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Online Safety Act Risk Assessment
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Service name:
Westfield-Eleven.org
Service type:
User-to-user (U2U) service
Status:
2025 Risk Assessment
Completion date:
15 Mar 25
Next review/update date:
01 Apr 25
Reason for review:
Initial Issue
Completed by:
Jon Clancy
Named person responsible for the risk assessment:
Jon Clancy
Approved by (governance and accountability channels):
Jon Clancy
CONTENTS
Scope Check
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1. Does your online service have links with the UK?
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Yes
2. Do you provide a “user-to-user” service?
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Yes
3. Do you provide a search service?
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No
4. Does your online service publish or display provider pornographic content?
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No, we don’t publish/display any pornographic content
5. Do any exemptions apply to the user-generated content on your online service? Select all that apply
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- [ ] Yes, users can only communicate by email, SMS, MMS and/or one-to-one live aural communications; or
- [ ] Yes, users can only interact with content generated by my business
- [X] No, my service is not limited to these types of content
6. Do any exemptions apply to your online service? Select all that apply
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- [ ] Yes, it is an internal business service, including services such as business intranet, content management systems, or customer relationship management systems
- [ ] Yes, it is provided by a public body, such as Parliament, a UK public authority, or foreign government
- [ ] Yes, it is provided by an UK education or childcare provider
- [X] No, none of the above applies
Step 1: U2U and Search Risk Profiles and Risk Factors
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User-to-User Service Risk Profile and Risk Factors
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1. Is your service any of these types?
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- [ ] Social media service
- [ ] Messaging service
- [ ] Gaming service
- [ ] Adult service
- [X] Discussion forum or chat room
- [ ] Marketplace or listing service
- [ ] File-sharing or file storage service
- [ ] None of the above
2. Do child users access some or all of the service?
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Yes. Apart from the Members Area sub-forum, which requires a log in, most areas of the Westfield Eleven Register website and forum are open to public view.
3. Does your service include any of these user identification functionalities?
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- [X] User profiles
- [ ] Anonymous user profiles or users without accounts
- [ ] None of the above
*Note:* Most posted content is publicly available for users without accounts to view, but there is no way to identify these users.
4. Does your service include any of these user networking functionalities?
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- [ ] Users can connect with other users
- [ ] Users can form closed groups or send group messages
- [X] None of the above
5. Does your service include any of these user communication functionalities?
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- [ ] Livestreaming (either open or closed channels)
- [ ] Direct messaging (including ephemeral direct messaging)
- [ ] Encrypted messaging
- [X] Commenting on content
- [X] Posting or sending images or videos (either open or closed channels)
- [ ] Posting or sending location information
- [ ] Re-posting or forwarding content
- [ ] None of the above
Users may add their own location to their profile, but this is rarely done. Automatic location display is not a feature that the service provides directly.
6. Does your service allow users to post goods and services for sale?
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Not as a marketplace like eBay. However, members may offer surplus parts to other registered users FOC or for nominal sums occasionally.
7. Does your service include any of the following functionalities that allow users to find or encounter content? Tick all that apply.
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- [X] Searching for user-generated content
- [X] Hyperlinking
- [ ] None of the above
8. Does your service use content or network recommender systems?
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No
Step 2: U2U and Search: Assess the risk of harm
=========================================
Additional characteristics and existing controls
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Some definitions:
Absence of Harmful Content
The Westfield Eleven Register forum went live on 29 Jan 09. There has not been a single instance of harmful content within the meaning of the OSA being posted.
Active Moderation
There are currently 125 Registered Users on the forum, of which only a dozen or so post content. Post count is very low, and all new users are approved by Administrator. Only Registered Users are permitted to post. There has never been any harmful content posted, and the poster would be instantly identified by the Admin and Moderators.
Little Content and Few Users
The Forum currently has 125 Registered Members of which 4 have been active in the preceding 30 days. In total, there are 692 Topics and 6163 Postings.
No Child Users
This is a discussion forum for a small volume kit car. There is no evidence of children posting as Registered Members or visiting our service, but acknowledge that children may view the publicly visible sections of the site.
Risk levels and evidence
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Terrorism
——————
Risk level:
Negligible
Risk factors considered:
Unlikely to be found on a specialised kit car forum.
Additional characteristics considered:
*Little Content and Few Users*
Existing controls considered:
Moderation - reporting and removal of any harmful content.
Evidence:
*Absence of Harmful Content*, *Little Content and Few Users*
Child sexual exploitation and abuse (CSEA) offences
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Risk level:
Low
Risk factors considered:
Unlikely to be found on a specialised kit car forum.
Additional characteristics considered:
*Little Content and Few Users*
Existing controls considered:
Moderation - reporting and removal of harmful content.
Evidence:
*Absence of Harmful Content*, *Little Content and Few Users*, *No Child Users*
Grooming (child sexual exploitation and abuse)
——–——————————————————————————
Risk level:
Low
Risk factors considered:
Unlikely to be found on a specialised kit car forum.
Additional characteristics considered:
*Little Content and Few Users*
Existing controls considered:
Moderation - reporting and removal of harmful content.
Evidence:
*Absence of Harmful Content*, *Little Content and Few Users*, *No Child Users*
Image-based child sexual abuse material
—————————————————-———————
Risk level:
Low
Risk factors considered:
Unlikely to be found on a specialised kit car forum.
Additional characteristics considered:
*Little Content and Few Users*
Existing controls considered:
Moderation - reporting and removal of harmful content.
Evidence:
*Absence of Harmful Content*, *Little Content and Few Users*, *No Child Users*
Child sexual abuse material URLs
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Risk level:
Low
Risk factors considered:
Unlikely to be found on a specialised kit car forum.
Additional characteristics considered:
*Little Content and Few Users*
Existing controls considered:
Moderation - reporting and removal of harmful content.
Evidence:
*Absence of Harmful Content*, *Little Content and Few Users*, *No Child Users*
Hate
———
Risk level:
Low
Risk factors considered:
Unlikely to be found on a specialised kit car forum.
Additional characteristics considered:
*Little Content and Few Users*
Existing controls considered:
Moderation - reporting and removal of harmful content.
Evidence:
*Absence of Harmful Content*, *Little Content and Few Users*
Harassment, stalking, threats and abuse offences
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Risk level:
Low
Risk factors considered:
Unlikely to be found on a specialised kit car forum.
Additional characteristics considered:
*Little Content and Few Users*
Existing controls considered:
Moderation - reporting and removal of harmful content.
Evidence:
*Absence of Harmful Content*, *Little Content and Few Users*
Controlling or coercive behaviour
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Risk level:
Low
Risk factors considered:
Unlikely to be found on a specialised kit car forum.
Additional characteristics considered:
*Little Content and Few Users*
Existing controls considered:
Moderation - reporting and removal of harmful content.
Evidence:
*Absence of Harmful Content*, *Little Content and Few Users*
Intimate image abuse
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Risk level:
Low
Risk factors considered:
Unlikely to be found on a specialised kit car forum.
Additional characteristics considered:
*Little Content and Few Users*
Existing controls considered:
Moderation - reporting and removal of harmful content.
Evidence:
*Absence of Harmful Content*, *Little Content and Few Users*
Extreme pornography offence
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Risk level:
Low
Risk factors considered:
Unlikely to be found on a specialised kit car forum.
Additional characteristics considered:
*Little Content and Few Users*
Existing controls considered:
Moderation - reporting and removal of harmful content.
Evidence:
*Absence of Harmful Content*, *Little Content and Few Users*
Sexual exploitation of adults
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Risk level:
Low
Risk factors considered:
Unlikely to be found on a specialised kit car forum.
Additional characteristics considered:
*Little Content and Few Users*
Existing controls considered:
Moderation - reporting and removal of harmful content.
Evidence:
*Absence of Harmful Content*, *Little Content and Few Users*
Human trafficking
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Risk level:
Low
Risk factors considered:
Unlikely to be found on a specialised kit car forum.
Additional characteristics considered:
*Little Content and Few Users*
Existing controls considered:
Moderation - reporting and removal of harmful content.
Evidence:
*Absence of Harmful Content*, *Little Content and Few Users*
Unlawful immigration
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Risk level:
Low
Risk factors considered:
Unlikely to be found on a specialised kit car forum.
Additional characteristics considered:
*Little Content and Few Users*
Existing controls considered:
Moderation - reporting and removal of harmful content.
Evidence:
*Absence of Harmful Content*, *Little Content and Few Users*
Fraud and financial services offences
—————————-—————————————
Risk level:
Low
Risk factors considered:
Unlikely to be found on a specialised kit car forum.
Additional characteristics considered:
*Little Content and Few Users*
Existing controls considered:
Moderation - reporting and removal of harmful content.
Evidence:
*Absence of Harmful Content*, *Little Content and Few Users*
Proceeds of crime
———————————
Risk level:
Low
Risk factors considered:
Unlikely to be found on a specialised kit car forum.
Additional characteristics considered:
*Little Content and Few Users*
Existing controls considered:
Moderation - reporting and removal of harmful content.
Evidence:
*Absence of Harmful Content*, *Little Content and Few Users*
Drugs and psychoactive substances
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Risk level:
Low
Risk factors considered:
Unlikely to be found on a specialised kit car forum.
Additional characteristics considered:
*Little Content and Few Users*
Existing controls considered:
Moderation - reporting and removal of content.
Evidence:
*Absence of Harmful Content*, *Little Content and Few Users*
Firearms, knives and other weapons
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Risk level:
Low
Risk factors considered:
Unlikely to be found on a specialised kit car forum.
Additional characteristics considered:
*Little Content and Few Users*
Existing controls considered:
Moderation - reporting and removal of harmful content.
Evidence:
*Absence of Harmful Content*, *Little Content and Few Users*
Encouraging or assisting suicide (or attempted suicide)
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Risk level:
Low
Risk factors considered:
Unlikely to be found on a specialised kit car forum.
Additional characteristics considered:
*Little Content and Few Users*
Existing controls considered:
Moderation - reporting and removal of harmful content.
Evidence:
*Absence of Harmful Content*, *Little Content and Few Users*
Foreign interference offence
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Risk level:
Low
Risk factors considered:
Unlikely to be found on a specialised kit car forum.
Additional characteristics considered:
*Little Content and Few Users*
Existing controls considered:
Moderation - reporting and removal of harmful content.
Evidence:
*Absence of Harmful Content*, *Little Content and Few Users*
Animal cruelty
—————————
Risk level:
Low
Risk factors considered:
Unlikely to be found on a specialised kit car forum.
Additional characteristics considered:
*Little Content and Few Users*
Existing controls considered:
Moderation - reporting and removal of harmful content.
Evidence:
*Absence of Harmful Content*, *Little Content and Few Users*
COMMENT: Those risk levels above that are assessed as "Low" are considered "Negligible" by the assessor due to the nature of the forum and its membership profile. However, the OFCOM guidance suggests that these can only be assessed as "Negligible" in very specific circumstances. In theory, the majority of offences listed above could be committed on this simple forum. The reality is that this is very highly unlikely.
Step 3: U2U and Search: Decide measures, implement and record
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How many monthly active UK users does your service have?
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The Westfield Eleven Register has 4 active users in the last 30 days, which include non-UK users.
There is no data for how many UK users there are, as this information is neither asked for, displayed nor recorded.
ICU A2: Individual accountable for illegal content safety duties and reporting and complaints duties
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Status:
Implemented
Date measure takes/took effect:
15 Mar 25
Relevant codes:
Child sexual exploitation and abuse, Terrorism, Other duties
Relevant duties
Section 10(2), (3), and (5) to (9). Section 20(2). Section 21(2) and (3) Online Safety Act 2023
ICU C1: Content moderation function to review and assess suspected illegal content
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Status:
Implemented
Date measure takes/took effect:
23 Jan 11
Relevant codes:
Child sexual exploitation and abuse, Terrorism, Other duties
Relevant duties:
Section 10(2) and(3). Section 21(2)(b) Online Safety Act 2023
ICU C2: Having a content moderation function that allows for the swift take down of illegal content
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Status:
Implemented
Date measure takes/took effect
23 Jan 11
Relevant codes:
Child sexual exploitation and abuse, Terrorism, Other duties
Relevant duties:
Section 10(2) and (3). Section 21(2)(b) Online Safety Act 2023
ICU D1: Enabling complaints
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Status:
Implemented
Date measure takes/took effect:
29 Jan 09
Relevant codes:
Child sexual exploitation and abuse, Terrorism, Other duties
Relevant duties:
Section 20(2). Section 21(2)(a) Online Safety Act 2023
ICU D2: Having easy to find, easy to access and easy to use complaints systems and processes
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Status:
Implemented
Date measure takes/took effect:
29 Jan 09
Relevant codes:
Child sexual exploitation and abuse, Terrorism, Other duties
Relevant duties
Section 20(2). Section 21(2)(c) Online Safety Act 2023
ICU D7: Appropriate action for relevant complaints about suspected illegal content
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Status:
Implemented
Date measure takes/took effect:
29 Jan 09
Relevant codes:
Child sexual exploitation and abuse, Terrorism, Other duties
Relevant duties:
Section 10(3). Section 21(2)(b) Online Safety Act 2023
ICU D9: Appropriate action for relevant complaints which are appeals – determination
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Status:
Implemented
Date measure takes/took effect:
29 Jan 09
Relevant codes:
Child sexual exploitation and abuse, Terrorism, Other duties
Relevant duties:
Section 21(2)(B) Online Safety Act 2023
ICU D10: Appropriate action for relevant complaints which are appeals – action following determination
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Status:
Implemented
Date measure takes/took effect:
29 Jan 09
Relevant codes:
Child sexual exploitation and abuse, Terrorism, Other duties
Relevant duties:
Section 21(2)(b) Online Safety Act 2023
ICU D11: Appropriate action for relevant complaints about proactive technology, which are not appeals
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Status:
Not Implemented
Date measure takes/took effect
N/A, we do not use proactive *technology*.
Relevant codes:
Child sexual exploitation and abuse, Terrorism, Other duties
Relevant duties:
Section 21(2)(b) Online Safety Act 2023
ICU D12: Appropriate action for all other relevant complaints
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Status:
Implemented
Date measure takes/took effect:
29 Jan 09
Relevant codes:
Child sexual exploitation and abuse, Terrorism, Other duties
Relevant duties:
Section 21(2)(b) Online Safety Act 2023
ICU D13: Exception: manifestly unfounded complaints
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Status:
Implemented
Date measure takes/took effect
29 Jan 09
Relevant codes:
Child sexual exploitation and abuse, Terrorism, Other duties
Relevant duties:
Section 21(2)(b) Online Safety Act 2023
ICU G1: Terms of service: substance (all services)
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Status:
Implemented:
Date measure takes/took effect:
23 Jan 11
Relevant codes
Child sexual exploitation and abuse, Terrorism, Other duties
Relevant duties
Section 10(5) and (7). Section 21(3) Online Safety Act 2023
ICU G3: Terms of service: clarity and accessibility
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Status:
Implemented
Date measure takes/took effect:
29 Jan 09
Relevant codes:
Child sexual exploitation and abuse, Terrorism, Other duties
Relevant duties:
Section 10(8). Section 21(3) Online Safety Act 2023
ICU H1: Removing accounts of proscribed organisations
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Status:
Implemented
Date measure takes/took effect:
29 Jan 09
Relevant codes:
Terrorism
Relevant duties:
Section 10(2) and 10(3) Online Safety Act 2023
Step 4: U2U and Search: Report, review, and update risk assessments
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Date of next annual risk assessment: 1 Apr 25.
Confirmation findings of the illegal content risk assessment have been reported, and recorded: Yes, see above.
Date the findings of the illegal content risk assessment were reported, and recorded: 15 Mar 25.
Information on how you take appropriate steps to keep the risk assessment up to date (for example, a written policy):
A Risk Assessment Review will be undertaken if the forum makes major changes to the way it operates. This will not include any reorganisation of current content or sub-forum layout. Ongoing monitoring for any content posted that might change the above risk assessment. Annual review on 1 Apr each year, with findings published soon after.
Children's Access Assessment
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[See: https://www.ofcom.org.uk/online-safety/ ... sessments/]
Stage 1
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Is it possible for children to access the service or part of it?
Yes
There is no evidence of children posting as Registered Members or visiting our service, but acknowledge that children may view the publicly visible sections of the site. There are no age verification tools, or limits on the ages of people viewing the forum. Only Registered Members may post content or access the Private Messaging function.
Stage 2
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Are there a significant number of children who are users of the service?
No
*Note:* There is no evidence of children accessing our service. It is impossible to know whether visitors are aged under 18 or not.
Is the service of a kind likely to attract a significant number of children?
No
Result
No need to carry out a Children's Risk Assessment.
OSA Risk Assessment Initial Issue
Moderator: jonclancy