IWF URL List Policy and Procedures

Assessment and listing of child sexual abuse URLs

Policy framework

Decisions regarding the listing or non-listing of URLs containing potentially criminal child sexual abuse content will be made consistent with the following policy statements:
  1. The decision-making authority for determining whether a URL containing potentially criminal child sexual abuse content should not be added to the IWF URL List of child sexual abuse content or whether such a URL should be removed from the IWF URL List lies with the Board of the IWF.
  2. The Board will take actions consistent with the public interest.
  3. Due regard will always be given to the potential public harm if the image(s) were to enter the public arena.
  4. All decisions will be informed by the IWF’s remit requirement of minimising the availability of potentially criminal images of child sexual abuse hosted anywhere in the world.
  5. The IWF will not knowingly leave service providers vulnerable by having potentially criminal images on their systems.
  6. The principle of removal of content at source, consistent with INHOPE principles, is supported.
  7. Action will be taken by the IWF in relation to all reports which contain potentially criminal child sexual abuse content but that action will not include in all cases the inclusion of the relevant URL on the IWF URL List provided by the IWF if a risk is likely to be triggered.
  8. Wherever possible URLs added to the IWF URL List will lead to the blocking of images and not text.
  9. The IWF will be transparent about its assessment processes and procedures.

Image assessment

  1. All reported URLs are assessed according to UK law, with each image being categorised in line with criteria set out by the UK Sentencing Guidelines Council.
  2. Only those images assessed to be at level 1 or above (as described by the UK Sentencing Guidelines Council) are considered for inclusion on the IWF URL List and are subject to the process described from section 3 onwards.
  3. Consideration will be given to the following elements when an assessment of an image is being undertaken:
    4. a. Previously unseen images.
    b. History and how widely the image is disseminated.
    c. Nature of the image.
    d. Nature of the website featuring the image.
    e. Number of images associated with the URL.
    f. Jurisdictional legal disparity.
  4. Consideration will also be given to the following risks potentially associated with adding a URL to the IWF URL List i.e.
    a. Creation of significant problems for internet users.
    b. Creation of significant problems for list licensees.
    c. Likelihood of listing leading to increased availability of the image.
    d. Impact on the reputation of website owner and consequential impact on the IWF and its Members.
  5. The IWF will liaise as necessary with relevant members, licensees or other parties when carrying out the above considerations.
  6. In instances when the consideration of the factors listed in 3 above indicates that content is potentially removable, action will be taken to seek the removal at source of that content. This action will be accompanied in most circumstances by the URL's temporary inclusion on the IWF URL List until the content is removed. If the content is not removed, the URL will remain listed. When the URL’s inclusion on the IWF URL List would be known to trigger one or more of the risks identified in 4 above, the URL is not added to the IWF URL List whilst actions are taken to seek the removal of source of that content. If the content is not removed, the matter will be referred to a Board committee. (A maximum of 10 days would be allowed to enable content to be removed.)
  7. In instances when the consideration of the factors listed in 3 above indicates that content is not potentially removable, the URL will be added to the IWF URL List unless to do so would be known to trigger one or more of the risks identified in 4 above. If a risk is triggered, the matter would be referred to a Board committee.

Referral to a Board Committee

The following matters will be referred to a committee of the Board:
  1. URLs which cannot be removed at source but their inclusion on the URL List would be known to trigger an identified risk
  2. The permanent removal from the IWF URL List of a URL which had triggered an identified risk by its inclusion on the IWF URL List.
The matter would be referred to a committee of the Board, and not the whole Board to avoid a delay to the assessment process. The committee would:
  1. Be expected to meet within 3 working days of a matter being referred from the Executive.
  2. Be held in person or by teleconference.
  3. Would normally be comprised of the Board Chair and two Vice-Chairs but if they are not available would be comprised of any three Board members so long as the ration of 2:1 was retained in relation to independent:industry membership.
  4. Have decision-making powers and would inform all Board members of the decision taken.
  5. Decide if the URL(s) referred should be added/removed from the IWF URL List and recommend any other actions to be taken. Such an action may include, but would not be limited to, advising the licensees of the URL not listed and the reason for not listing it.
The Committee would receive a full report from the Executive on the findings of their assessment process and assessment of risks to inform their decision-making. In developing their report, the IWF would liaise, as necessary, with relevant members/licensees/affected parties. The committee would then make its decision based on:
  1. Policy framework statements.
  2. Assessment findings (The level of the image may be used to inform the decision).
  3. Anticipated or actual impact of the risk being triggered.
  4. (Where relevant) the likelihood of the risk being triggered.
  5. The level of the image would not affect the decision if the risk triggered was the likelihood of listing leading to increased availability of the image. In all other instances, the level of the image would be used to inform the decision.
Specifically, in relation to risks, the committee would consider if:
  1. The likelihood of increased availability of the image was greater than 50%.
  2. The extent of the problem for internet users in terms of the numbers of users and the extent of loss of websites/internet functionality to them.
  3. The nature and extent of the technical problems listing would create for licensees.
  4. The impact on the reputation of website owners of other legitimate affected parties.

Reporting outcome

  1. The Board will be advised.
  2. Affected and other relevant parties will be advised as appropriate.
  3. Consideration will be given to publishing a statement on the IWF website announcing the decision.

How to appeal against content assessment by the IWF

To appeal against an assessment leading to a notice to remove content or the inclusion of a webpage on the IWF child sexual abuse content block list please go to the Content Assessment Appeal Process.

How to make a general complaint about the IWF’s service delivery

If you wish to complain about the IWF’s service delivery including the behaviour of members of staff please see the General Complaints Process.
 
Co-funded by the European Union Safer Internet Thinkuknow INHOPE UK Council for Child Internet Safety