Ofcom consultation on Online Safety - Additional Safety Measures - Which? response

Executive summary

Which? welcomes this opportunity to respond to Ofcom’s consultation on its proposed new measures which seek to build on the illegal harms and children’s safety codes of practice. Our response focuses solely on measures pertaining to the illegal harms codes of practice that are designed to tackle the fraud and financial services offences category of priority illegal harm, as defined by the Online Safety Act 2023.

While we largely support Ofcom’s proposals, there are a few areas where we would like to see the regulator go further:

• We believe that services should have to use proactive technology to scan all existing content, not just new content, for signs of fraud;
• We believe that providers should design their recommender systems to exclude fraud content from their users’ recommender feeds, as they currently have to do for other kinds of harm; and
• We believe that those found to have generated content judged to constitute a fraud or financial services offence should have their account removed and should be prevented from returning to the service on which they committed the offence.