Codes of practice and recommended measures

The following are functionalities you almost certainly need to add into your game/service. These are all important to Ofcom and the Online Safety Act, and cannot be overlooked or deferred. They need to be considered and implemented where appropriate.

I have broken down the list of codes to those specific to games, but for all details, please refer to: Protection of Children Code of Practice for user-to-user services.

Governance and accountability of your service

• PCU A2 - Individual accountable for the safety duties protecting children and reporting and complaints duties,
• PCU A3 - Written statements of responsibilities,
• PCU A5 - Tracking evidence of new and increasing harm to children,
• PCU A6 - Code of conduct regarding protection of children from harmful content,
• PCU A7 - Compliance training.

Age assurance (highly effective age assurance)

• PCU B5 - Priority content is prohibited on the service, but it is not technically feasible to take down all such content when the provider determines it to be in breach of its terms of service. This covers bullying, abuse and hate, and violent content (toxic messages from users).
• Potentially, PCU B4 - which is the same as above but in relation to Primary Priority Content (specifically suicide or self-harm). For games with a higher proportion of serious toxicity, this might be more appropriate.

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Regardless of B5 or B4:

At either rate, you will need to implement highly effective age assurance to gate user access to the relevant functionalities (user communication) until HEAA has been completed. More on this specifically in the following section.

Content moderation

• PCU C1 - Having a content moderation function to review and assess suspected content that is harmful to children,
• PCU C2 - Having a content moderation function that allows for swift action against content harmful to children,
• PCU C3 - Setting internal content policies,
• PCU C4 - Performance targets,
• PCU C5 - Prioritisation,
• PCU C6 - Resourcing
• PCU C7 - Provision of training and materials to individuals working in content moderation (non-volunteers),
• PCU C8 - Provision of materials to volunteers.

Reporting and complaints

• PCU D1 - Enabling complaints,
• PCU D2 - Having easy to find, easy to access, and easy to use complaints systems and processes,
• PCU D3 - Provision of information prior to the submission of a complaint,
• PCU D4 - Appropriate action-sending indicative timeframes,
• PCU D5 - Appropriate action-sending further information about how the complaint will be handled,
• PCU D6 - Opt-out from communications following a complaint,
• PCU D7 - Appropriate action for relevant complaints about content considered harmful to children,
• PCU D8 - Appropriate action for content appeals-determination,
• PCU D10 - Appropriate action for content appeals-action following determination,
• PCU D11 - Appropriate action for age assessment appeals
• PCU D13 - Appropriate action for complaints about non-compliance with certain duties
• PCU D14 - Exception: Manifestly unfounded complaints.

Settings, functionalities, and user support

• PCU F1 - Providing age-appropriate user support materials for children,
• PCU F3 - Signposting children to support when they report harmful content,

User controls

• PCU J1 - User blocking and muting, only where your game has more than 700,000 monthly active United Kingdom users,
• PCU J3 - Invitations to group chats, where the service has group messaging functionality.

Terms of service

• PCU G1 - Terms of service: Substance (all services),
• PCU G3 - Terms of service: Clarity and accessibility.

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Summary - Codes of Practice and Recommended Measures

There’s a lot you have to do here, and it’s as simple as “do it”:

From having a designated and named member of staff responsible for protecting children, reporting, and complaints duties, to a whole host of functionality that you just have to have in place.

The good news is that Ofcom have made it very clear as to what you have to do. The bad news is, there’s a lot.