@neil @networkstring That's my understanding.
Since Ofcom, and the law, don't provide absolute definitions, the only entity who can make this assessment is the nominated person responsible. Which for this forum is me.
I asked what happens if someone else disagrees with my assessment at the Ofcom presentation. Would Ofcom arbitrate? They mumbled about the online service's complaints procedure, which I took to mean "no".
If I'm the named person responsible for the risk assessments, I get to have the final say. I think...
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