Online Safety Policy
This policy is designed to be accessible, understandable, and easy to read without legal and other jargon. If you have any comments, questions, or concerns about this policy, please get in touch with us by emailing hello@treadl.com.
This policy will have slight changes made to it occasionally. Please refer back to it from time to time.
Important: this policy refers specifically to the version of Treadl running at treadl.com (and subdomains). We refer to this as "the service" or often simply just "Treadl", "us", "we", etc. Treadl is open-source software and can be run by anyone and be called anything. Other "instances" of "Treadl" should have their own online safety notice, policy, risk assessment, and/or any other required documentation and processes in place that are suitable to that instance.
This policy governs Treadl's responsibilities with regard to online safety for all its users and visitors of the service.
Complaints
If you would like to make a complaint about this policy, or Treadl's handling of online safety in general, please reach out to us using the email address at the top of this policy, or by filing your complaint on Treadl's dedicated complaints and reports form.
Responsible Person
In accordance with the UK Online Safety Act, we have identified that the named individual responsible for online safety duties (including the handling of reporting and complaints and management of online safety processes, including this policy) for Treadl is Will Webberley, who can be contacted using the email address at the top of this policy document.
Illegal Content Risk Assessments
Treadl will at all times maintain a valid and up-to-date Illegal Content Risk Assessment, which assesses the risk of illegal content being encountered on Treadl, Treadl being used to facilitate a related offence (under the Online Safety Act) and the determination and implementation of proportionate mitigation measures.
This assessment, where possible, will be published online such that it is publicly available for transparency purposes for our visitors and users. For more information, and to view our risk assessments, please refer to Treadl's Online Safety Portal.
This policy governs that the risk assessment will be reviewed according to the following schedule:
- At least once per year;
- If substantial changes are made to Treadl (i.e. changes that would affect a user's risk with regard to online safety);
- If any legal regulator related to online safety (e.g. Ofcom) publish updated guidance or risk profiles that need to be considered.
Upon each review, we expect the latest risk assessment to be published within one month of the new assessment being completed.
Upon each review, identified recommendations for service changes (for example, from relevant Codes of Practice) will be implemented in a timely manner and, where possible, within two months of the review. If the change impacts the risk assessment, the current active assessment will be updated to reflect the change in risk.
Upon each review, changes will be communicated throughout Treadl's governance channels to ensure awareness of practice and risk is maintained.
Moderation
Where possible, user-generated content (including text, files, and media) is to be moderated by Treadl administrators to reduce the likelihood of dissemination of such content to other visitors and users.
This includes via the following mechanisms:
- Pre-publish moderation (content "approval"): where content must be approved before it is available to other users. If not approved, it is not made available.
- Post-publish moderation (content "review"): where content must be reviewed in a timely manner (we do not define this here, but expect this to be within a few hours) once it is available to other users.
Where it is not possible, and in all cases, provide a reporting or complaints mechanism (as described in the relevant section below in this policy).
If, during the moderation process, suspected illegal content is found, a manual process is invoked to remove the content. This is achieved by removing files and updating database entries accordingly. This must be carried out immediately upon discovering such content.
If illegal content is identified, we will notify the responsible user of the content take-down and/or alert the relevant authorities, depending on the severity of the content.
When extending Treadl with new features, or updating existing ones, it is required that consideration is given to developing software such that content approval is built-in to the changing feature to ensure Treadl maintains or continuously improves its online safety features.
Individuals' Rights and Freedoms
Treadl respects the rights and freedoms of individuals using the service, which includes an individual's right to expression. In the handling of complaints and moderation, we will be diligent in considering these rights.
Once judgment has been made, we will make the appropriate action. Complaints or appeals about this action can subsequently be made via Treadl's reporting and complaints process (see below).
Reporting and Complaints
Treadl must, at all times, maintain a robust, transparent, easy-to-use, and available reporting and complaints procedure for at least the following use cases:
- Complaining about Treadl's online safety processes and practices (including this policy and risk assessments);
- Reporting user-generated content that is illegal (or, in some cases, purely offensive);
- Reporting cases where Treadl is being used to facilitate or commit a legal offence (particularly those related to online safety);
- Complaining about decisions taken by Treadl with relation to user-generated content or the handling of other reports or complaints (for example, perceived unfair treatment);
- Appeals to complaints made about user-generated content or to any other reports or complaints made.
Treadl facilitates reports and complaints via a form available to all visitors and users on its website.
The report and complaints process (and its form) is available to both registered users and visitors and it must be prominently displayed and accessible from anywhere on the service where user-generated content might appear.
Submissions to this form immediately notify Treadl admins via email, who will then take appropriate action accordingly at a high priority (within a 3 work hours UK time). Actions taken, or not taken, as a result of complaints may be communicated back to the complainer/reporter, as described in this policy.
If the complaint is an appeal for which a decision related to content or user removal is reversed, the admins will allow the user to re-register and re-add the content in its original form and the complainer will be notified. Treadl will not be able to automatically reinstate content or users that have been deleted as the result of a suspected illegal content takedown. If it becomes apparent that a disproportionate number of takedown decisions are reversed, changes will be made to the original decision process to ensure that these are more accurate in future.
If the complaint is related to the approval or moderation process too aggressively removing or de-prioritising content, we will review this against the Terms of Use and illegal content guidelines to determine if the original decision in the approval/moderation needs to be reversed. If so, the complainer will be notified and alerted to any other available actions.
If the complaint is not an appeal, but is determined to be manifestly unfound, the complaint will not be dealt with. Treadl may or may not notify the complainer. For example, complaints are unfound if they do not refer to illegal content, or do not refer to content that is contravention of forbidden content (as described in our Terms of Use). This policy will be reviewed annually to ensure that legitimate complaints are not being identified as unfound.
All complaints, appeals, and reports (no matter the cause or reason) will be dealt with in a reasonable time-frame, and usually within one working day. Higher-priority complaints (e.g. those related to suspected illegal content) will be dealt with within a few working UK hours.
All complaints, appeals, and reports (even if unfound) will be recorded in a register, alongside actions taken and justifications. This will be used to help in reviewing this policy.
Generally, whilst respecting user freedom of expression to appropriate points, Treadl will be the sole decider when it comes to handling content and user take downs, complaints, and appeals.
Treadl will make sure to regularly test the reports and complaints process to ensure continuous availability.
Proscribed Organisations
Users and content from or related to proscribed organisations (organisations banned under the UK Terrorism Act) is forbidden, and will be removed if encountered or a relevant complaint is made. For example, this could be a username, link to a proscribed organisation website, imagery, or other content uploaded as part of a user profile or project.
User and Visitor Responsibilities
Individuals visiting or using Treadl ("users") have both community (e.g. related to service "terms of use") and legal responsibilities related to online safety. In particular:
- Users must not use Treadl to facilitate or commit any legal offences (under UK law) and -- specifically with regard to this policy -- offences related to illegal content or harms related to the Online Safety Act.
- Users must not use Treadl to upload, create or otherwise store, process, or disseminate any form of illegal content as described in the UK Online Safety Act.
- Users must not use Treadl in any way that brings harm to any other user or to the service itself.
- Using the dedicated reports and complaints process, users must report any occurrences of (or suspicions of) illegal content encountered on Treadl, or cases where it is suspected that Treadl is being used to facilitate or commit a legal offence.