, I wouldn’t [be] willing to report. [LP6] Males … who … sought help, many of them come from the LGBT community … and so they are facing … different kinds of stigmas … by revealing the experience because … they are afraid that this will … force them to … come out and they don't want that part. [SP2] Those people who get blackmailed is not only afraid of their nude photo or dick pic … get spread out, also, they are afraid of … getting coming out … they afraid their family or … in the workplace know that they are gay. [SP1] I think most of the men who … encounter those events, they are not very willing to tell others until they cannot support themselves … And in the beginning, I think most of them is trying to deal with it themselves … usually, they will not find support from friends or family … because … they afraid of the shame. [SP1] People might not even want to go to the police because it takes time to take … a statement. [LP8] I mean, for some of the victims, even if the cases are quite serious, so from our perspective is serious, … they decided not to pursue any legal actions because they could not … bear the pressure or they don't want to, … they don't have the … courage to … speak in front of the judges. [SP2] Some of them just want their images being taken down from the internet … for some, they choose to report the case because they think the abuser should pay their cost … they think that … they don't want more people being victimised. [SP2] Most of them really want to find out who is the distributor and want them to be prosecuted, but at the same time they also want the images to disappear. [SP3] Victim might not want to see offender punished, but the remedy that the victim can get is quite unclear. [LP3] If more victims are willing to share and more victims’ stories being told on the internet and then people know … there were huge impacts … brought by these kind of abusive acts. [SP2]
Factors impacting policing responses
Availability of offences
Stakeholders, particularly legal professionals, generally agreed that police have always taken reports of intimate abuse seriously, but it was not easy to successfully prosecute. As revealed by the following comments, this was thought to be largely because of the difficulty in finding an appropriate offence to cover the behaviour: Despite their best efforts, given the lack of legal framework surrounding the issue, they often had to turn away people who sought help … even where the police did try to press charges against the perpetrators, they were often unable to successfully prosecute them. [LP5] It was always problematic as to what charge to bring and they tried a number of different charges over the years. [LP7]
Stakeholders agreed that since the enactment of the new offences, there appears to have been an improvement in how police deal with complaints of IIA. Simply having specific offences was thought to be beneficial: “I suppose the biggest benefit of the new legislation is, first of all, you have a dedicated offence” [LP7]. Furthermore, the new offences overcome some of the definitional problems associated with existing offences, by, for example, “cover[ing] conducting private or in public” [LP7].
More fundamentally, it was identified that the new offences give a clear direction to the police that action should be taken against perpetrators: [The police] have more motivation … because told by the law that they need to … take up the case … they … no longer have the excuse to … reject … our clients. The police officers, they now … open the file and then they will put [it] to Department of Justice and let them decide if … [they] want to prosecute or not … Now … more than 90 percent of … intimate image … cases … who reported the case to police … they got their case file open. [SP2] In my experience … the police is very helpful … they show their … concern, show their … passion on the case … I think the attitude at that moment is okay … at least the victims feel like … the police do not ignore them. [SP1] The training and also a lot of the thing that is supposed to be provided with the police, that is not there. [SP3] We still have to remind the police that this, this all exists because sometimes … we just feel like they don't know what's going on. [SP3]
Ease of identifying the perpetrator, evidence gathering and resourcing
While generally agreeing that there have been improvements in policing since the new laws, stakeholders did note that certain types of behaviour are more likely to be investigated and prosecuted. This was thought to depend largely on whether the perpetrator can readily be identified and evidence gathered to support a prosecution. Cases involving voyeurism or the non-consensual recording of images, particularly inside Mass Transit Railway (MTR) stations and trains, were thought more likely to lead to successful prosecutions because the perpetrator is usually readily identifiable: It's easier to catch people doing it like in the MTR … but if it's like posting pictures, it's harder … to prove. [LP1] Usually voyeurism type of cases/cases involving [a] known perpetrator are very straightforward so directly go to the police … [for] those kind [of cases] … the successful rate is actually … quite high because usually … the evidence would be the person got caught. [LP1] Usually, these cases … they're caught red handed and it's usually quite easy for the police to solve, … the witness finds out right away, and then they make a fuss … and they call the police, and then the phone is seized. [LP4] Upskirting you just have to look at the CCTV … and … [for] voyeurism as well. [SP3] [The] victim would be … oblivious to it. They'd be … going up the escalator, minding their own business, and then somebody … down the escalator says, hey, you stop that … There have been instances where the public has got involved and roughed the person up. But more often than not, they'll just hold them until the police call … the MTR staff are quite good at contacting the police, getting them straight to you. [LP7] Sometimes … it's … blackmail by someone they already know or encounter already … In this scenario, maybe [it's] more easier for the police to take action. [SP1] The people who … encounter someone online and then send their … dick pic or lewd photo to the strangers … and then that stranger will blackmail … the victims, and then ask him to buy … some … cards in the 7Eleven, the porn card, or … transfer money … in this scenario, [it] is very difficult to do anything … The police is trying to do something because … the police accompanied the victim to the 7Eleven, but no one appeared. [SP1] For the non-consensual sharing cases, they usually encounter huge problems in identifying the abusers … because they found the image being spread on the internet, but they … don't have very concrete clues about who are behind the social media accounts … then the police did not … pay much attention to this kind of … cases because they think that the evidence is not strong. [SP2] [It is] more difficult to prosecute someone who uses an account because you need to prove that this account belongs to that person … and that itself is very difficult. [LP1] It is still difficult to identify the wrongdoer in the online world. [LP3] Most of the users would use the server … abroad … and so their IP address may not be in Hong Kong, and then [the police] would say … it's hard to prosecute overseas and they will say there is not enough evidence and … they cannot identify the distributor too. [SP3] It's hard to find the IP address and also find the … one that will spread that … and then, this is quite difficult to collect the evidence to prove. [SP5] Most of the time when the investigator wants to check the IP address of … the distributor, they have to pass the information to … the team called cyber-security-team, and that takes time because they have to queue … and for the image based sexual abuse cases, that would be a more lower priority. [SP7] I don't think they have allocated enough resources and attention to these kinds of cases … they usually use the excuse that … oh, I could not trace the perpetrator. [SP2] For victims that know who distributed it and perhaps who took the image … they go to police and insist for the police to … push forward with the investigation … sometimes they do see that it's not something that police are very willing to do initially because of the effort they have to put in to investigate and also perhaps to … identify … all the … tracing, all the works. [SP3]
Perceptions about intimate image abuse
Some stakeholders felt that police may view IIA as less serious than other crimes, such as internet fraud and other sexual offences, or they are too busy dealing with such cases. This was thought to be a reason why complaints of IIA may not be prioritised by police: They just think that, well, we prefer to do some hardcore crimes rather than doing this kind of … internet thing. [LP6] They are too busy dealing with other cases. So, these kind of … minor cases, they will get like, just leave it … don't report it, don't complain, don't make a fuss, basically … They tend to prioritise what they want to deal with. [LP8] I think intimate image abuse … is not a serious offence from their perspective. I mean, compared to other criminal offences. [SP2] I think, even though the law is passed … in terms of a lot of … front line operations in the law enforcement … they still don't see it as … abuse. They still see it as a private … dispute. [SP3] For example, they will say this is just a dispute between [a] couple, … it's just a disagreement between you and your ex-boyfriend and then you deal with it at home. [SP2] Nowadays, they do work on it a bit, but they also … have this approach of … it's kind of like mediation … if you people can settle it yourself, then why do all this paperwork? [LP8] The victim might get told, … like, oh, well … it's just a picture, he deleted it already. Why do you still care? Just drop it. [LP8]
Variance among police
Stakeholders identified that there was a degree of variance in the way police officers respond to reports of IIA and that it is important not to see the police as a single body. Differences in approach were attributed to various factors, such as the station where the officers are based and the availability of specialist teams: We talk about police as [if] it is a quite unified body, but … we know [from] a lot of experience [it] is quite different … depending on like police stations. So different stations are different. … Even different teams, they may have different practice. [SP3] I think it's also … a lot of variation in how police handle the case. Some of them may be really helpful. [SP6] After you get through the duty officer, sometimes things can get … slightly smoother. Like they have more sensitivity … afterwards. [SP3] One of the senior officers … he's not very familiar with the LGBT issues, but at least he shows his care. … But for the … junior or the … lower class police officer maybe … sometimes … [they are] saying something wrong. [SP1]
Stakeholders also commented that police were more likely to take action if the complaint was made to a specialised unit. For example, there are specialised teams that deal with child abuse (“Child Abuse Investigation Unit”), and so it was more likely that action would be taken where the complaint concerned a young person: Where it's like child abuse or child sexual abuse … they have a specialised team for that. [SP3] Because … this is related to underage [person] … the police will provide more … concern about that. [SP1]
Discussion
This study has found that the issues concerning the policing of IIA in Hong Kong resonate with those identified by research in other jurisdictions. Despite the enactment of new offences, there are still concerns about the comfortablenss and willingness of victims to report IIA to the police. Main factors deterring victims from reporting are feelings of shame and embarrassment and fear that reporting will expose intimate information about the complainant. Reluctance to make a complaint was thought to be particularly prevalent where the victim was male and especially a member of the LGBT+ community. This accords findings of the Law Commission of England and Wales (2021). The Law Commission noted in its consultation paper (2021, para 5.95) that LGBT+ victims of IIA “report feeling ashamed and humiliated, because they have been revealed as not conforming to society's expectations about their gender or sexuality”. Being “outed” can expose an LGBT+ person to a range of harms: “Their family and friends may attempt to control or erase their sexual or gender identity, they may cut off emotional or financial support, or they may cease contact altogether” (Law Commission, 2021, para 5.92). This can lead to significant emotional and psychological harm and even homophobic violence (Law Commission, 2021; see also Meechan-Rogers et al., 2021). As Bailey and Dunn (2024) comment, the harms of IIA disproportionately affect women (cis and trans) and are amplified for victims experiencing multiple marginalisations. Research also shows that LGBT+ individuals are more likely to experience intimate image abuse than heterosexual persons (Meechan-Rogers et al., 2021; Powell et al., 2020).
Responses indicating that feelings of shame, self-reproach and fear about intimate information, especially about sexuality, being revealed are considered to be a barrier to reporting are unsurprising given similar research findings in other jurisdictions (Law Commission, 2021; McGlynn et al., 2019; Short et al., 2017). These feelings may be somewhat heightened in Hong Kong, where social attitudes, particularly among the Chinese, are influenced by a mix of Confucian and Christian values, leading to quite a sexually conservative society (Kwok & Wu, 2015). Research on related issues has also shown that there is a culture of victim-blaming in Hong Kong society, particularly in relation to sexual harassment (Equal Opportunities Commission, 2019, para 4.6.14; Tsui, 2020). Such cultural attitudes can deter victims from disclosing their experiences to others and can encourage perpetrators of sexual harassment to feel that their behaviour is justified (Equal Opportunities Commission, 2019, para 4.6.13). Despite this, new offences can improve things by demonstrably communicating to the community that IIA is harmful and wrong. Specific offences can also lead to more open conversations about IIA, especially when connected to public education campaigns designed to inform the public about the new laws (Crofts, 2025). It is noteworthy that despite research showing a downturn in trust in the Hong Kong Police Force in recent years (Ho & Li, 2025; McCarthy et al., 2023), a general lack of trust in the police was not mentioned by stakeholders as a perceived impediment to reporting. This may be because the lack of trust is more commonly associated with matters of public order and protest. It may also be due to more general improvements in feelings of safety and confidence in police in recent years (Hong Kong Police Force, 2024b).
Factors that were perceived to drive victims to report to the police were the desire for compensation or punishment of the perpetrator. However, a more common reason identified by stakeholders in cases of distribution or threats to distribute was the expectation, or hope, that police could help them have the images removed from the hands of the perpetrator or from online circulation. When the new offences were enacted in Hong Kong, a procedure was introduced to allow a magistrate to issue a disposal order requiring a person to delete images. A limitation of this provision is, however, that the order can only be made once the intimate image is the subject of criminal proceedings. As such, police are not well-positioned to assist with the removal of images. In fact, as noted by stakeholders, police may actually recommend to the victim that the images not be removed so that they can be preserved as evidence. This appears to not be an uncommon practice, as confirmed by research from other jurisdictions (Huber, 2025).
Stakeholders had mixed, but mostly positive, views about police responsiveness when IIA was reported to the police. Some felt that the police have always done the best that they can, but prior to the enactment of the new offences, the issue was finding an offence that would fit. This accords with findings from other jurisdictions (Bond & Tyrrell, 2021; Henry et al., 2018; Huber, 2025; McGlynn et al., 2019) and is unsurprising given that existing offences were not designed with IIA in mind (Citron & Franks, 2014; Crofts, 2021; Henry et al., 2018; Law Commission, 2021). It does appear that generally police would try to find an offence to apply, however, where none could be found or where there were difficulties gathering evidence police might turn complainants away. Stakeholders agreed that generally things have improved and that police are now more responsive since the enactment of the new offences. This is largely because the creation of the new offences gives the police more motivation to pursue prosecution. As one stakeholder noted, in most cases, police do initiate an investigation; however, this does not always mean that the case will proceed to prosecution.
A major issue identified as impacting how police respond to complaints of IIA and the likelihood of prosecution being pursued was the type of IIA reported and the ease of identifying a perpetrator or gathering evidence. Linked to this is resource allocation and perceptions about the nature and seriousness of IIA. Cases of voyeurism and unlawful recording were generally thought to be easier to prosecute because the perpetrator is often “caught red-handed” by the victim or, more commonly, by bystanders. In contrast, there was a clear perception that it can be difficult to trace the distributor of an intimate image or establish that the alleged perpetrator was responsible for distributing the image, especially where a foreign IP address is used. These findings correlate with those noted by Henry et al. (2018), who reported that cross-jurisdictional matters can be a barrier, especially where the victim or the perpetrator was in other jurisdictions, or an international service provider held evidence.
Even where the perpetrator could be found, if the case involved former partners, stakeholders noted that there was a tendency for police to see this as a private issue that could be dealt with by the complainants. In this regard, some service providers felt that police should have more training on the nature of IIA and how to appropriately deal with complainants. Again, these issues correspond to overseas research, where Bond and Tyrrell (2021) found that almost 95% of police in the United Kingdom had not received any formal training on how to conduct investigations into revenge pornography (see also Henry et al., 2018). It was, however, noted that there is considerable variance among police. Stakeholders observed that more junior and frontline staff may have less awareness about IIA and the relevant offences but things improve once cases are passed to more senior or specialised officers. It was also noted that police may respond better when a complainant is accompanied by a person from a support service or when the complainant is classed as vulnerable.
Another view expressed by stakeholders was that some police officers still view IIA as less serious than other types of offence, particularly other cyber-crimes or sexual offences. This was perceived to mean that fewer resources are allocated towards investigating IIA and that police tend to prioritise dealing with offences that they regard as more serious. There may be some weight in this view, given that research has shown that technology crime has grown significantly more than other crimes over the last five years (Research Office of the Legislative Council Secretariat, 2024). Indeed, in the year 2023 alone, such crimes surged by 49.6% compared to other crimes, with the most prevalent forms of technology crimes being “online shopping scams”, followed by “online investment fraud” and “phishing scams” (Research Office of the Legislative Council Secretariat, 2024). The response of the Hong Kong Police Force (2024b) to this dramatic rise in “technology crime” has been to “put vigorous efforts into combating deception in recent years”.
The implications of this study are clear and align with research from other jurisdictions: the key to effective policing is appropriate training of police officers. Such training should not only concern the content of the new offences, how evidence should be gathered and what cases satisfy those offences (Huber, 2025; Powell & Henry, 2018), but should also cover the forms that IIA can take and the seriousness of those harms. This can help overcome any remaining attitudes that IIA is not as serious as other offences or is a private matter. Training should also focus on how to appropriately deal with victims, including how to communicate and refer to relevant support services (Huber, 2025; Powell & Henry, 2018). This can help complainants to understand the prosecution process and alleviate some of the feelings of frustration about the nature of the criminal justice process. Huber (2025) noted that there are questions about the effectiveness of awareness training in creating a real change in practice in relation to racism and sexual violence (Bowling et al., 2004; Stanko & Hohl, 2018). To be most effective in creating real change in practice, and to avoid such training being superficial, it should draw on collaborative networks between stakeholders (officers, academics, policy-makers) inside and outside the criminal justice system (Carlton & Russell, 2018; Huber, 2025).
Alongside police training, there is a need for holistic public education to combat victim-blaming attitudes in society so that victims feel supported and able to disclose IIA. Additionally, developing non-criminal procedures, such as those provided by the Australian e-Safety Commission, with a straightforward complaint mechanism, swift investigation process and delivery of appropriate remedies, can be a valuable alternative to the slower-moving criminal justice process (Crofts, 2025). This could incorporate or work alongside a take-down service, such as that successfully launched by the Hong Kong NGO, RainLily, in 2021, to provide victims with the remedy that they often primarily desire (RainLily, 2023). RainLily (2023, p. 26) also recommended in its Report on the Take-Down service that the Office of the Privacy Commissioner for Personal Data “can take more proactive role in addressing” intimate image abuse. Such measures can alleviate some of the frustration that victims feel with the lack of control over the criminal process and dissatisfaction with the limited ability of the police to help remove images from circulation.
Conclusion
This research has found that adopting specifically labelled and targeted offences can significantly improve the policing of IIA by signalling both to the police and the community that IIA is harmful, is deserving of criminalisation and is not the fault of the victim. Specific offences make it easier to prosecute by having elements tailored to the behaviours. However, it is clear that simply creating new offences is not enough to deter the behaviour, to ensure adequate policing and to secure convictions when it does occur. There is a need for training of the police about the nature and harms of IIA to overcome any perceptions that the harm is not real because it is not physical, that it is a private matter or not serious. Such training should also focus on what cases satisfy the legal elements of the offences and how evidence can be gathered to support prosecution. Training should also help police to respond appropriately when victims report abuse. After all, the path to protecting victims starts with ensuring that victims feel comfortable and supported in reporting IIA to the police.
Footnotes
Acknowledgements
I would like to thank the participants who generously gave their time to take part in this study and Zirui Wang for research assistance.
Funding
The author disclosed receipt of the following financial support for the research, authorship, and/or publication of this article: This work was supported by the Research Grants Council of the Hong Kong Special Administrative Region, China (grant number CityU 11606621).
Declaration of Conflicting Interests
The author declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.