UK Online Safety Act Moderation and Appeals

For illegal content, user-to-user services need proportionate systems and processes designed to prevent users encountering priority illegal content, mitigate identified risks, minimise how long priority illegal content remains, and swiftly take down illegal content when the provider becomes aware of it. Search services must minimise the risk of users encountering priority illegal content and known illegal content in or via search results.

Services likely to be accessed by children have additional duties for content harmful to children. The exact moderation design depends on the service, assessed risks, applicable duties, and Ofcom codes. Measures can include detection, triage, human review, removal, visibility reduction, recommendation controls, account action, user support, and escalation, but each measure must be justified and tested in context.

A content-reporting mechanism lets users and other eligible people notify the provider about content of a kind covered by the Act. A complaints procedure covers specified complaints about content, the provider's compliance, and certain provider decisions. For user-to-user services, sections 20 and 21 govern these duties; sections 31 and 32 cover search services.

The complaints procedure must allow relevant complaints, provide for appropriate action when a complaint is upheld, be easy to access and use, including by children, and be transparent. Appropriate action depends on the case. It may include removing illegal content, correcting a restriction, reinstating content removed in error, or changing an account decision. The Act does not require every complaint to produce the user's preferred result.

User-to-user terms must explain how users are protected from illegal content and set out the complaints policies and procedures required by the Act. Search services must make the corresponding illegal-content statement and complaints information public. Providers must apply stated provisions consistently.

Useful evidence includes moderation guidance, training, quality sampling, model and rule versions, error analysis, response times, reversals, repeat reports, systemic issues, staffing and language coverage, vendor oversight, child accessibility, and remediation. Metrics need stable definitions and should distinguish reports, pieces of content, decisions, accounts, complaints, and successful complaints.