Online Safety Act

Updated 2024-12-22

We assess that OpenBenches.org is a “U2U” (User-to-User) service because it allows users to upload UGC (User Generated Content as defined in Section 55 of the Online Safety Act) and allows users to leave comments on UGC.

This assessment is based on Ofcom’s Regulation Checker which says:

User-to-user services: online services that allow users to interact with each other. This includes the ability to generate, upload or share content, such as images, videos, messages or comments, with other users of that online service.

We assess that OpenBenches.org is a “smaller service” because it has fewer than 7 million monthly active UK users.

This assessment is based on Ofcom’s Measures applied to U2U services and search services which says:

§1.6 Large services. We define a service as large where it has an average user base greater than 7m monthly active UK users, approximately equivalent to 10% of the UK population. Smaller services. These are all services that are not large and will include services provided by small and micro businesses.

We also assess that we are “Low-risk” based on Ofcom’s four-step risk assessment process. There is no prior evidence of illegal content1, nor complaints about such, on the service. The service doesn’t allow for searching external sites. Comments are pre-moderated. Technical measures are in place to reduce the likelihood of illegal content being uploaded. Images are made available via a CDN (Content Delivery Network) which scans for illegal content and blocks it.

This document summarises the action we believe we need to take based on Ofcom’s document “Summary of our decisions“. Specifically, “Table 1: Measures for U2U services” which details what measures services have to take in order to be compliant with the Online Safety Act.

This document is split into sections and subsections based on that table. The “Measure number” (e.g. ICU D2) have been selected based on our assessed size and risk.

Governance and accountability

ICU A2

Individual accountable for illegal content safety duties and reporting and complaints duties

  • Both directors of Open Ideas Ltd. are accountable.
  • They both receive reports and complaints.
  • They both are able to moderate content.

Content moderation

ICU C1

Having a content moderation function to review and assess suspected illegal content

  • Comments are pre-moderated.
  • UGC images & text can be post-moderated.

ICU C2

Having a content moderation function that allows for the swift take down of illegal content

  • The service allows a moderator to remove content with a single click.

Reporting and complaints

ICU D1

Enabling complaints

  • A complaint form is available.
  • Users can submit a website address and a brief description of the complaint.

ICU D2

Having an easy to find, easy to access, and easy to use complaints system and processes

  • Every page which has UGC has a button which links to the complaint form.
  • The form does not require a login, nor does it require any personal details.

ICU D7

Appropriate action for relevant complaints about suspected illegal content

  • If the complaint is upheld:
    • Content will be removed from display.
    • The user who uploaded the content may have their account banned.

ICU D9

Appropriate action for relevant complaints which are appeals – determination (services that are neither large nor multi risk)

  • As per Section 72 (8), we will allow appeals to be submitted via the complaints form.
  • As per ICU D2, we do not capture the contact details of complainants, so we cannot enter into any correspondence about moderation decisions.

ICU D10

Appropriate action for relevant complaints which are appeals – action following determination

  • As per Section 72 (8), we will allow appeals to be submitted via the complaints form.
  • As per ICU D2, we do not capture the contact details of complainants, so we cannot enter into any correspondence about moderation decisions.

ICU D11

Appropriate action for relevant complaints about proactive technology, which are not appeals

ICU D12

Appropriate action for all other relevant complaints

  • These will be handled on a case-by-case basis.

ICU D13

Exception: manifestly unfounded complaints

  • These will not be acted on.
  • Persistent complainants may be blocked.

Terms of service

ICU G1

Terms of service: substance (all services)

ICU G3

Terms of service: clarity and accessibility

User access

ICU H1

Removing accounts of proscribed organisations

  • There are no user accounts. Users have the option to use OAuth to sign in from other, larger, U2U providers.
  • If the accounts are of proscribed organisations, they will need to be removed by the U2U service which provides OAuth credentials.
  • Individual entries in the user database can be removed on request.

Footnotes

  1. The seventeen listed illegal content types are terrorism; child sexual exploitation and abuse; hate; harassment, stalking, threats and abuse; controlling or coercive behaviour; intimate image abuse; extreme pornography; sexual exploitation of adults; human trafficking; unlawful immigration; fraud and financial offences; proceeds of crime; drugs and psychoactive substances; firearms, knives and other weapons; encouraging or assisting suicide; foreign interference; animal cruelty. ↩︎