Artifact GuideUKRisk Assessments Playbook

UK Online Safety Act Risk Assessments Playbook

Use one operating playbook to assign assessment inputs, challenge weak evidence, approve mitigations, and reopen decisions when the service changes.

The playbook coordinates the work; it does not merge the Act's separate illegal-content, children's access, and children's risk-assessment duties.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

A risk-assessment playbook sets the operating rules around the Part 3 legal assessments: who opens them, which evidence each team supplies, how risks are challenged, who approves controls, and what reopens the record. Use it for every regulated user-to-user and search service, while keeping the illegal-content assessment, children's access assessment, and any children's risk assessment identifiable as separate outputs with their own statutory tests and deadlines.

Section 1

How should the risk assessments playbook operate?

Intake opens a versioned assessment for a defined service, a new or newly in-scope service, or a proposed . Legal or regulatory owners confirm the applicable duty and deadline; product and engineering describe the design; trust and safety supplies harm and enforcement evidence; data teams quantify prevalence, reach, recommender exposure, search pathways, complaints, and uncertainty; privacy, security, accessibility, and child-safety specialists test proposed controls.

A challenge meeting tests scope, missing evidence, foreseeable misuse, groups at greater risk, design choices that amplify harm, control dependencies, and the residual-risk conclusion. Unsupported conclusions return for more evidence rather than converting uncertainty into a low score.

Approval links each material risk to a current control, owner, delivery date, monitoring signal, and in-force Ofcom code measure or documented effective alternative. The Act sets the binding duty; Ofcom codes describe a compliance route, guidance explains Ofcom's approach, and consultations do not impose current requirements. The accountable owner approves only after urgent actions and launch gates are explicit.

Operations monitors the assumptions. Product change, new harm evidence, control failure, or an Ofcom update creates a review ticket and identifies which assessment versions must be reopened.

  • Responsibilities: name the accountable executive and the people responsible for scope, evidence, analysis, control delivery, independent challenge, approval, and monitoring.
  • Evidence rule: link conclusions to reproducible queries, test reports, complaint samples, policy versions, risk profiles, and dated specialist input; label estimates and data gaps.
  • Decision rule: a high-severity plausible harm cannot be closed solely because current prevalence is low or unknown.
  • Change rule: release processes must ask whether the change is significant or makes an existing assessment potentially inaccurate before release. A requires the relevant assessment before release; Ofcom also recommends reviewing assessments at least every 12 months.
Section 2

Which assessment, action, and monitoring records are needed?

Maintain an assessment register with service, assessment type, version, statutory provision, owner, approval date, next scheduled review, event-driven review trigger, significant-change decision, open actions, and evidence location. Within each assessment, keep separate rows for each content or harm pathway and each materially affected user group.

  • Input pack: service map, user and child-access evidence, Ofcom risk profiles, internal metrics, user research, complaints, incidents, control tests, and planned changes.
  • Decision pack: scoring rationale, uncertainties, control mapping, code comparison, rejected alternatives, residual risk, approvals, and launch conditions.
  • Action log: accountable owner, deliverable, completion evidence, due date, dependency, status, and escalation path.
  • Monitoring plan: metric definition, baseline, threshold, owner, review frequency, and the assessment reopened when the threshold is crossed.
Section 3

When should the operating process change?

Review the playbook when assessments repeatedly miss the same evidence, actions remain overdue, control tests cannot be reproduced, or product teams bypass the significant-change gate. Review the underlying statutory assessment whenever the Act's accuracy or significant-change trigger is met; an annual calendar alone is not enough.

  • Sample completed assessments and trace each conclusion back to evidence and each mitigation forward to production evidence.
  • Compare predicted risk with incidents, complaints, prevalence, exposure, and bypass data after launch.
  • Escalate overdue high-risk actions and record any interim restriction or compensating control.
  • Retire fields that do not affect a decision and add missing fields when a review identifies a real evidence or ownership gap.
Primary sources

References and citations

ico.org.uk2 citations
Referenced sections
  • ICO observations on children's privacy practices in sampled platforms.
  • Shows how ICO child-privacy reviews can inform age-appropriate evidence and review triggers in an Online Safety Act risk-assessment playbook.
"Children's code"
gov.uk2 citations
Referenced sections
  • Government overview of the Online Safety Act.
  • Confirms the Act's overall platform duties, supporting the playbook's scope triage before code mapping and mitigation assignment.
"The Online Safety Act 2023 (the Act) is a new set of laws that protects children and adults online."
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