In the UK, Ofcom has published two economic discussion papers
targeted at building knowledge and understanding of safety
measures, sharing best practice and developing its understanding of
how it might best evaluate online safety measures under the
UK’s Online Safety Act 2023 (the Act).
For anyone subject to the measures under the Act, it makes
interesting reading and provides insights into Ofcom’s
developing thinking in relation to its approach to the evaluation
of effectiveness of measures adopted by services under the Act.
Evaluating online safety measures
The first economic discussion paper is a general paper titled Evaluating online safety measures – Ofcom (May
2024).
It sets out an evaluation framework that could be used to assess
the effectiveness of safety measures to mitigate against the risks
of online harms. It outlines a four-stage process which can be
summarised as follows:
Stage 1: Objectives and appraisal
Services should understand the purpose of the safety measure and
how it will achieve its objective.
Ofcom’s model anticipates that there will need to be
consideration of interdependencies, feedback, user experience
arising from the change, external factors and unintended
consequences in order to be effective.
The paper outlines an approach called “Theory of
Change” which provides a roadmap for evaluating the
effectiveness of safety measures over time. Any worked example
using the Theory of Change model will be more complex than the
below illustration, but it does provide useful checkpoints for
anyone creating or reviewing an evaluation framework:
The paper refers to understanding and consideration of
“unintended consequences” as being important in the
evaluation cycle. One example is that a “safety measure
may reduce risks of harm to a number of users, an unintended impact
could be greater harm for some users (e.g. due to users that seek
to bypass the safety measure and as a result end up encountering
more harmful material). Therefore, the net effect on users will
depend on the scale of both intended and unintended
effects.”
Stage 2: Identification of success metrics
Using the roadmap (likely to be more complex than the above
figure – for a worked example see Figure 3 in the paper which
is not reproduced here), the paper suggests that services should
quantitatively and qualitatively measure progress toward these
objectives using key success indicators and relevant metrics.
Indicators might include metrics like user engagement with
safety features or rates of reported harmful content. Metrics
likely fall into three categories: Process, Risk and Harm, with the
potential for an “unintended outcomes metric” in some
cases. In order to measure the metrics, the paper suggests using
the S.M.A.R.T methodology (smart, measurable, achievable, relevant
and timebound).
Stage 3: Assessing outcomes
In interpreting the metrics, the paper outlines four
methodologies (quantitative comparisons and analysis, econometric
techniques, A/B testing and behavioural techniques).
Stage 4: Evaluate and iterate
Regular analysis of collected data ensures services will be able
to assess the effectiveness of their safety measures.
As anticipated by my colleagues Lorna Cropper and Frankie
Everitt in their blog How Ofcom’s approach to Video Sharing
Platforms will inform its regulation of the Online Safety Act,
Ofcom is using real world examples of video sharing platforms to
develop an approach to effectiveness under the Act. Part 2 of the
paper contains a helpful worked example of the model in the context
of Video Sharing Platforms and parental controls.
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An evaluation of the impact of Twitch’s content
classification labelling
The second paper is a case study titled An evaluation of the impact of Twitch’s
content classification labelling – Ofcom (September 2024). The
paper examines changes made by Twitch to its content classification
labelling (CCL) in 2023.
Twitch introduced changes to its content classification
guidelines which moved from a binary mature/non-mature
classification to six CCLs (mature-rated game; sexual themes;
drugs, intoxication or excessive tobacco use; violent and graphic
depictions; significant profanity or vulgarity; and gambling). The
changes included penalties for content creators that failed to
accurately label streams, including labelling the creator’s
channel with the relevant CCL for a set period of time irrespective
of whether all streams fell within the definition for the CCL.
The findings can be summarised as follows:
content labelling accuracy by content creators increased
substantially following the CCL change;
the CCL change did not materially alter the type of content
produced by creators; and
the CCL change did not alter viewer behaviour materially.
The paper underscores the complexity of online safety and the
need for comprehensive evaluation frameworks that incorporate
various metrics and stakeholder inputs. It provides a step-by-step
approach that could be used to evaluate online safety measures and
signals that Ofcom is more likely to expect in-depth analysis
rather than “simplistic comparisons of high-level
metrics”. Finally, the case study highlights that the changes
did not substantially change what creators are developing or what
this set of viewers were watching.
What should services do with this information?
Familiarise yourself with the Act and understand where your
service may be caught by the definitions within the Act.
Once the Codes of Practice are in force, conduct the risk
assessments under the Act relevant to your service. There is likely
to be some work which could be carried out in advance of this date
and services should start the review exercise as early as possible.
The illegal harms code of practice remains in draft (it is expected
to be published by the end of the year) and the draft of the
children’s access assessments code of practice is awaited. In
the interim, the discussion papers provide examples of good
practice that services may find useful when assessing compliance
with the Act and future codes of practice. The ICO’s “Age
Appropriate Design: a code of practice for online services”
has been in force for some time and should also be considered.
Understand the potential harms associated with your platform
through risk assessments.
Develop and implement measures designed to address these risks.
This could include content moderation, reporting mechanisms and
user support systems and tools. User and other stakeholder feedback
can also be helpful in understanding the effectiveness of these
measures and facilitate continuous learning and improvement.
Data is key: robust data collection is likely to be key to
evaluating the safety of online safety measures.
Review and refresh: set regular reviews of the systems (at
least once a year and any time you make a change to the service)
which consider the efficacy of the system and improvements.
Implement a clear system of governance which ensures regular
reviews and reporting at a senior level within your
organisation.
Be prepared to respond to requests from the regulator which
seek to understand the measures that you have in place for
evaluating online safety and how you carry out such assessments and
the continual feedback loop for learning and improvement.
Together, the papers are over 100 pages long and targeted at
generating discussion from services, academics, civil society
organisations and the broader trust and safety and online safety
expert community.
With the staged approach to implementation of the Act,
evaluation of safety measures may not be top of most services’
agendas but, for those interested in looking forward to what
regulation might look like and seeking an opportunity to engage
with its development, the papers are informative reading.
For advice on how the Act may impact your business,
or for guidance on compliance and evaluation, please
contact John
Brunningand Nicola
Margiotta.
Our thanks to Lorna Cropper for her assistance in
the preparation of this blog.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.