UK Online Safety Act Complaint and Appeal Handling Workflow

Step 1 - log and classify. Capture the service, account or search result, content or conduct, date, complainant status, safety issue, decision being challenged, and any immediate threat. Preserve the relevant content, notices, policy version, moderation signals, and system logs before they expire.

Step 2 - route by statutory matter. For a user-to-user service, section 21 covers complaints by users and affected persons about specified illegal-content and child-safety duties, content reporting, and certain provider actions; Category 1 services have additional complaint subjects. Section 32 sets the corresponding complaints duty for search services. Check the statutory provision because the eligible complainant and subject differ by route.

Step 3 - contain urgent harm, then decide. Emergency, safeguarding, or law-enforcement escalation can run in parallel with the merits review. The reviewer should apply the Act, the service's terms, the current risk assessment, and the code measure or documented alternative actually adopted. Take appropriate action, explain the outcome in usable language, and complete or assign any correction.

Step 4 - review a challenged decision when the service's applicable procedure provides for it. The baseline sections 21 and 32 duties require a complaints procedure and appropriate action, but they do not create a universal statutory second-tier appeal for every decision. Use a reviewer who was not responsible for the original decision where independence matters, and record the final outcome and correction. Ofcom does not act as a general appeal body for individual cases; eligible entities may bring a statutory super-complaint about features or conduct that present a material risk of significant harm or significantly adversely affect freedom of expression.

The case record should show whether the complainant and subject fall within the applicable statutory procedure. Capture contact preferences, accessibility needs, safeguarding flags, exact allegation, content identifier, original decision, applicable duty and policy, evidence reviewed, outcome, remedy, notice sent, review route, retention rule, and owner.

Review the procedure after a material service or terms change, an Ofcom code update, repeated overturned decisions, missed safeguarding cases, accessibility failures, or evidence that users cannot find or use the route. Sample both upheld and rejected cases and check the result against the evidence available at the time.