Compliance Document
Children's Access Assessment
1. Legal Basis and Purpose
This Children's Access Assessment (“CAA”) is prepared pursuant to section 11 of the Online Safety Act 2023 (“OSA”) and in accordance with Ofcom's Guidance for small and medium user-to-user services (published January 2025). The purpose of this assessment is to determine whether it is likely that children (persons under the age of 18) will access the Discreet Liaisons service.
The conclusions of this assessment determine the level of additional child safety duties that apply to the service under the OSA. If the assessment concludes that children are NOT likely to access the service, the provider is not required to comply with the enhanced child safety duties set out in sections 11–15 of the OSA.
2. Service Description
Discreet Liaisons is a user-to-user adult dating and social connection platform operated in the United Kingdom. The service enables registered adult members to create profiles, upload photographs (subject to human moderation), and communicate privately with other members. The service has the following characteristics:
- Strictly adults-only (18+), with age declaration required at registration;
- Registration required — no content is accessible to non-members;
- Profile photographs are moderated by a human before being displayed;
- Nudity and sexually explicit content are expressly prohibited;
- A built-in user reporting mechanism is available on all member profiles;
- No social media login (no Facebook, Google, or similar sign-in);
- A paid subscription is required for male members to access full messaging features;
- SSL-encrypted infrastructure; anonymous billing descriptor;
- No third-party advertising;
- Content is not indexed by search engines; it is fully behind a registration wall;
- The service is operated by a small, independent UK operator.
3. Methodology
This assessment applies the five-factor framework recommended by Ofcom in its January 2025 guidance for assessing the likelihood of children accessing a service:
- The subject matter of the service;
- The nature and purpose of the service;
- How the service is presented to users and potential users;
- The functionalities and features of the service;
- The existing steps the provider has taken (or is proposing to take) to confirm users' ages or otherwise restrict children's access.
4. Factor Analysis
4.1 Subject Matter
The service concerns adult romantic and sexual connections between adults, including discreet affairs and private dating. The subject matter is inherently adult in nature and is explicitly and conspicuously targeted at adults only. The service addresses concepts such as marital affairs, discreet dating, and adult sexual autonomy that are entirely outside the sphere of interest or understanding of children.
Assessment: Strongly indicates children are unlikely to access the service.
4.2 Nature and Purpose
The purpose of the service is explicitly to facilitate private adult romantic and sexual connections. The platform's name, branding, and all marketing content make it unambiguously clear that the service is for adults only. There are no features — gaming, social interaction, entertainment, or general social networking — that might attract children. The platform is a niche, purpose-built adult service.
Assessment: Strongly indicates children are unlikely to access the service.
4.3 Presentation and Discoverability
The service's public-facing pages (including landing pages and SEO content) are clearly targeted at adults seeking discreet dating. The domain name and all marketing material reference adult relationship concepts. The service does not appear in app stores (no mobile application) and is not marketed through channels that reach children (no social media advertising, no youth-oriented platforms). Content is not visible to unauthenticated visitors.
Assessment: Indicates children are unlikely to access or be directed to the service.
4.4 Functionality and Features
The service offers no features of general appeal to children: there is no gaming, no video streaming, no social news feed, no group chats, no public content, and no way to interact with content without an authenticated adult account. The user interface is designed for adults (desktop-first, formal registration process, subscription payment required for male members). There is no content visible to non-registered visitors. The registration process requires a date of birth and an explicit declaration of adult age.
Assessment: Strongly indicates children are unlikely to access the service.
4.5 Age Restriction Measures
The following measures are in place to restrict access to adults only:
| Measure | Implementation |
|---|---|
| Age declaration at registration | Date of birth field is mandatory; accounts with a date of birth indicating age below 18 are rejected by the system |
| Terms acceptance at registration | Users must explicitly check a box confirming they are 18+ and accept the Terms & Conditions |
| Registration wall | All platform content is inaccessible to unauthenticated visitors; zero public-facing content |
| No social sign-in | No Facebook, Google, or equivalent login eliminates the risk of accidental registration via a parent's authenticated session |
| Payment barrier (male members) | Full access for male members requires a payment card subscription, providing an additional indirect age indicator |
| Email verification | Registration requires a valid, unique email address |
| Account suspension | Accounts where we have reasonable grounds to believe the user is under 18 are suspended immediately without refund |
Assessment: Comprehensive proportionate measures consistent with Ofcom's guidance for a service of this type and scale.
5. Conclusion
Assessment Outcome: Children are NOT LIKELY to access the service.
Having assessed all five factors required by Ofcom's guidance and the Online Safety Act 2023, the operator of Discreet Liaisons concludes that children are not likely to access the service. This conclusion is supported by: (1) the explicitly adult subject matter and purpose of the service; (2) the absence of any features of appeal to children; (3) the robust registration barrier including mandatory age declaration, Terms acceptance, and email verification; (4) the payment barrier for full feature access; and (5) the absence of publicly accessible content.
In accordance with section 11(4) of the OSA, this conclusion means that the enhanced child safety duties under Part 3 of the OSA do not apply to this service at this time. This assessment will be reviewed annually or whenever there is a material change to the service, the user base, or the legal/regulatory framework.
6. Ongoing Monitoring
Notwithstanding the above conclusion, the platform operator commits to:
- Reviewing this assessment annually (next review: 14 February 2027) or on any material change to the service;
- Acting immediately on any report or indication that a user may be under 18;
- Keeping records of this assessment and any subsequent reviews for a minimum of 3 years;
- Monitoring Ofcom guidance for updates to the Children's Access Assessment methodology.
Document version: 1.0 • Date: 14 February 2026 • Review due: 14 February 2027
Prepared under s.11 Online Safety Act 2023 and Ofcom's Children's Access Assessment Guidance (January 2025).