Illegal content risk assessment for the Online Safety Act

Document history

Version	Date	Author	Comment
1.0	2025-02-12	Peter Molnar	Contact: mail@petermolnar.net

Background

This is a personal website that exists for fun and to have a home online.

Key facts

• I – Nora Hamucska – am a resident of the United Kingdom
• The server is located in the United Kingdom
• Me and my spouse are the only administrators, editors, and content providers of the service
• Me and my spouse are the only people who can create or approve new content on the service
• Anyone in the world can view the service
• Someone who accesses the web interface of the service can see the content.

Online Safety Act illegal content risk assessment

Key information

Information	Answer
The service to which the risk assessment relates	self-hosted website at: norahamucska.com  and any subdomain service under the same domain
The named person responsible for the risk assessment	Nora Hamucska
The findings of this risk assessment have been reported and recorded through appropriate governance channels	Yes: logged in this document
Next scheduled review date	2026-02-01

Document history

Date	Version	Nature of change (created / reviewed / updated)	Who completed the risk assessment	Who approved the risk assessment
2025-02-12	0.1	Created	NB	NB

Ofcom’s suggested steps

• Step 1: Understand the kinds of illegal content that need to be assessed
• Step 2: Assess the risk of harm
• Step 3: Decide measures, implement, and record
• Step 4: Report, review, and update

Ofcom’s risk factors

Me and my spouse are the only administrators, editors, and content providers of the service, and we are the only people who can create or approve new content on the service.

According to Ofcom’s risk factors guidance:

• 2 (child access): there is no access control, so a child could view my instance. Nothing on my instance is particularly attractive to children
• 4a (user connections): people can follow me via feeds or other means
• 5e (posting images or videos): I can post images/videos
• 7b (hyperlinks): I can post hyperlinks

Priority legal content

Type of content	Risk factors (from Ofcom’s risk profiles)	Conclusion	Rationale	Measures
Terrorism	1a, 4a, 5,b, 5e, 7b	Negligible	There is no content like this is, or will ever be posted, therefore likelihood of a visitor encountering this content is nonexistent.	None
Child Sexual Exploitation and Abuse (CSEA): Grooming	1a, 2, 3a, 4a, 5b	Negligible	There is no content like this is, or will ever be posted, therefore likelihood of a visitor encountering this content is nonexistent.	None
Child Sexual Exploitation and Abuse (CSEA): Images	1a, 2, 5b	Negligible	There is no content like this is, or will ever be posted, therefore likelihood of a visitor encountering this content is nonexistent.	None
Child Sexual Exploitation and Abuse (CSEA): URLs	7b	Negligible risk	There is no content like this is, or will ever be posted, therefore likelihood of a visitor encountering this content is nonexistent.	None
Encouraging or assisting suicide	1a, 5e, 5g, 7b	Negligible	There is no content like this is, or will ever be posted, therefore likelihood of a visitor encountering this content is nonexistent.	None
Hate	1a, 3a, 5e	Negligible	There is no content like this is, or will ever be posted, therefore likelihood of a visitor encountering this content is nonexistent.	None
Harassment, stalking, threats and abuse	1a, 3a, 4a, 5b, 5e, 5g	Negligible	There is no content like this is, or will ever be posted, therefore likelihood of a visitor encountering this content is nonexistent.	None
Controlling or coercive behaviour	1a, 4a, 5b	Negligible	There is no content like this is, or will ever be posted, therefore likelihood of a visitor encountering this content is nonexistent.	None
Drugs and psychoactive substances	1a, 3a, 4a, 5b, 5e, 7b	Negligible	There is no content like this is, or will ever be posted, therefore likelihood of a visitor encountering this content is nonexistent.	None
Firearms, knives or other weapons	1a	Low	There is no content like this is, or will ever be posted, therefore likelihood of a visitor encountering this content is nonexistent.	None
Human trafficking	1a, 3a, 5e	Negligible	There is no content like this is, or will ever be posted, therefore likelihood of a visitor encountering this content is nonexistent.	None
Unlawful immigration	1a, 3a, 5e	Negligible	There is no content like this is, or will ever be posted, therefore likelihood of a visitor encountering this content is nonexistent.	None
Sexual exploitation of adults	1a, 3a	Negligible	There is no content like this is, or will ever be posted, therefore likelihood of a visitor encountering this content is nonexistent.	None
Extreme pornography	1a, 5e	Negligible	There is no content like this is, or will ever be posted, therefore likelihood of a visitor encountering this content is nonexistent.	None
Intimate image abuse	1a, 5b, 5g	Negligible	There is no content like this is, or will ever be posted, therefore likelihood of a visitor encountering this content is nonexistent.	None
Proceeds of crime	1a, 3a	Negligible	There is no content like this is, or will ever be posted, therefore likelihood of a visitor encountering this content is nonexistent.	None
Fraud and financial offences	1a, 3a, 4a, 5b, 7b	Negligible	There is no content like this is, or will ever be posted, therefore likelihood of a visitor encountering this content is nonexistent.	None
Foreign interference	1a, 3a, 4a, 5e, 5g, 7b	Negligible	There is no content like this is, or will ever be posted, therefore likelihood of a visitor encountering this content is nonexistent.	None
Animal cruelty	1a, 5e	Negligible	There is no content like this is, or will ever be posted, therefore likelihood of a visitor encountering this content is nonexistent.	None

Other illegal content

Illegal content/offence	Risk of encountering this content/offence	Rationale	Measures that you will implement using Ofcom’s Codes of Practice or alternative measures
All other content / offences	Negligible	The likelihood of a visitor encountering other illegal content, or the service being used to facilitate or commit other offences, is incredibly low, due to the manual, always present moderation of any incoming links or content.	None

 

Safety duties about illegal content

The following sets out my approach to compliance with the various safety duties in s10 OSA.

See also Ofcom’s recommended measures (table on page 8).

Proportionality

Some of the duties require me to take “proportionate measures”.

In determining what is proportionate, the OSA says that “the size and capacity of the provider of the service” are particularly relevant.

To that end, I am quite large, with a significant capacity for being caring and understanding.

Duties and approach

Duty	My approach
To prevent individuals from encountering priority illegal content by means of the service	We will not post illegal content.
To effectively mitigate and manage the risk of the service being used for the commission or facilitation of a priority offence	We will not post illegal content.
To effectively mitigate and manage the risks of harm to individuals	No additional actions planned.
To minimise the length of time for which any priority illegal content is present	We will take down any illegal content.
Where the provider is alerted by a person to the presence of any illegal content, or becomes aware of it in any other way, swiftly take down such content	We will take down any illegal content.
To have in place regulatory compliance and risk management arrangements	We do not consider that these are proportionate to the risk.
design of functionalities, algorithms and other features	There are no algorithms on the site.
policies on terms of use	There is no terms of use.
policies on user access to the service or to particular content present on the service, including blocking users from accessing the service or particular content	There is no access control on the site.
content moderation, including taking down content
functionalities allowing users to control the content they encounter	This is not relevant to my website.
user support measures	This is not relevant to my website.
staff policies and practices	This is not relevant to my website.
to include provisions in the terms of service specifying how individuals are to be protected from illegal content	There are no terms of service.
A duty to apply the provisions of the terms of service consistently	There are no terms of service.
A duty to include provisions in the terms of service giving information about any proactive technology used by a service for the purpose of compliance with a duty set out in s10(2) or 10(3) (including the kind of technology, when it is used, and how it works).	There are no terms of service.
A duty to ensure that the provisions of the terms of service are clear and accessible	There are no terms of service.

In accordance with s66, if I were to become aware of unreported CSEA, I will report it to the NCA.

Ofcom reference	Measure	Comment
ICU A2	Accountable individual	Nora Hamucska
ICU C1	Content moderation function	I will review and assess suspected illegal content
ICU C2	Take down	I will remove reported illegal content
ICU D1	Enabling complaints	Anyone can complain via mail@norahamucska.com
ICU D2	Easy to find complaints information	Use mail@norahamucska.com
ICU D7	Appropriate action for complaints	I will handle any complaints
ICU D10	Appeals	I will handle appeals
ICU D11	Proactive technology	I am not using proactive technology
ICU D12	Appropriate action for complaints	As per ICU D7, I will handle any complaints
ICU D13	Manifestly unfounded complaints	I will handle complaints
ICU G1	Terms of service	Not applicable
ICU G3	Clarity of terms	See ICU G1
ICU H1	Proscribed organisations	I will block anyone I become aware that they are a member of a proscribed organisation.

Actions

Action	Date	Status
None	n/a	n/a

 

This document is based on Neil Brown‘s work and is licensed under Creative Commons CC BY-SA 4.0.