UK Online Safety Regulations and impact on Forums

But wouldn’t that also cover guest posting? I think it’s probably important to make clear in your risk assessment whether you allow guest posting.

Yes it would, and that is a good point (in our case we don't allow guest posting)
 
Invision Community has just added mandatory CSAM scanning for their Cloud customers. While hashed-based image identification is useful, it won't stop the spread of CSAM via text links to folders which leaves every forum that allows personal messaging with a potential problem.

 
Cloudflare recently made it easier to deploy as well:


 
Invision Community has just added mandatory CSAM scanning for their Cloud customers. While hashed-based image identification is useful, it won't stop the spread of CSAM via text links to folders which leaves every forum that allows personal messaging with a potential problem.

I appreciate IPB for this improvement. XenForo management has not said they will take action, nor have they shown any sign that they will. I hope they introduce improvements that surpass those of IPB, making us feel ashamed for doubting them.
 
XenForo management has not said they will take action, nor have they shown any sign that they will.
It could be that they are being more realistic about what the OSA actually means. It isn't a case of install this software/addon/upgrade and you'll be compliant. You could scan as much (probably non-existent) CSAM material as you like and still not be compliant if you didn't do your risk assessment.
 
Cloudflare recently made it easier to deploy as well:


Enabled!
 
It could be that they are being more realistic about what the OSA actually means. It isn't a case of install this software/addon/upgrade and you'll be compliant. You could scan as much (probably non-existent) CSAM material as you like and still not be compliant if you didn't do your risk assessment.
As you know, risk analysis is only a tool to determine how to comply with the relevant requirements. After determining the clauses, we need to determine how we will comply with it. If we go from the example of IPB development, Child Sexual Abuse Material is a risk that we need to control, so how will we comply or control it? Here, as administrators, our actions come into play and XenForo's involvement is required at this stage. It is not a good solution to step aside and leave us completely alone with manual methods by saying that Administrators and Moderators should take action and control the content. Even if CSAM scanning is not a 100% solution, it is still a corporate response. For this reason, I appreciate IPB again.
 
Last edited:
Here, as administrators, our actions come into play and XenForo's involvement is required at this stage.
At this stage I'd suggest it's more about undertaking a risk assessment than implementing tools for compliance. It's worth keeping in mind that as far as OFCOM is concerned, the finer points of the Act are still a work in progress. In addition these forums are not exempt so I would imagine there will have to be some development time spent in order to satisfy the Act.
 
Out of interest has anyone contacted either of the two main parties that do CSAM scanning?
I would assume Cloudflare and IPB are using one of these systems under the hood, since holding the material in question would, well be questionable... and all the fuzzy hash matching is kept a moderately guarded secret. XF could I guess in theory offer something on their cloud hosting and might stand more of a chance of getting in the door than the owner of a small forum! Or possibly they could branch out the business and act as a middleman layer to one of those bodies (with their approval), but time and money I guess are factors there. I keep meaning to look at the MS offering (since the IWF fees are simply too high for me) in more detail since it claims to be free "for qualified customers", but doesn't obviously say what that means.
 
Out of interest has anyone contacted either of the two main parties that do CSAM scanning?
I would assume Cloudflare and IPB are using one of these systems under the hood, since holding the material in question would, well be questionable... and all the fuzzy hash matching is kept a moderately guarded secret. XF could I guess in theory offer something on their cloud hosting and might stand more of a chance of getting in the door than the owner of a small forum! Or possibly they could branch out the business and act as a middleman layer to one of those bodies (with their approval), but time and money I guess are factors there. I keep meaning to look at the MS offering (since the IWF fees are simply too high for me) in more detail since it claims to be free "for qualified customers", but doesn't obviously say what that means.

We fail at the first hurdle for IWF membership

Applicants must:

  • be legally registered organisations trading for more than 12 months;
  • be publicly listed on their country registration database;
  • have more than 2 full-time unrelated employees;
  • and demonstrate they have appropriate data security systems and processes in place.
If you do not meet this minimum threshold, we will be unable to respond or advance your application.

so according to their website they wouldn't even respond to us.

I have enabled Cloudflare scanning, but that is the best we can realistically do for now. I do consider us very low risk anyway, but we have seen with the likes of mumsnet that malicious people can always cause problems.
 
If there was a plugin or API service that offered to block

1. CSAM
2. Any nudity
I wish I knew how to differentiate between nudity and porn. I mean in terms of laws or regulations - I know how I personally can tell the difference. And Youtube allows that scene from Colin from Accounts.
 
I wish I knew how to differentiate between nudity and porn. I mean in terms of laws or regulations - I know how I personally can tell the difference. And Youtube allows that scene from Colin from Accounts.
Easy if somebody is posting nude pics up of themselves it's nudity and porn. You do something about it.
If it's a nude statue ignore it.
 
Whilst I've not tested my setup in anger I hope it will do the job (certainly should for my UK users). By no means super pretty or elegant as the provider I'm using is rather geared up for product sales rather than vanilla age verification and their templates reflect this "you've recently bought an age restricted product..." etc. but they do at least offer a pay per lookup model - which suits me as I don't need to do many and others seem to be monthly fees. Whilst my company hosts several forums none are crazy big and the one I personally look after is teeny so a few hundred a month for verification services was far too much!

I didn't do an extensive search for providers however and I'm waiting to hear back from one at the moment. So I'll live with a bit of on-site documentation explaining what users should expect from the process. I really was just looking for a backstop solution in case I needed it.

It still needs a bit of spit and polish but it's getting there (as and when I work on it). Also since I I've not done more than the odd little dabble of PHP for the last 20 years and I write most of my software in Ruby it's written in Ruby and ties into XF via both the API and also directly to the DB. Sorry written primarily for myself and clients so UI wasn't a requirement and I've a bit much on to go and re-learn PHP and the XF add-on structure.

I also realise others might want checks during registration and the like - this is just hooked into the standard account upgrade purchase mechanism and currently just PayPal (since that's what our forum clients are using). So my "model" is going to be to restrict private messaging and maybe the odd other thing to just those verified as being 18+. Otherwise we'll just go for the normal T&C approach to age. If someone wants to use those features then they cough up for the verification - which was going to be something like £1.30 I think to cover fees and whatnot - run through the process (which if they are on the (I assume) electoral role in the UK should be automatic, if not then it's the standard triad of: age estimation via webcam, upload ID, credit card check). Is it foolproof? Nope, but it would appear to be compliant from the Ofcom requirements which is enough for me. To be fair I'll also be grandfathering in a good number of users since many of us know each other IRL anyway. Actually we've a decent number of grandfathers now I think of it! So I don't know how much use it will actually see!

Having done this tool however it would be pretty trivial to do a shiny proper add-on that did the same but was more slick. The APIs for the providers I looked at are not overly complicated. The main decision would be to decide if you were just doing periodic polling or accepting webhooks back from the provider. The latter is obviously more slick, but I ended up deciding to just periodically poll since my numbers are small. Some of the larger providers also offer digital ID solutions (eg Yoti/EasyID) - which are more private (kinda) for the end user - essentially you the forum provider ask the ID provider if 'user A' is 18+ and they say yes/no. You never see any personal data. Because the provider I am using is geared up for sales of age restricted products it assumes I (the forum provider) has things like the name and address I am sending the "goods" to etc.

The main blocker generally would seem to be the fees. If you were running as a middleman layer with an XF Add-on for sale then I suspect there is a decent sum to potentially be made and a couple of hundred a month wouldn't matter. Whilst I did wonder about this, I have enough work on right now to occupy myself. I'll leave that to XF core team or one of the Add-on devs here to spin up, they'd have a better idea than me if it'd be profitable.

I'll write up my solution here I expect once I'm using it and have tested edge cases and whatnot.
 
Does anyone have an absolutely minimal template for a small XF forum, that they would like to share?

I found @eva2000's template on Github but it seemed a bit long ...!

I'm hoping to spend as little time and effort as Ofcom has apparently spent on it.
 
Back
Top Bottom