Right. Ofcom's next online session is about "low risk" services.
I'll be tooting my thoughts in this thread.
Feel free to mute if you wish :)
[#]OnlineSafetyAct
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"We haven't done a great deal of work about decentralised services in detail".
We can't give you a specific answer to who the provider might be.
(I fear "we can't help with that" will be a common theme.)
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Nope. Skipped over that.
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An excellent question from @cyberleagle, which Ofcom's webinar system has mangled badly:
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Ofcom is using an example of a "small gaming service" with "around 15,000 monthly UK users".
I wonder if Ofcom recognises that many of the people worrying about the OSA are talking about services with 0.1% of that userbase?!
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Even if low risk, you must have:
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I'll try to find some spare time to write some template "not legal advice" terms and conditions, and complaints-related information.
Although, honestly, goodness knows how that applies in the context of, say,
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Questions!
"We probably can't give a definitive answer..."
What about services which are new, so have no evidence base?
Answer: you're right, we can't give a definitive answer...
sigh
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Oooh!
I think Ofcom has just said that single-user Mastodon instances are out of scope.
They read out my question, and said that.
But I fear that they have said that without knowing what the service is...
Even so, I'll be looking for that part of the recording :)
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Question: is a complaints contact email address sufficient?
Answer: "there is a lot of flexibility, and what is "easy to use" will look different for different services"
Ofcom thinks that they've said somewhere that a contact email address might be sufficient.
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They attempted to answer @cyberleagle's question about the meaning of "illegal harm", and I'm not sure if they answered it or not...
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@neil I am now also watching this live.
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@neil Why does the presenter need to say "next slide"? Are they unable to use powerpoint?
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@bloor @neil AI. AI everywhere.
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@bloor @neil Maybe they're a big fan of Professor Sir Chris Whitty?
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@neil
Okay, so if they're plaintext emails with uuencoded (or base64 encoded) images inside… 😛
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@gumnos @neil
ASCIIPron FTW! OK, for the UK but with ROT13.
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@gumnos@bsd.cafe @neil@mastodon.neilzone.co.uk alt.binaries.*
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@neil what of urls to images?
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@revk @neil
He's just mentioned that "there have been a low number of instances of problems in the past" and that being a factor in determining risk.
How do you launch a new service then? It has no history?
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@revk @neil Or put another way, can you reduce your judgement of risk as time goes by, and by necessity must you start from a "high place" and then gradually downgrade your judgement of risk, as traffic grows but problems do not?
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@neil what of urls that, at the time of posting, are benign and later become less legal?
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@neil Ha! The ASCII-art archives from the 80's and early 90's would like a word!
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@neil for IRC, I'd argue that the message, from a server perspective, is utterly ephemeral -- there's [typically] no storage of the message so there's nothing to delete. The user's IRC client may store (cache?) the message but that's surely out of scope.
I'm deliberately ignoring the possibility of bots/services on ircnets which may store messages.
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@neil Terms and conditions readable by the lowest reading age that can access your site.
For some childrens sites, that sounds hillarious!
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@tony @neil And for any sites for adults.
1 in 7 English adults have a reading age of an average 9-11 year old and there are enough at EL1 or EL2 that they might access your site. EL1 is 5-7.
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@tony @neil
And "lowest reading age" doesn't refer to lowest age. Many adults have a far lower reading age than might be expected. So all Terms and Conditions are going to have to be in very plain English, unlike almost all Terms and Conditions currently.
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@neil I'd be particularly interested to know about things like private messaging systems on forums: is giving people the ability to report content in a private messages system enough for "ability to review", or would it oblige service providers to be able to easily read every message?
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@neil how does one take down irc DMs? How does one make people unsee messages?
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@revk This worries me, especially given the comment that Ofcom expects that all sites/services will be able to comply.
That, to me, is a misunderstanding of some (common, well-used) technology at play.
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@neil @revk in fact this thread makes me wonder if amateur radio repeaters that connect together over the internet are in scope. Ofcom’s own scope tool suggests they are and my (admittedly brief) reading of the act would seem to confirm it. https://www.legislation.gov.uk/ukpga/2023/50/section/228 - I think it would be basically impossible for them to comply.
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@neil I wonder if there is a market for individuals with nothing, homeless, that can sell their name as responsible individual for £100 to people running services?
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@neil How would they do spot checks? Which is to say, do they have a list of services that are in scope? If not, are they planning to compile one? One thing I don't recall seeing anywhere is any obligation to register with Ofcom or similar.
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@JubalBarca @neil the act has some wording about user-to-user and search services registering with Ofcom over some kinda fee structure, although I did speed read so I have missed out some detail
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@neil oh well, as long as they probably won't fine me £18m for failing to navigate their illegible guidance, that's ok then.
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@neil Does that paperwork have to be in English. It looks like having a set of policies in Welsh ought to be just fine and ensure they get tied in knots if they try to be silly, just like with tax inspections.
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@etchedpixels @neil presumably providing such policies exclusively in Welsh would be a strong indicator that the "target market" wasn't the whole of the UK, and therefore take yourself out of scope? 🏴
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@ahnlak @neil Now that's a thought. I wonder what services you could include that would mean your website wasn't suitable for the EU market and therefore Northern Ireland 8)
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@etchedpixels
If you can do that without it being in English, then that should be compliant.
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@neil Maybe there's an argument here that the Act is concerned specifically with unitary service providers, and so "users" have to be understood as partitioned between instances, rather than existing across multiple services? I have no idea how to read that statement other than "they did not understand the question".
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@aphyr
Even then though it doesn't take into account people accessing via the web interface, not from a federated instance.
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@neil If you never manage to get a copy of the recording, I also witnessed them say that on the live stream, having read out your question. And would be happy to provide a witness statement.
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@bloor Thank you!
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@neil Did you… did you just engineer a waiver of the OSA specifically for your single-user Fedi instance??!
I’m in awe.
@bloor
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@neil Ah, but is it single user according to their definitions? I thought you were saying users included anyone viewing it, no? You might be the only admin user, and the only user with a local account, but I think we are all users of your Mastodon instance according to this ridiculous law aren't we?
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@dentangle My question was
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@neil@mastodon.neilzone.co.uk @dentangle@chaos.social What's the betting they didn't consider federated content arriving on your server from the outside world, and assessed it as if it was your personal blog where the only content was what you yourself had authored?
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@neil 'I have evidence you said it was ok' is quite a mitigation, I would say :-D
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@neil well that would be good… cynically, you’re probably right….
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@neil In my instance, being one of several co-owners/admins of a forum, could I nominate one of the US based admins as the accountable individual, as not being resident in the UK, are less likely to be at risk? Not that I would, but I could see people giving it a try!
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@neil this is the exact position I’m in for the football fan forum I run. I’ve signed up for a seminar by someone called “Promising Trouble “ but I guess it’s not an official ofcom one…?!?
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