• [I'm the administrator of Cycling UK's Forum]

    The Ofcom guidance distinguishes between "smaller" and "larger" user-to-user services, where "large" means 7 million active users (around 10% of the UK population). Smaller services considered "low risk" are not required to comply with many of the more onerous duties, which gives me some hope that the Powers That Be have considered small forums and the effect the Online Safety Act might have on them.

    I await the Ofcom online Tool that will help us check how to comply with the Online Safety Act: https://www.ofcom.org.uk/Online-Safety/check-how-to-comply/

    At that point Cycling UK, our moderators, and I, will have to decide whether the costs of any new legally-required duties are worth the effort, or whether we will simply close the Cycling UK Forum down. Shutting the Forum would be very sad, as over 18+ years it has provided much pleasure and usefulness and almost no harm to anyone at all.

  • We have a band of volunteer lawyers currently looking into things, but so far they've roughly concluded along the same lines of myself... that there are two things to look at, the risk level and the type of service.

    The type of service is captured in https://www.ofcom.org.uk/siteassets/resources/documents/online-safety/information-for-industry/illegal-harms/illegal-content-codes-of-practice-for-user-to-user-services.pdf?v=387711 and forums appear to be multi-risk according to the definition on page 78 of that document... mostly based on the risk involved, i.e. can you conclusively say that file uploads do not contain harmful or illegal content? if you say yes, does this include attachments on a DM? hence we start triggering some of the criteria... similar for stalking / harassment, threats and abuse... which is also extended to be "harmful but legal".

    Forums appear to be a "multi-risk service".

    The other doc is this one https://www.ofcom.org.uk/siteassets/resources/documents/online-safety/information-for-industry/illegal-harms/risk-assessment-guidance-and-risk-profiles.pdf?v=388231 and on first read we thought "Low risk", but then it starts saying you have to look at the risk profiles... and those too include things (page 64) stating that "discussions forums and chat room" are "We would normally expect such services to be assessed as at least medium risk" and we don't have strong reasons to assess elsewise.

    The high level reads not so bad... but once you (like we have) start cross-comparing their own words, it becomes much harder to not conclude we're a Medium risk + Multi-risk service... and that's where the scanning of DMs, scanning of attachments, potential age verification and other implications start arising.

    We're still investigating and awaiting tools, and considering options... but the default announcement of closure stands as it gives the greatest possible notice of the presently most likely outcome.

    I do hope we don't have to, and likewise that you don't have to close the forums either.

About

Avatar for user159461 @user159461 started