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If you read the guidance: https://www.ofcom.org.uk/siteassets/resources/documents/online-safety/information-for-industry/illegal-harms/risk-assessment-guidance

If you read the guidance: https://www.ofcom.org.uk/siteassets/resources/documents/online-safety/information-for-industry/illegal-harms/risk-assessment-guidance-and-risk-profiles.pdf https://www.ofcom.org.uk/siteassets/resources/documents/onli... It amounts to your basic terms of service. It means that you'll need to moderate your forums, and prove that you have a policy for moderation. (basically what all decent forums do anyway) The crucial thing is that you need to record that you've done it, and reassessed it. and prove "you understand the 17 priority areas" Its similar for what a trustee of a small charity is supposed to do each year for its due diligence.

baggy_trough 2y ago
Most people don't have time to wade through that amount of bureaucratic legalese, much less put it into practice.
mulmen 2y ago
Is the trustee of a small charity on the hook for £18,000,000 in minimum fines?
- KaiserPro 2y ago
  Trustees for small charities can be personally liable for unlimited amounts. GDPR, Safeguarding, liability for the building you operate in, money laundering. there are lots of laws you are liable for.
- andrewaylett 2y ago
  The maximum fines are 10% of "qualifying worldwide revenue", or £18M, whichever is larger. This is an exercise in stopping companies from claiming tiny revenues when they're actually much larger, rather than fining genuinely tiny companies (or individuals) a ridiculous multiple of their value (or wealth). Plenty of things in UK law attract "an unlimited fine", but even that doesn't lead to people actually being fined amounts greater than all the money that's ever existed.
  - sunshowers 2y ago
    Sounds like a legally risky environment. One of the biggest things we've understood about the world over the last century has been that commerce flourishes under an environment of legal certainty.
pembrook 2y ago
Yep super simple. You just have to make individual value judgements every day on thousands of pieces of content for SEVENTEEN highly specific priority areas. Then keep detailed records on each value judgement such that it can hold up to legal scrutiny from an activist court official. Easy peasy.
- IanCal 2y ago
  > You just have to make individual value judgements every day on thousands of pieces of content That's simply not true.
- aimazon 2y ago
  Any competent forum operator is already doing all of this (and more) just without the government-imposed framework. Would the OP allow CSAM to be posted on their website? No. Would the OP contact the authorities if they caught someone distributing CSAM on their website? Yes. Forum administrators are famous (to the point of being a meme) for their love of rules and policies and procedures.
  - WarOnPrivacy 2y ago
    You just have to make individual value judgements every day on thousands of pieces of content for SEVENTEEN highly specific priority areas. Then keep detailed records on each value judgement such that it can hold up to legal scrutiny from an activist court official. > Any competent forum operator is already doing all of this What is your evidence that the record keeping described by the parent is routine among competent forum operators?
    - jodrellblank 2y ago
      The record keeping requirements described by the parent are completely wrong: https://news.ycombinator.com/item?id=42436626 https://news.ycombinator.com/item?id=42436626
      - WarOnPrivacy 2y ago

baggy_trough 2y ago

Most people don't have time to wade through that amount of bureaucratic legalese, much less put it into practice.

mulmen 2y ago

Is the trustee of a small charity on the hook for £18,000,000 in minimum fines?

KaiserPro 2y ago
Trustees for small charities can be personally liable for unlimited amounts. GDPR, Safeguarding, liability for the building you operate in, money laundering. there are lots of laws you are liable for.
andrewaylett 2y ago
The maximum fines are 10% of "qualifying worldwide revenue", or £18M, whichever is larger. This is an exercise in stopping companies from claiming tiny revenues when they're actually much larger, rather than fining genuinely tiny companies (or individuals) a ridiculous multiple of their value (or wealth). Plenty of things in UK law attract "an unlimited fine", but even that doesn't lead to people actually being fined amounts greater than all the money that's ever existed.
- sunshowers 2y ago
  Sounds like a legally risky environment. One of the biggest things we've understood about the world over the last century has been that commerce flourishes under an environment of legal certainty.

pembrook 2y ago

Yep super simple. You just have to make individual value judgements every day on thousands of pieces of content for SEVENTEEN highly specific priority areas. Then keep detailed records on each value judgement such that it can hold up to legal scrutiny from an activist court official. Easy peasy.

IanCal 2y ago
> You just have to make individual value judgements every day on thousands of pieces of content That's simply not true.
aimazon 2y ago
Any competent forum operator is already doing all of this (and more) just without the government-imposed framework. Would the OP allow CSAM to be posted on their website? No. Would the OP contact the authorities if they caught someone distributing CSAM on their website? Yes. Forum administrators are famous (to the point of being a meme) for their love of rules and policies and procedures.
- WarOnPrivacy 2y ago
  You just have to make individual value judgements every day on thousands of pieces of content for SEVENTEEN highly specific priority areas. Then keep detailed records on each value judgement such that it can hold up to legal scrutiny from an activist court official. > Any competent forum operator is already doing all of this What is your evidence that the record keeping described by the parent is routine among competent forum operators?
  - jodrellblank 2y ago
    The record keeping requirements described by the parent are completely wrong: https://news.ycombinator.com/item?id=42436626 https://news.ycombinator.com/item?id=42436626
    - WarOnPrivacy 2y ago