UK Online Safety Regulations and impact on Forums

Alvin63 said:
Did you try the digital toolkit?
Click to expand...
I must admit I'm getting confused now.

I just did the risk assessment questionnaire thing, that told me I needed to download the template file on how I would be mitigating things.

I remember someone posted an example of this in this thread.

But I now see a link from Eva with a massive GitHub document that seems it should be posted in the sites terms and conditions?
 
benFF said:
I must admit I'm getting confused now.

I just did the risk assessment questionnaire thing, that told me I needed to download the template file on how I would be mitigating things.

I remember someone posted an example of this in this thread.

But I now see a link from Eva with a massive GitHub document that seems it should be posted in the sites terms and conditions?
Click to expand...
The online questionnaire is the digital toolkit with the odt download you fill in so sounds like you’ve done everything.
 
It’s this one. You have to go through the four sections. After the tick box bit that asks about risk factors there is info comes up about your risks and what’s needed under low medium or high. After that bit I had to go back and change my risk tick boxes because I’d just giesssed at it. Then back again to the third section - risk info didn’t change. Last section tells you what measures you need. Which wasn’t a lot but the earlier risk info suggested things you might need to do if you want to be low risk

The odt download file is your record of your risk assessment., Took me ages filling that in. Then going back to do it again as I didn’t understand the last bit but in section 4 of the toolkit - the recommendations, you need to copy and paste those and the smaller greyed out bits under them (showing which part of the act to apply to) in the last bit of the odt form.

I found it like a bad exam paper or school exercise.

www.ofcom.org.uk

Check how to comply with the illegal content rules

The tool is divided into four steps that follow Ofcom’s risk assessment guidance. Following these steps will help you to comply with the illegal content risk assessment duties, and the linked safety duties and record-keeping and review duties.
www.ofcom.org.uk www.ofcom.org.uk
 
There's a bit here about if it's medium risk

"If your service is medium or high risk for one kind of illegal harm, it is a ‘single-risk’ service, and more measures may apply. If your service is medium or high risk for two or more kinds of illegal harm, it is a ‘multi-risk’ service, and further measures may apply. The Codes of Practice indicate which recommended measures apply to each type of service."

www.cooley.com

UK Online Safety Act: Codes of Practice and Risk Assessment Guidance // Cooley // Global Law Firm

www.cooley.com www.cooley.com

So I don't want to be a medium risk in one category! Basically if a site is accessible to children, and doesn't have every single hyperlink checked - either manually, or by some automated means, then it comes under medium risk for the hyperlinks section. In the basic risk assessment.

The only way to make it low risk is to have some method of every single hyperlink being checked. Either by pre-moderation or some kind of automated scanning.

Under the child risk assessment section it's similar. The only way to be low risk is everything is pre-moderated - that's what it seems to say. Presumably it would accept automated constant moderation.

Hence it's either age verification (and having everything low risk) or all links pre-moderated, or some automated scanning of links.'

That is my understanding so far. And reading all this stuff is spoiling my life!
 
Asked Chat GPT what the additional measurs where and it said

The specific extra measures for single-risk services are detailed in Ofcom's Codes of Practice. These measures are tailored to the identified risks and may include:


  • Enhanced Content Moderation: Implementing more robust systems to detect and remove harmful content.
  • User Empowerment Tools: Providing users with better controls to manage their experience, such as blocking or reporting harmful content.www.ofcom.org.uk
  • Transparency Reports: Regularly publishing reports on content moderation activities and effectiveness.
  • Algorithmic Safeguards: Adjusting recommendation systems to minimize the spread of harmful content.
  • Age Verification: Implementing measures to ensure that users are appropriately age-gated, especially concerning harmful content.

The irony of this is - if it's medium/single risk you need enhanced content moderation. But if you have enhanced content moderation you become low risk. In other words, they want you to have enhanced content moderation (if you don't have age verification). Unless you can show the site definitely isn't one that children would access.

I certainly wouldn't be wanting to regularly publish transparency reports. So I'd like to do whatever is needed to be low risk! They don't care how small the site is - as long as its less than 70,000. That doesn't seem to come into it. They think small size doesn't make a site safer.
 
Terms of service: I'm having a slight problem with the fact that the Complaints procedure contradicts the standard terms of service. Standard TOS says something like the right to remove or ban etc without explanation.

But under OSA we have to have a complaints procedure about content removal.
 
Our main forum has been running since 2004, with 165,930 members, some of those will be bots/spammers/dead accounts of course, and it has been in decline for a long time now, but this law was the final nail. We set cloudflare to block UK access and are transferring ownership of it to a US member. I have given up. I had plans for other sites that were going to have forums, those plans abandoned too.
I tried reading all documents on the Ofcom site, the tool etc but I just feel its too much, its an Anime forum, we don't stand a chance.

Best of luck to those of you who are continuing.
 
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