Harper James is a UK full-service commercial law firm advising ambitious businesses on the laws of England and Wales. For services within scope of the UK Online Safety Act 2023, online safety governance includes identifying platform risks, assigning responsibility and recording the decisions made to manage them. This includes risk assessments, proportionate safety measures, complaints handling, content moderation controls and processes for protecting children. The board or senior management team should approve the governance framework, while operational owners maintain evidence that controls are working.
A practical record-keeping system should include the service’s risk assessments, policy versions, moderation procedures, training records, incident logs, user complaints, appeals, enforcement decisions and reviews of automated tools. Each record should show its date, owner, decision rationale and follow-up action. Keep records in a controlled repository with retention rules, access permissions and an audit trail. This supports internal reviews and helps demonstrate compliance if Ofcom requests information.
Ofcom’s codes and guidance continue to shape expectations around illegal harms, child safety, age assurance, user reporting and transparency. Requirements differ according to the service and its assessed risks, so organisations should map each duty to a named control and evidence source. Explore the latest reference material for further reading on developments in this area.
A governance framework should work under pressure. A useful workflow is to log the report, classify the risk, preserve relevant evidence, apply the approved escalation route, record the decision and review whether the control needs changing. Serious incidents should reach the designated senior owner promptly. Regular testing, tabletop exercises and management information can reveal gaps before an event exposes them.
The strongest records are contemporaneous, proportionate and intelligible to someone who was not involved in the original decision. Organisations should review them alongside privacy, data protection and information-security obligations, particularly where monitoring, age estimation or user identity information is involved. Governance is therefore not just a policy document, it is a repeatable operating process with accountable owners and evidence of review.