Illegal Content Risk Assessment

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.