Compliance Document
Illegal Content Risk Assessment
1. Purpose and Legal Basis
This Illegal Content Risk Assessment (“ICRA”) is prepared pursuant to sections 9–10 of the Online Safety Act 2023 (“OSA”) and Ofcom's Illegal Content Risk Assessment Guidance for small and medium services (published January 2025). The purpose of this assessment is to identify, assess, and document the risk of priority and non-priority illegal content appearing on or being distributed through the Discreet Liaisons platform, and to document the mitigations in place.
The risk assessment covers the categories of “priority illegal content” as defined in Schedule 7 of the OSA, together with other illegal content relevant to a user-to-user adult dating platform.
2. Risk Assessment Methodology
Each risk category is assessed using a two-dimensional matrix:
- Likelihood: How likely is it that this type of illegal content will appear on the platform? (1 = Very Low, 2 = Low, 3 = Medium, 4 = High)
- Impact: What would be the harm to users or society if this content appeared? (1 = Minimal, 2 = Moderate, 3 = Serious, 4 = Severe)
- Residual risk (post-mitigation): Likelihood × Impact, interpreted as: 1–4 = Low, 5–9 = Medium, 10–16 = High
3. Service Context
Discreet Liaisons has the following risk-relevant characteristics:
- Adults-only platform with mandatory age declaration at registration;
- All content is behind a registration wall — no public content;
- Profile photographs are reviewed by a human moderator before display;
- Nudity and sexually explicit content are expressly prohibited and enforced;
- Users can report profiles and messages via an in-platform reporting mechanism;
- No social media login — reduces risk of fake account creation at scale;
- A paid subscription requirement for male members acts as a deterrent to throwaway accounts;
- No file-sharing beyond photographs — no video, no document uploads;
- Private messaging is not pre-moderated but is reportable;
- Small user base — reduces scale of potential harm;
- UK-based operator and user base.
4. Risk Category Assessments
4.1 Child Sexual Abuse Material (CSAM) and Child Sexual Exploitation
Relevant legislation: Protection of Children Act 1978; Sexual Offences Act 2003; Online Safety Act 2023 (Priority Illegal Content — Schedule 7)
Assessment: The platform's subject matter (adult discreet dating), mandatory age verification, registration wall, and prohibition on all sexually explicit content significantly reduce the likelihood of CSAM being uploaded or shared. The platform does not permit video uploads or document sharing. Human moderation of all photographs provides an additional safeguard. All private messaging is reportable.
Mitigations in place:
- Human moderation of all photographs before display — no photo visible until approved;
- Explicit prohibition on any content involving minors in Terms & Conditions;
- Mandatory rejection of any image depicting nudity or explicit content;
- User reporting mechanism on all profiles and accessible via safety contact;
- Mandatory age declaration at registration (18+);
- Accounts suspected of involving minors are suspended immediately;
- Any CSAM identified will be reported immediately to the Internet Watch Foundation (IWF) and the National Crime Agency (NCA), and to Ofcom as required under s.66 OSA.
4.2 Sexual Grooming and Child Sexual Exploitation
Relevant legislation: Sexual Offences Act 2003 (s.15, 15A); Online Safety Act 2023 (Priority Illegal Content)
Assessment: The registration wall and mandatory 18+ age declaration means no child can legitimately access the platform. The absence of public profiles and content removes the attack surface available for grooming approaches directed at children browsing the open web. Adult-to-adult communication is private and reportable.
Mitigations in place:
- Children's Access Assessment concluded children are unlikely to access the service;
- Registration wall — no content accessible to non-members;
- User reporting for any communication that appears to target or involve minors;
- Immediate account suspension on any indication of a minor's presence;
- T&Cs expressly prohibit grooming or exploitation of any person.
4.3 Human Trafficking and Sexual Exploitation of Adults
Relevant legislation: Modern Slavery Act 2015; Sexual Offences Act 2003; Online Safety Act 2023 (Priority Illegal Content)
Assessment: The platform expressly prohibits advertising of commercial sexual services. Human trafficking typically involves the advertising or solicitation of paid sexual services, which is prohibited by the platform's T&Cs and would be actioned on report. The small scale of the platform and the payment barrier for male members reduce the commercial viability of using the platform for exploitation purposes compared with free, large-scale social networks.
Mitigations in place:
- T&Cs expressly prohibit advertising or promoting escort, sex worker, or paid sexual services;
- T&Cs prohibit human trafficking and modern slavery;
- User reporting mechanism available for any suspicious profiles or solicitation;
- Any profile identified as advertising commercial sexual services will be suspended immediately and, where trafficking is suspected, reported to the NCA;
- Photo moderation detects and rejects overt commercial sexual solicitation imagery.
4.4 Fraud and Romance Fraud
Relevant legislation: Fraud Act 2006; Online Safety Act 2023 (Priority Illegal Content — fraud offences)
Assessment: Romance fraud is a recognised risk on all adult dating platforms. The risk is elevated on discreet/affairs-focused platforms because victims may be less likely to report concerns to third parties due to embarrassment. The platform's human photo moderation reduces catfishing risk. The paid subscription barrier for male members deters throwaway fraudulent accounts to some degree.
Mitigations in place:
- T&Cs expressly prohibit impersonation, financial solicitation, phishing, and romance fraud;
- User reporting mechanism available; reports of financial solicitation are treated as high priority;
- Safety guidance provided to users (never send money, never share financial information);
- Human photo moderation detects stock or stolen photographs commonly used by fraudsters;
- Accounts identified as engaged in fraud will be suspended immediately and, where appropriate, reported to Action Fraud and the NCA;
- Ongoing monitoring of report patterns to identify coordinated fraud activity.
Note: This risk category is assessed as Medium residual risk and is subject to enhanced monitoring and a commitment to implement stronger detection measures if the volume of reports increases.
4.5 Harassment, Stalking, and Threatening Communications
Relevant legislation: Protection from Harassment Act 1997; Malicious Communications Act 1988; Online Safety Act 2023 (s.181 — cyberflashing; intimate image abuse)
Assessment: Harassment between users is a risk inherent to all social and dating platforms. The private messaging model means harassment occurs in one-to-one contexts that are not pre-moderated. However, the platform provides robust reporting mechanisms and the ability to block users. The discreet nature of the platform provides some natural disincentive to harassment (users do not wish to expose their own presence on the platform).
Mitigations in place:
- T&Cs expressly prohibit harassment, stalking, threatening communications, and cyberflashing;
- Users can block other users, preventing all further contact;
- User reporting mechanism on all profiles; harassment reports reviewed within 72 hours;
- Immediate account suspension for confirmed harassment;
- Non-consensual sharing of intimate images is treated as a priority report and escalated immediately;
- Where harassment constitutes a criminal offence, reports may be passed to the police.
4.6 Hate Crime and Incitement to Hatred
Relevant legislation: Public Order Act 1986 (Part III); Crime and Disorder Act 1998; Online Safety Act 2023 (Priority Illegal Content)
Assessment: The platform's private, one-to-one messaging model and niche subject matter mean it is unlikely to be used for the broadcast of hate speech or incitement to hatred. There is no public forum, no comment section, and no group messaging. The risk of coordinated hate content is considered very low.
Mitigations in place:
- T&Cs prohibit hate speech and content targeting protected characteristics;
- User reporting mechanism available;
- Account suspension for confirmed hate speech.
5. Summary Risk Table
| Risk Category | Inherent Likelihood | Impact | Residual Risk |
|---|---|---|---|
| CSAM / Child Sexual Exploitation | Low (2) | Severe (4) | Low |
| Grooming / Child Sexual Exploitation | Low (2) | Severe (4) | Low |
| Human Trafficking / Sexual Exploitation | Low (2) | Severe (4) | Low |
| Fraud / Romance Fraud | Medium (3) | Serious (3) | Medium |
| Harassment / Threatening Communications | Medium (3) | Serious (3) | Medium |
| Hate Crime / Incitement | Very Low (1) | Serious (3) | Low |
6. Overall Risk Conclusion
The overall illegal content risk profile of Discreet Liaisons is assessed as Low to Medium. The most serious risk categories (CSAM, grooming, trafficking) are rated Low residual risk due to the platform's structural safeguards (registration wall, age declaration, human photo moderation, no public content). Two categories — romance fraud and harassment — are rated Medium residual risk, and these will be subject to enhanced monitoring.
The operator commits to reviewing this assessment annually (next review: 14 February 2027) or following any material change to the platform, user base, or legal framework.
Document version: 1.0 • Date: 14 February 2026 • Review due: 14 February 2027
Prepared under s.9–10 Online Safety Act 2023 and Ofcom's Illegal Content Risk Assessment Guidance (January 2025).