'Making' is widely interpreted by the courts and can include the following:
opening an attachment to an email containing an image: R v Smith; R v Jayson [2003] 1 Cr. App. R. 13
downloading an image from a website onto a computer screen: R v Smith; R v Jayson [2003] 1 Cr. App. R. 13
storing an image in a directory on a computer: Atkins v DPP; Goodland v DPP [2000] 2 Cr. App. R. 248
accessing a pornographic website in which indecent images appeared by way of automatic “pop-up” mechanism: R v Harrison [2008] 1 Cr. App. R. 29
receiving an image via social media, even if unsolicited and even if part of a group
live-streaming images of children
The breadth of what constitutes “making” – see below, Selection of Charges – means it will often be the appropriate charge rather than “possession”. When a device is seized, it may be the case that an image is stored in such a way that it is not possible to say that the suspect possessed it, because it is not accessible to them. Even if it is not accessible, however, the evidence may show that they had knowingly “made” the image.