The modern international legal framework of cyberbullying in relation to the protection of children's rights

Rodionov Aleksei Evgen'evich ORCID: 0009-0002-5146-473X Postgraduate student; Department of International Law; Institute of Legislation and Comparative Law under the Government of the Russian Federation' (IZiSP) Lawyer; Law Office 'Dubrovskaya; Kuznetsova and partners of Moscow 34 Bolshaya Cheremushkinskaya str., Moscow, 117218, Russia alex.kreativ@mail.ru

Introduction

The Internet information and telecommunication network has become an integral part of the global economy, communications and law ^{[5, 6, 22, 40]}. The development of the Internet has led to the emergence of new legal challenges − personal data protection, cybersecurity and international regulation of the digital environment ^[41], and it is also impossible to exclude the influence of the Internet as the main means of achieving the goals of hybrid warfare ^{[25, p. 6]}.

The Internet moved from the status of a research project to a global commercial and social phenomenon, since in 1989 Tim Berners-Lee proposed the concept of the World Wide Web, which included hypertext documents accessible through browsers ^[52]. This technology has made the Network available for mass use, which has led to its rapid growth in its modern form.

It should be noted that threats to information security are an integral aspect of the development and use of information technologies ^{[18, p. 129]}. The lack of precise legal norms in international law regulating countering cyber attacks is compounded, however, by the lack of a unified definition of the concept of "cyber attack" ^{[18, 39]}.

Computer crimes, or cybercrimes, are a wide range of acts that include attacks of varying degrees of danger on various social values: privacy, property, access to information ^{[5, pp. 167-171]}. According to G.G. Shinkaretskaya, the accepted definitions do not distinguish between cybercrime, cyberattack and cyberwar, therefore these terms can be used everywhere and widely ^[35].

The term "bullying" is used to refer to bullying in educational organizations. The word "bullying" as a lexical unit of the modern language field comes from the Dutch boel "lover, brother" and the Middle German diminutive buole "brother". During the 17th century, it was used in European languages in meanings ranging from "nice guy", "braggart" to "persecutor of the weak". As a verb to "intimidate", the word bully was first used in English no earlier than 1710 ^{[19, pp. 112-115]}.

In this regard, it should be noted that cyberbullying is a separate type of network (online) aggression, which differs from the nature of Internet attacks ^{[5, p. 1-2; 6]}, and as a modern legal phenomenon, many authors do not have a definition of "victim of cyberbullying" ^{[5, p. 1]}. In domestic and foreign literature, they traditionally limit themselves to the interpretation of "cyberbullying", without explaining the concept of persons affected by it ^{[4; 13; 46]}.

The issue of cyberbullying is the subject of active research in both foreign and domestic science.

The work of such foreign scientists as Juvonen and E.F. Gross, Ts. Kyriatsou and A. Zuin, as well as K. Alonso, E. Romero and K. Kumar, greatly contributed to the development of the theoretical foundations of this phenomenon. Their research examines cyberbullying from various perspectives − psychological, social, cultural, and legal. They pay attention to the psychological effects experienced by victims, as well as analyze the features of aggressive actions in the online environment.

Russian researchers such as D.V. Zavyalova, A.Y. Gusev, D.V. Zhmurov, L.V. Bondarenko, O.N. Vedernikova, E. Verhelst, and others also made significant contributions to the study of the problem. The works of these authors are devoted to various aspects of cyberbullying, including its legal classification, social consequences and countermeasures. D.V. Zavyalova and A.Y. Gusev focus on the characteristics and forms of cyberbullying in the Russian context, and D.V. Zhmurov and L.V. Bondarenko consider the psychological and social factors influencing the occurrence of this phenomenon.

The concretization of the concept of cyberbullying was carried out in the works of J. Juvonen and E.F. Gross, where cyberbullying is proposed to be understood as the impact on an individual or harassment of an individual using information and communication technologies. Cyberbullying is carried out to spread slander and insults, humiliate the victim, and drive the victim to suicide ^{[11, 42]}.

At the same time, Ts. Kyriatsou and A. Zuin understand cyberbullying and the disclosure of confidential information as an independent category of criminal acts, including the posting of materials in the information environment that constitute a personal or family secret ^{[11, 44]}.

The category of victims is often described as individuals with relatively high rates of benevolence, neuroticism, and extraversion, who are open to experience ^[38].

There are several controversial points in these definitions. Firstly, when limiting cyberbullying solely to exposure through information and communication technologies (Juvonen and Gross), the role of other factors, such as the context of a social network or specific forms of online aggression, is not taken into account. Secondly, the disclosure of confidential information (Kyriatsou and Zuin) may be too extensive and cover actions that cannot always be classified as cyberbullying, for example, in the case of accidental data leaks or the unintentional dissemination of personal information.

Modern Russian jurists give the following definitions of cyberbullying. D.V. Zavyalov: "Cyberbullying, unlike classical bullying, is carried out in cyberspace: in social networks, messengers, forums, playgrounds and other communication network spaces" ^[6]. A.Yu. Gusev gives a streamlined formulation: cyberbullying is harassment, bullying systematic in nature, using the Internet information and telecommunications network ^[15]. D.V. Zhmurov states: "Traditionally, this phenomenon is understood as aggressive interaction using electronic means of communication" ^[13].

When analyzing the definitions of cyberbullying proposed by domestic authors, several key observations can be made. D.V. Zavyalova restricts cyberbullying exclusively to cyberspace, not taking into account that aggression can manifest itself in other forms of communication, such as online games or e-mail. A.Yu. Gusev indicates a "systematic nature", but does not specify the criteria which can be used to determine the systematic nature of harassment, which makes it difficult to apply the definition of this author in legal or social practice. D.V. Zhmurov's definition of cyberbullying as "aggressive interaction" is too generalized and does not reflect the specific psychological and social aspects of this phenomenon, such as intentional humiliation and psychological impact on the victim.

It seems possible in the framework of this work to give our own definition of this act: cyberbullying is systematic targeted actions committed using information and communication technologies (including, but not limited to, the Internet, mobile phones, social networks and other electronic means of communication) aimed at humiliating, intimidating, insulting, harassing or causing other harm (physical, psychological, reputational) to another person; these actions include threats, the dissemination of false or compromising information, the publication of offensive materials, the use of derogatory images or messages, as well as other forms of online aggression that lead to significant and long-term negative consequences for the psycho-emotional state, social reputation or physical well-being of the victim.

R. Badinter has a formulation: "Human rights are not given to us by revelation, they have their own history" ("Les droits de l'homme ne nous ont pas été révélés, mais ont une histoire") ^{[39, p. 1]}, which reflects the long-term formation of such rights. With the rapid development of digital technologies and the expansion of virtual space, cyberbullying is becoming a global problem affecting human rights in general, as well as children's rights, including the right to protection from violence, mental and physical health, and privacy in the face of a new threat.

Meanwhile, the development of information technology has made significant adjustments to military doctrines, plans and strategies of military operations. For example, in the military units of the countries of the North Atlantic Alliance, cyber troops have been created with functions not limited to protecting their own communications alone ^{[34, p. 2]}. They are actively engaged in espionage using the Internet, as well as spreading defamatory information and forming the necessary public opinion on social networks ^{[25, p. 6]}. In the context of a hybrid confrontation between States, children are the most vulnerable group.

The relationship between cyberbullying against minors and hybrid (information) wars is caused by the use of the Internet information and telecommunications network as a tool for targeted information impact. Cyberbullying, which is one of the forms of illegal information influence, involves psychological pressure, threats, dissemination of defamatory information and data manipulation, which leads to a significant violation of the rights and freedoms of minors guaranteed by international and national law. These methods can be integrated into hybrid warfare strategies aimed at undermining the stability of civil institutions, inciting social tension and demoralizing vulnerable groups, including minors ^{[16; 21]}.

In addition, the approaches used in cyberbullying are inherently similar to those used in hybrid warfare, including the spread of disinformation, information manipulation, and propaganda pressure. The difference lies in the scale of the impact: if cyberbullying is limited to affecting individuals, then hybrid wars cover a wider range of subjects, including minors as the most vulnerable audience ^[26].

Cyberbullying can be considered not only as an independent illegal phenomenon, but also as an element of the strategy of hybrid wars, using similar mechanisms of information influence in order to disrupt public order, destabilize and achieve other illegal goals ^[27].

Due to the urgency of the problem of countering cyberbullying in the context of protecting children's rights, it is possible to explore international legal regulators aimed at preventing and suppressing cyberbullying and to consider the effectiveness of measures applied by the international community. Special attention should be paid to the role of universal and regional international treaties, as well as the activities of specialized international organizations.

Materials and methods

The object of the study is the international legal framework governing cyberbullying and the protection of children's rights. The subject of the study is the norms of international law governing public relations in the field of protection of minors from bullying on the Internet. The purpose of the study is to critically evaluate the effectiveness of existing international treaties, conventions and declarations in countering cyberbullying and protecting children from online violence.

To conduct the research and comprehensively disclose its subject, the article uses systematic and integrated approaches, comparative legal and doctrinal principles of research.

The main part

By virtue of Part 3 of Article 1 of the Charter of the United Nations, the UN aims to carry out international cooperation in solving international problems of an economic, social, cultural and humanitarian nature, as well as to promote and develop respect for human rights and fundamental freedoms for all people without distinction between race, gender, language and religion.

Any major UN body is obligated, through the "UN Charter", to promote international cooperation in the above-mentioned areas (paragraphs "b" of Part 1 of Article 13, Part "c" of Article 55, part 2 of Article 62, part "c" of Article 76 of the "UN Charter").

The implementation of international cooperation is fixed in the "Declaration on Principles of International Law" concerning friendly relations and cooperation between States in accordance with the "Charter of the United Nations", "Resolution 2625 (XXV) of the UN General Assembly" dated 24.10.1970.

The fundamental provisions of freedom of opinion and expression were defined in Article 19 of the Universal Declaration of Human Rights (adopted by the UN General Assembly on 10.12.1948), in Articles 2-27 of the International Covenant on Civil and Political Rights (adopted on 16.12.1966 by Resolution 2200 (XXI) at the 1496th Plenary Meeting of the UN General Assembly)., in Articles 12-14 of the Convention on the Rights of the Child (approved by the UN General Assembly on 11/20/1989), in Part 6 of Article 1 of the United Nations Millennium Declaration (adopted by General Assembly Resolution 55/2 of 09/08/2000) and many other documents.

In the context of cyberbullying, it is necessary to note the "Convention on the Rights of the Child" of 1989, which establishes the general principles of the protection of the rights of the child applicable to activities to protect children from crimes on the Internet and oblige States to protect the child from information and materials harmful to his well-being (paragraph "e" of art. 17) ^{[7, p. 2]}.

The Council of Europe Convention on the Protection of Natural Persons with regard to Automated Processing of Personal Data (1981) is also important, which created the basis for protecting privacy in the context of digitalization, indirectly addressing possible cyberbullying threats related to the misuse of data. Article 1 of this Convention stipulates that its purpose is to ensure in the territory of each party for every individual, regardless of his nationality or place of residence, respect for his rights and fundamental freedoms, and in particular his right to privacy in relation to automated processing of personal data concerning him ("data protection"). Article 2 of the said Convention explicitly establishes the concept of "personal data", however, it follows from the meaning of the entire Convention that in reality the question is not about protecting a specific individual from encroachment (Article 10 of the Convention), but rather the personal data itself. Primary personal data is also the target of cyberbullying attacks, and therefore, these standards guarantee the security and protection of data transmission.

The Council of Europe Convention on Cybercrimes (Budapest Convention), adopted on 11/23/2001, has become an important international instrument in the field of regulating behavior in the digital space. This is the first and still the key international treaty aimed at combating crimes committed using computer systems. The main purpose of this Convention, enshrined in its preamble, is to develop a joint criminal law policy that would help protect society from cybercrime, including through the adoption of appropriate legislative measures and the creation of effective international cooperation. The Convention under consideration introduces legal and procedural standards for the prevention and prosecution of cybercrime, including phenomena such as cyberbullying, in cases where it involves violations of criminal law ^[48].

Articles 2-6 of the Budapest Convention list the offences that States parties are required to incorporate into their national legislation, including unlawful access to computer systems, interference with data or systems, and misuse of devices. These provisions indirectly cover cyberbullying cases involving the use of hacked or fake accounts, the posting of malicious content, or illegal access to personal data.

The CoE Convention on Cybercrimes pays special attention to the collection of electronic evidence and ensuring the protection of victims. Chapter II of this legal document establishes procedural measures for the effective investigation of cybercrimes. In particular, Articles 16 and 18 introduce obligations to ensure quick access to traffic data and user identification, which is especially important in cyberbullying cases, where offenders often use the anonymity of the Internet to evade responsibility.

No less significant is the provision of Article 15 of the Budapest Convention, which requires participating States to provide guarantees for the protection of individual rights and freedoms in the implementation of procedural rules, including data protection, which brings it closer to the provisions of the Convention for the Protection of Natural Persons with regard to Automated Processing of Personal Data (1981). This requirement provides a balance between the need to combat crimes and protect the privacy of users by creating a legal framework to curb illegal activities without unduly interfering with human rights.

In addition, the "CoE Convention on Cybercrimes" provides for mechanisms for international cooperation (Chapter III), including the rapid exchange of information between the competent authorities of the participating States, which is especially important for investigating cross-border cases of cyberbullying. Thus, Article 35 of this Convention introduces the institution of round-the-clock contact points that can be used for the rapid exchange of data on crimes committed on the Internet. On November 7, 2002, the Committee of Ministers of the Council of Europe adopted, and on January 20, 2003, the "Additional Protocol to the Convention on Cybercrime concerning the criminalization of acts of a racist and xenophobic nature committed through computer systems" was opened, which is directly aimed at preventing discriminatory and degrading behavior on the Internet, including cases involving cyberbullying.

The disadvantage of the Budapest Convention is the lack of a direct article on harassment in the digital environment, but its provisions create the basis for prosecution for related offenses such as threats (art. 4) and misuse of data (art. 6). The Convention on Cybercrime, although it is a progressive document of its time, requires modernization in the light of new challenges of the digital age ^[49]. Challenges include the proliferation of phenomena such as massive cyber attacks, anonymity, connection encryption, systematic online attacks using platforms that reach a large audience of online visitors, and others that go beyond the original formulations of the Convention ^[45].

Meanwhile, the "CM/Rec Recommendation (2014)" is of interest.6 of the Committee of Ministers to the Member States of the Council of Europe on Guidelines on Human Rights for Internet Users" (adopted on 16.04.2014 at the 1197th meeting of Permanent Representatives of Ministers), which emphasizes the need to develop national strategies aimed at protecting children from violence, including cyberbullying, as well as promoting digital literacy.

In Part 1 of the CM/Rec Recommendations(2014)6 ..." it is stated that: "The member States of the Council of Europe are obliged to ensure to everyone under their jurisdiction the rights and fundamental freedoms enshrined in the European Convention for the Protection of Human Rights (ETS No. 5, Convention). This obligation also applies to the use of the Internet. Other Council of Europe conventions and documents related to the protection of freedom of expression, access to information, freedom of assembly, protection against cybercrime, and the right to privacy and personal data protection also apply here."

In the section "Children and youth", Part 5 "CM/Rec Recommendations(2014)6..."it is explicitly stated that cyberbullying should be suppressed and not allowed.: "You should be provided with special protection from the violation of your physical, mental and moral well-being, in particular, protection from sexual exploitation and abuse on the Internet and other forms of cybercrime. In particular, you have the right to education designed to protect you from such threats."

The Council of Europe has consolidated the need to curb and prevent cyberbullying, considering it as a threat to the physical, mental and moral well-being of children, comparable to sexual exploitation and other forms of cybercrime.

Based on this, cyberbullying is legally recognized as an illegal act requiring all possible measures to eliminate it. The member States of the Council of Europe are obliged to ensure the right of children to be protected from such threats, including the creation of educational programs aimed at preventing and countering cyberbullying. In addition, special attention is paid to freedom of expression, the right to privacy, the right to education, the rights of the child and protection from cybercrime (Part 9 "Background and context").

Moreover, the Council of Europe, not repealing, but developing the provisions of the "CM/Rec Recommendation (2009)5 of the Committee of Ministers to Member States on measures to protect children from harmful content and behavior and to encourage their active participation in the new information and communication environment", translated these principles and objectives into a new Recommendation, thereby reflecting the continuity and relevance of the issues raised and emphasizing that participating States should organize a timely response to complaints cyber bullying or cyber harassment that has negative consequences.

The United Nations recently drew attention to the growth of cyber bullying in society, in particular against children on the Internet and in the digital space.

Paragraph 16 of UN Resolution No. 74/133 of 2019 "strongly condemns all forms of violence against children committed under any circumstances, including physical, psychological and sexual violence, (...) sexual exploitation of children on and off the Internet, harassment, including cyber bullying, and urges States to ensure that they We have intensified efforts to prevent all forms of such violence and protect children from it through a comprehensive, gender- and age-sensitive approach, developed an inclusive, multi-functional and systematic set of measures to effectively respond to violence against children and to ensure safe and child-sensitive mechanisms for counseling, complaint handling and reporting, and guarantees for the rights of victims. We have integrated this set of measures into national planning processes."

UN General Assembly Resolution No. 75/166 "Protection of children from bullying" dated 12/16/2020 stated that every year, starting in 2020, the International Day against Violence and Bullying at School, including Cyberbullying, is celebrated on the first Thursday of November ^{[7, p. 5]}.

The United Nations has developed various other recommendations, such as "Protecting Children Online (COP)," which is a multi−stakeholder network created by the International Telecommunication Union (ITU) to protect children online with a comprehensive set of recommendations for all stakeholders on how to promote a safe and empowering online environment for children and youth.

In 2019, UNICEF published a discussion paper titled Child Rights and Online Gaming: Opportunities & Challenges for Children and the Industry ("Child Rights and Online Gaming: Opportunities and Challenges for Children and the Industry") to discuss the opportunities and challenges facing children in one of the fastest growing entertainment industries. The document covers the following topics: 1) children's right to play and freedom of expression (time spent playing and health consequences); 2) non-discrimination, participation and protection from violence (social interaction and full inclusion, toxic environment, age restrictions and their verification, protection from grooming and sexual abuse); 3) the right to confidentiality and freedom from economic exploitation (business models of providing access for data, free games and monetization, lack of transparency in commercial content).

The basis of international law is state sovereignty, which, however, hardly fits into the reality of cyberspace ^[53]. Despite the consensus reached on the implementation of state sovereignty in cyberspace, none of the existing States can claim sovereignty that would cover the entire cyberspace ^[47] due to the fact that many elements of the infrastructure on the basis of which cyberspace exists are located within different sovereign territories and, therefore, according to international law, belong to to different jurisdictions ^[8].

Nevertheless, J. Trachtman rightly notes that the division of jurisdictions should not be a reason for refusing to regulate the entire cyberspace: after all, actions in cyberspace are still carried out in a specific territory, as well as their consequences are felt in a specific area ^[51]. And the fact that individual problems go beyond specific jurisdictions is not something new for international law ^[8].

Based on the above, it should be noted that the international community as a whole has begun a procedure for recognizing cyberbullying as a new form of cybercrime through the norms of international law, posing a threat comparable in harm to traditional forms of violence against children.

The issue of preventing cyberbullying as a form of violence in the digital space has become a priority area of activity for many regional international organizations. Their approaches to solving this problem form a legal framework and create platforms for cooperation between States.

Let's consider the key documents and initiatives of such organizations as the European Union (EU), the Organization of American States (OAS), the Association of Southeast Asian Nations (ASEAN), the Eurasian Economic Union (EAEU) and the Commonwealth of Independent States (CIS) ^{[7, pp. 1-2]}.

The European Union is actively involved in regulating behavior in the digital environment, paying special attention to the protection of personal data and the fight against illegal content. The leading EU document in this context is the "General Data Protection Regulation (GDPR) 2016/679", which entered into force in 2018. The "General Regulation ... (GDPR) 2016/679" sets strict requirements for the processing of personal data, which, in turn, creates barriers to the misuse of information typical of cyberbullying (for example, publishing personal data without consent).

In 2022, the European Parliament and the Council of the EU adopted the Digital Services Act, which regulates the activities of digital platforms, obliging them to respond promptly to complaints about illegal content, including cases of cyberbullying. Article 12 of the DSA Act provides for the obligation of platforms to ensure a safe online space, which directly concerns the prevention of digital violence.

As G. Wiener emphasizes, the EU measures demonstrate an integrated approach to ensuring digital security, combining criminal, civil and administrative mechanisms ^[54].

In 2015, the Inter-American Commission on Human Rights published the report "Cyberbullying and Digital Security in America" and called on Member States to develop national programs to prevent online violence, especially among children and adolescents on social media, because when victimization occurs online, there is a high probability that it will reach a wide audience. Control over the content and distribution of publications is beyond the victim's control, and a publication can instantly go viral. This is compounded by the fact that content is stored on the Internet for longer than in person, which makes it available indefinitely, unless it is deleted. However, deleting something on one site does not mean that it will not be available on other sites and will not easily spread to hundreds, if not thousands, of other sites ^[48].

The ASEAN has developed a "Cybersecurity Action Plan 2021-2025," which includes measures to protect users from cyber threats, including cyberbullying. The document emphasizes the need to develop regional cooperation in the field of prevention and investigation of digital crimes ^[50].

The EAEU is aware of the need for joint efforts to combat cybercrime and cyberbullying and is taking serious measures aimed at ensuring information security. For example, in 2013, an Agreement on cooperation between the member States of the Commonwealth of Independent States in the field of information security was signed in St. Petersburg. This regulatory legal act is the main one in the field of combating cybercrime, and the EAEU member states are still guided by it when drafting new acts in the field of cybersecurity ^{[14, p. 3-4]}.

On 05/29/2014, the "Protocol on Information and Communication Technologies and Information Interaction within the Framework of the Eurasian Economic Union" was signed in Astana (Appendix No. 3 to the "Treaty on the Eurasian Economic Union") ^{[14, pp. 4-5]}.

According to G.I. Tunkin, back in 1970, the sphere of human rights, which had previously been exclusively an internal matter of States, remained closed to international intervention for a long time. However, an unprecedented development has taken place in this area of international law over the past 60 years. This development covers a wide range of norms, from generally accepted standards to provisions concerning international mechanisms with mandatory jurisdiction to protect violated rights. This development can be considered as a significant achievement, indicating the expansion of the influence of international law on the protection of human rights ^{[23, p. 93]}; over the next 40 years, the international community was able to increase this range ^[12].

Nevertheless, the most important aspect of any international legal proposal remains the benefit to all participants in the potential process. If the agreement is not a compromise, then the possibility of signing it is unlikely. This is due to the "will of States" in international law ^[31].

It should be noted that the legal position on the "agreed will" of the state in international law is shared by such modern jurists as V.R. Avkhadeev ^[1], B.M. Ashavsky ^{[2, 3, 33]}, A.I. Kovler ^[10], I.V. Kholikov [25-29, 43], as well as jurists of the past: G.I. Tunkin ^[23], I.I. Lukashuk ^[31], F.F. Martens ^[32] and others.

"The agreed will, firstly, finds expression in the content of the norm, and secondly, it obliges subjects to comply with this norm. The nature of the binding force of the norm depends on the will of the subjects. They can make it legally or morally and politically binding at their discretion. The subjects directly reach an agreement on the content of the norm and on making it binding" ^{[31, p. 17]}.

Existing international legal acts, although they address certain aspects of the protection of children's rights in the digital space, do not always contain exhaustive rules governing cyberbullying, as disagreements arise over the definition of cyberbullying itself, the establishment of jurisdiction in cross-border cases, and the definition of measures of responsibility for the commission of this act ^[24].

Traditional international humanitarian mechanisms focused on physical forms of violence ^[9] are not effective enough to counteract cyberbullying, which can cause significant harm to the mental and emotional health of children, exacerbating the humanitarian crisis in armed conflicts ^[16].

The use of cyberbullying as a tool of hybrid warfare poses a new threat to children's rights ^{[16, p. 3]}, requiring a legal response ^{[14, 7, 16, 17]}, and the development and implementation of universal international legal frameworks requires the need to reach consensus between States with different legal systems, cultural traditions and levels of technological development ^{[20, p. 5-6]}.

Conclusion

Thus, new international acts should take into account the specifics of cybercrime in armed conflict, including determining responsibility for organizing and conducting cyber attacks aimed at children ^[15], establishing jurisdiction over cross-border crimes ^{[21, 30]}, as well as developing mechanisms to prevent and investigate such acts ^[36-37]. In the context of hybrid warfare, the key factors are the identification of the actors responsible for cyberbullying (States, non-state armed groups, private individuals), and the establishment of responsibility for actions committed under the guise of anonymity.

Cyberbullying aimed at minors is not only a separate illegal act, but also an element of information influence used in the framework of hybrid wars. The similarity of the methods and goals of these phenomena, such as disinformation, manipulation of public consciousness, and psychological pressure, confirms the need for their comprehensive analysis in the context of armed conflict. Modern international law currently demonstrates an insufficient degree of regulation of these issues, since the lack of a unified concept of cyberbullying, gaps in the definition of cross-border jurisdiction and insufficient development of accountability mechanisms create legal uncertainty. These factors complicate the prevention and investigation of crimes related to cyberbullying and its use in hybrid warfare.

Taking into account the above, among the priority areas for improving the international legal regulation of cyberbullying remains the need to develop a unified concept based on the experience of regional international organizations in order to ensure uniform application of norms in different jurisdictions.

In addition, consideration should be given to the development of the concept of "digital neutrality", a principle prohibiting the use of cyberspace for information attacks and manipulation of children and the use of hybrid warfare methods, with the obligation of States to take measures to prevent such actions to protect children.

These measures should be based on the basic principles of international law, including the principle of sovereign equality of States, non-aggression, peaceful settlement of disputes and cooperation between States. Special attention should be paid to the need to fulfill the obligations arising from the "UN Charter." The adoption of such measures will strengthen the international legal order and ensure stability in the face of modern digital challenges.