Takedown Policy & Procedures

Compliant with the Online Safety Act 2023 (UK)

Policy Number: TKP-EIT-001
Effective Date: August 2025
Review Date: August 2026

1. Policy Statement

E IT s ("we," "us," "our") is committed to providing a safe online environment for our users. In compliance with the UK's Online Safety Act 2023 (the "Act"), we have established robust and transparent procedures for the swift and effective removal of illegal content, with particular focus on content amounting to illegal content and content that is harmful to children, as defined by the Act.

Our priority is to balance the fundamental right to freedom of expression with our legal duty to protect users from harm.

2. Scope

This policy applies to all:

• Content hosted, shared, or distributed on our services, including [e.g., user-generated content, comments, videos, images, forum posts].
• Users of our services, both within and accessing from the UK.
• Employees and contractors who are involved in content moderation or the takedown process.

3. Definitions

• Illegal Content: Content that is prohibited by UK criminal law. This includes, but is not limited to:
• Terrorism content
• Child Sexual Exploitation and Abuse (CSEA) content
• Harassment and stalking
• Hate crime
• Incitement of violence
• Sale of illegal drugs or weapons
• Revenge pornography
• Content Harmful to Children: Content that is not necessarily illegal but has a material risk of causing significant physical or psychological harm to a reasonable child. This is defined by priority categories in the Act, such as:
• Promotion of self-harm or suicide
• Bullying content
• Pornographic content accessible to children
• User: Any individual who uses or accesses our service.
• Takedown: The action of removing, disabling access to, or deleting content from our platform.
• Ofcom: The Office of Communications, the independent regulator for the Act.

4. Proactive Safety Measures & Risk Assessment

In line with the Act's "Safety by Design" principle, we:

• Conduct regular Risk Assessments to identify and mitigate the risks of users encountering illegal content and content harmful to children on our service.
• Employ proactive technology where proportionate and effective to identify and remove priority illegal content, especially CSEA and terrorist content.
• Provide clear and accessible user tools for reporting content and managing their online experience (e.g., blocking, filtering).
• Ensure our terms of service clearly outline prohibited behaviours and content.

5. Takedown Procedures
6. How to Report Content

Users can report content they believe violates this policy via email to support@eits.dev

A report should include:

• URL or precise location of the content.
• Description of the content and reason for the report.
• The user's name and contact information (for follow-up, if required).
• Date and time the content was seen.

1. Takedown Process Workflow

1. Receipt & Triage: All reports are logged and categorised based on the alleged violation (e.g., illegal, harmful to children, breach of terms).
2. Assessment: Our trained content moderation team assesses the reported content against:
• UK law (for illegal content).
• Our terms of service.
• The risk of harm to children.
3. Decision & Action:
• Urgent Illegal Content (e.g., CSEA, Terrorism): Content identified as priority illegal content will be removed immediately and reported to the relevant authorities (e.g., National Crime Agency's Child Exploitation and Online Protection command, Counter Terrorism Internet Referral Unit) as required by law.
• Other Illegal Content: Content assessed as illegal will be removed swiftly. We will consider the context to ensure decisions are consistent with freedom of expression principles.
• Content Harmful to Children: If our service is likely to be accessed by children, we will enforce our terms of service and use age assurance or restriction tools to protect children from this content, which may include takedown.
• Non-Violating Content: If the content does not violate our policy or the law, it will remain on the service. The reporter will be notified of this outcome.
4. Appeals Process:
• Users who have had content removed, or whose report was not actioned, have the right to appeal the decision.
• Appeals must be submitted within 30 days via support@eits.dev
• Appeals will be reviewed by a senior moderator or manager not involved in the original decision.
• We will provide a clear and reasoned response to the appeal within a reasonable timeframe.

6. Record Keeping & Transparency

• We maintain detailed records of all takedown reports, assessments, actions, and appeals for a minimum period as required by the Act and Ofcom. This is to ensure accountability and for regulatory reporting purposes.
• We will publish annual Transparency Reports outlining the volume and nature of takedowns, the effectiveness of our appeals process, and the steps we are taking to improve user safety.

7. Duties to Ofcom

We recognise our duties to cooperate with Ofcom. This includes:

• Providing information and data as requested by Ofcom for the purpose of their regulatory functions.
• Paying any relevant fees to Ofcom.
• Notifying Ofcom of any significant changes to our service that may impact risk.

8. Policy Review

This policy will be reviewed annually, or more frequently in response to changes in the law, Ofcom's codes of practice, or the nature of our service.

9. Contact Information

For questions about this policy, please contact:
support@eits.dev