• 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.

  • Out of interest, would the risk assessment change at all if you didn't allow uploads/attachments?

  • Out of interest, would the risk assessment change at all if you didn't allow uploads/attachments?

    Not enough.

    But the things that create issues and the most obvious actions:

    • Prevent all File Uploads, force the use of ImgUr or another 3rd Party - mitigates exchange of potentially harmful images, videos, etc via the forum
    • Prevent all Direct Messages, encourage the use of WhatsApp / Signal, etc - mitigates the risk of stalking, harassment, hate, fraud, etc via the forum
    • Close all the Classifieds, encourage eBay - mitigates the risk of fraud, stolen goods, etc via the forum
    • Add age verification - mitigates the grooming of children

    We'd still have the risk of vulnerable individuals experiencing harm, and honestly that's just society at large.

    And the forum would now be a very very different beast, a public only, text only message board... with age verification.

    This is where any of these steps start hitting the lines of what I don't wish to do, I don't wish to intentionally cripple the site. I find that unacceptable.

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