Internal Compliance Document
This Content Moderation and Complaints Procedure (“Procedure”) documents how Discreet Liaisons identifies, reviews, and acts upon content and behaviour that breaches our Terms & Conditions or is otherwise illegal or harmful. It is prepared in accordance with the Online Safety Act 2023 (“OSA”) and Ofcom's guidance for user-to-user services.
This Procedure is available to Ofcom on request as evidence of the platform's compliance with its content moderation and complaints obligations under Part 3 of the OSA.
Discreet Liaisons operates a hybrid moderation model:
All photographs submitted to the platform are reviewed by a human moderator via the platform's administration interface before they are made visible to any other member. A photograph will only be approved and displayed if it meets all of the following criteria:
Photographs that do not meet these criteria are rejected and the account holder is notified. Repeated non-compliant submissions result in account suspension.
Approved photographs are stored in encrypted cloud storage (Amazon S3). Images are served via temporary signed URLs with short expiry periods, ensuring photographs are not permanently accessible via direct links.
Private messages between members are not pre-moderated. Messages are reviewed reactively when a report is received. The platform's design ensures users can report any message or any member profile at any time. Users can also block any other member, which immediately prevents all further contact from that member.
Where reports indicate illegal content within messages (including suspected CSAM, fraud, or harassment), the platform operator will take immediate action including preservation of relevant records and notification to appropriate authorities.
Profile text fields (name, bio, preferences) are reviewed during the photograph moderation process and on receipt of a report. Profile content that breaches the Terms & Conditions (including contact information, commercial solicitation, or abusive content) will be removed and the account holder notified.
The platform provides a built-in reporting mechanism accessible from every member's profile page. Reports can also be submitted by email to safety@discreetliaisons.co.uk.
When a user submits a report, they are asked to select a reason:
All reports are logged in the platform's admin dashboard with a timestamp, the reporting user's ID, the reported user's ID, and the reason selected. Reports are visible to the platform administrator via the moderation interface.
On receipt of a report, the platform operator performs an initial triage within the following timeframes:
| Report Category | Initial Triage | Resolution Target |
|---|---|---|
| CSAM / child safety | Immediate (within 1 hour) | Immediate suspension + law enforcement referral within 24 hours |
| Trafficking / exploitation | Within 4 hours | Within 24 hours; NCA referral if credible |
| Threats / violent content | Within 8 hours | Within 24 hours |
| Fraud / financial solicitation | Within 24 hours | Within 48 hours |
| Harassment | Within 24 hours | Within 72 hours |
| Fake profile / fraud | Within 48 hours | Within 72 hours |
| Other / general | Within 72 hours | Within 5 working days |
The reviewing moderator will:
The following actions may be taken following a content review:
| Action | Applicable Circumstances |
|---|---|
| No action / dismiss | Report is unsubstantiated or amounts to a false or malicious report |
| Content removal | Specific content (photograph, profile text) breaches T&Cs but the account otherwise appears legitimate |
| Formal warning | Minor breach, first offence; account holder is notified of the breach |
| Temporary suspension | Repeated minor breaches or a moderate single breach |
| Permanent ban | Serious breach of T&Cs, including illegal content, repeated harassment, fraud, or impersonation |
| Law enforcement referral | Any suspected criminal conduct including CSAM, trafficking, fraud, or serious harassment |
| IWF referral | Any identified or suspected CSAM |
| Reporting user notified | Where the report resulted in action, the reporting user is informed (without disclosing specific action taken) |
The following escalation path applies:
Users whose accounts are suspended or whose content is removed may appeal the decision by contacting safety@discreetliaisons.co.uk within 14 days of the action. The appeal will be reviewed by the platform operator (a person not involved in the original decision, where possible). A decision on appeal will be communicated within 10 working days.
Permanent bans issued following identification of CSAM or other serious illegal content are not subject to appeal.
The following records are maintained:
| Record Type | Retention Period |
|---|---|
| All user reports (log of report, reporter, reported user, outcome) | 3 years |
| Moderation decisions and rationale | 3 years |
| Suspended and banned account records | 5 years (to prevent re-registration) |
| Law enforcement / IWF referrals | 6 years or as directed by the relevant authority |
| This Procedure document and all compliance assessments | 3 years from supersession |
| User appeals and outcomes | 3 years |
Records are stored securely on the platform's encrypted infrastructure. Where records relate to criminal investigations, they will be preserved in accordance with instructions from the relevant law enforcement body.
This Procedure will be reviewed annually (next review: 14 February 2027) or whenever there is a material change to the platform, user base, or regulatory framework. A summary of moderation activity (total reports received, actions taken, referrals made) will be recorded annually as part of the platform's OSA compliance record.
This document is available to Ofcom on request. A summary of the platform's safety approach is available publicly at our Online Safety page.
Document version: 1.0 • Date: 14 February 2026 • Review due: 14 February 2027
Prepared for compliance with the Online Safety Act 2023 and Ofcom's guidance for user-to-user services.