New safety compliance regulation launches a new era, setting the example for others to follow


As digital communication continues to grow, so does the rise in abuse, hate speech and harassment. Ensuring online communities are safe has become a larger and evolving challenge, resulting in increased scrutiny over digital platforms.

As many communities struggle to get up to speed, the UK government is acting, driving change, and bringing in a new era of online safety compliance. The proposed UK Online Safety Bill would establish a regulatory regime to address illegal and harmful content online, specifically pertaining to individuals in the United Kingdom.

The bill’s scope covers illegal content, such as terrorism and CSEA (Child Sexual Exploitation and Abuse), also known as CSAM (Child Sexual Abuse Material), as well as content that’s lawful, but potentially harmful. The latter ranges from online bullying and abuse to advocacy of self-harm and spreading disinformation / misinformation.

Two Hat’s Role

Our Founder and Executive Chairman Chris Priebe, along with our Director of Trust & Safety Carlos Figueiredo, met with the officials at the UK DCMS (Department of Digital, Culture, Music and Sport), providing recommendations that have informed the final draft. DCMS officials wanted to know more about our definitions of online harms and what we viewed the role of tech to be in supporting the identification and prevention of behaviors like cyberbullying and hate speech.

Specifically, Two Hat recommended foundational best practices around community health and safety, the need for shared categorization (taxonomies) of harms, the need for an open and annual dataset to compare safety tech providers, and standardized transparency reports that could be used to give a company an A+ rating on app stores

Along with other contributors the UK responded with a £2.4m Online Harms Data Transformation Project and the first Safety Tech CogX event. Two Hat spoke at both kick-off events in our ongoing hope to increase the safety of the Internet

Holistic community health and safety approaches are key

The Bill sets out the duties of care that apply to providers (of user-to-user and search services), namely to undertake risk assessments, and also duties with regards to content on their services that is illegal, harmful to children, or harmful to adults.

Similar to creating a physical space, there is a duty to provide physical safety features, such as balcony railings and safety staff. Likewise, in the digital space there is a duty to provide safety, such as context appropriate filters, staff, reporting and record keeping. “Safety by design” is a way of thinking through all the layers of community protection prior to releasing your product.

Having holistic community health and safety approaches, tools, and processes, including a combination of tools and human experts in the operational loop, will likely be a foundational step to complying with future legislation.

Robust user reporting flows and redress

This Bill places the duty on services to have systems and processes in place that allow their users or affected persons to report content that they consider illegal or harmful to children or harmful to adults.

Systems and tools, like Two Hat’s Community Sift, allow companies to triage user reports through classification and prioritization. These are indispensable when running a scalable and sustainable review of user generated reports.

The importance of reporting capabilities and data insights

In some cases, the regulation will require companies to publish transparency reports, keep records, and provide OFCOM (UK’s Office of Communications) with information.

Critically, service providers will benefit from best-in-class reporting capabilities that indicate the health of a digital community over time, the impact their safety operations are having, and specific details around each type of online harm – e.g. the percentage of bullying in relation to the total chat a company has proactively filtered in the last year.

Comprehensive reporting capabilities and data insights will now be an even more vital part of online safety operations. Given the importance of these reporting infrastructure needs, and our feedback from community partners, Two Hat is actively investing in areas that drive better actionable insights of the health and safety of online communities.

Communicating data insights to key stakeholders (such as the c-suite, investors and users) related to the social health of the community, such as volume and type of online content, what’s improving, user happiness and user longevity, leads to improved transparency. Collectively, this has a direct line to retention and is one of the biggest bottom line contributors of growth (or exodus) of a product.

Two Hat stands in support of the Online Safety Bill

We applaud the UK Parliament in their world leadership of creating much-needed online health and safety standards. Two Hat will continue to offer consultation, best practices and guidance to governments, both domestic and abroad, related to protecting online communities.

If you are concerned about staying ahead of legislation and compliance, which may hold digital platforms and services more accountable, or are concerned with the impact of bullying, hate speech and harassment in your community, please get in touch.

Further readings

Disclaimer: The information contained on this blog, including any articles or content published, made available or referenced in it, are intended as introductory content only that should not be relied on. It is not, and should not be construed as, legal advice and should not be relied on as such. No solicitor-client or similar relationship will arise as a result of accessing or reading the information contained on this blog and we have no fiduciary duty towards you. Accordingly, we make no representations or warranties as to the accuracy, timeliness or adequacy of any information made available on this blog and we and our affiliates will have no liability to you, whether direct or indirect. You are encouraged to seek independent legal advice regarding the UK’s Draft Online Safety Bill and other subject matter of this blog, including how it relates to your own circumstances, before taking any action.

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