UK Online Safety Act

General IF Community Resources
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With the advent of the UK Online Safety Act, all games on the IF Archive are currently unavailable to users whose connections place them in the UK. This restriction is temporary as we review the IF Archive’s holdings and flag works that are legally required to be restricted. Our apologies!

…That’s the announcement that went out Monday. In the middle of the forum outage, unfortunately. Two unrelated volunteer crises at the same time, that’s what we like to see! Argh.

Here’s the details:

We received this advice from our lawyer on Monday and it said “do this now”. So we got to work.

The restriction applies to the following directories (including subdirectories):

https://ifarchive.org/if-archive/games/
https://ifarchive.org/if-archive/collections/
https://ifarchive.org/if-archive/rec.arts.int-fiction/
https://ifarchive.org/if-archive/rec.games.int-fiction/
https://ifarchive.org/if-archive/unprocessed/
https://unbox.ifarchive.org/

Note that the index pages are not restricted. You can visit https://ifarchive.org/indexes/if-archive/games/, for example, but (if you’re in the UK) clicking on any game will show an error page.

I used Cloudflare’s geolocation feature (and Cloudflare access rules) to set this up.

We are not legally permitted to recommend ways around this restriction. Yes, the UK’s guidance actually says that.

Our next step is for our volunteers to go through our entire game list and tag games which the UK regulations restrict. Once that’s done, we can lift the directory block and replace it with a tag-based block. However, before we start that process, we need to talk to the lawyer some more.

The step after that is to look into age verification services which satisfy the UK law. Yes, these services are intrusive and imperfect. I figure it’s better to make that choice available for users who are willing to try them.

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To ask the obvious question: does this affect IFDB, IFComp, IFWiki, or this forum? Maybe! We need to talk to the lawyer some more! We are figuring this mess out as fast as we can.

Another note: you’ve probably seen that Itch.IO has placed a similar restriction on UK users. Remember that this is a completely separate problem from the “payment processors” discussed in this thread. IFTF uses Paypal, but we do not sell games so we are not subject to Paypal’s limitations on what merchants can sell. IFTF does offer its web services to UK users, so we are subject to UK regulations.

(Itch is subject to both, so it has implemented two separate limitation policies.)

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Posting from the UK, thanks very much for posting this statement and explanation. None of this is your fault and I don’t envy any of you (or itch) having to navigate this. I have a lot more to say about the Online Safety Act but I think it would be against both the Terms of Service and the law.

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Well I’ve heard that per your Technology Secretary, if you criticize this law you’re on the side of child predators…

(These f’ing people. I often find it annoying when people roll their eyes and say “notionally left-leaning government!” in a sarcastic tone of voice, but what else is there to do here but roll one’s eyes and say “notionally left-leaning government!” in a sarcastic tone of voice?)

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Thanks Andrew / @zarf. It was good to talk to you by email.

To the community: Going forward, I’m going to be primarily hosting my games on sites or platforms that don’t currently require ID- or image-based age checks.

That means:

(1) I’ve delisted my games from Itch io.

(2) I asked IF Archive to delist my games but allowed them to overrule me. I’ve agreed to allow IF Archive to continue hosting my games since I recognize its importance as an archive.

(3) I’ll monitor the situation with other IF sites.

This might have little impact. I expect my games won’t be tagged as restricted, I don’t have a high volume of players, and I’m not in the UK. And if my games are flagged as restricted, some sites might restrict sharing external links as well.

But at a minimum, hopefully you’ll be able to find my work through Google or another search engine as the primary means of access.

I have more to say, but that’s enough for one post.

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I thought using “But think of the children!” to defend misguided or outright malevolent legislation was a stereotype of the right. Note, I have no information of this bill beyond this thread and its mention in the Itch.io thread, but I get the impression its a classic example of let’s make life harder for everyone on the slim chance we catch some bad actors that’ll probably do very little to actually catch bad actors.

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It’s a stereotype, but not an inaccurate one—or a recent one, unfortunately. The United States is the most famous for it, but “we need the government to outlaw things we don’t like in order to protect our children” goes back to ancient Greece if not earlier. (Think about Socrates being accused of “corrupting the youth” with his philosophy and sentenced to death after he made too many enemies in high places.)

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Just because I’ve seen too much of the “left-wing nanny state” narrative already, I should point out that this law was passed in 2023 under the Conservative government.

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Yeah, that is an entirely helpful fact to re-up! Sure seems like in this as in so much else, Labour is pretty happy to keep moving those Tory policies ahead though…

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On a completely unrelated subject, didn’t the archive have a list of mirrors on its front page before? Or am I misremembering things?
Now certainly feels like an opportune moment to (re-?) add such a list.

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Further to PBP’s post, I am warming more toward the IFArchive. But it depends on whether that will wind up the same. Personally i think the IFArchive (and others) should resist this law.

So, of course, I’m all for making the internet safer. But this law does no such thing. Anyone can circumvent any blocking by … Not sure if i am allowed to say. That’s how bad things are. Are things really this bad? Where is free speech?

So it appears everyone (and their dog) are frantically scrambling to comply with a whole host of regulation at their own expense!! If these foreign governments want you to do something, why aren’t they prepared to bear the costs of it?

That there is the contentious issue for me. Foreign Jonny says he’s now your boss, tells you what you must do, but you have to pay for it!

No thank you. I would instead take a practical line;

Without refusing to comply, i would simply be reactive instead of proactive. As i understand it, the law comes with a duty to install a reporting mechanism. I’m sure such a thing is already present. To flag things etc. I would instead, react to things flagged and not waste time vetting everything. And just get on as usual.

Today, because I was bored, i took a look at the actual legislation;

Here is definition of the infamous Illegal Content. Looks like AI garbage to me. I really wonder if it is.

I don’t think anyone knows what this law really implies. Even lawyers. It’ll just be, “Good evening and expenses. Yeah, you have to comply.” The path of least resistance. What lawyer’s going to push back? Not worth it. Their primary duty is to the State, not the client.

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My feelings aren’t especially warm right now.

I think creating policies to satisfy the OSA means that IF Archive is trying to do half its mission (“preserve the history and practice”) but has instantly failed in the other its mission (“freely available to the public”).

What I really want to raise is that there’s a case for geoblocking the UK indefinitely unless and until the law is repealed. While that is more extreme in who it will block, it is less extreme in terms of policy change than adding an age verification and content tagging system.

It’s possible that massive protests will occur over the coming months, not just in public but with independent sites choosing to geoblock the UK. People on many other forums are advocating for it. If independent sites act in unison — ie. not the big social networks already putting things in place — it could be effective.

I briefly raised this possibility to Andrew /@zarf, and he asked what benefit this would have. So my answer here is that it’s a form of compliance and protest.

That’s obviously a huge step and if the archive does consider it, it should ask the community if they support it, especially UK users. And of course the site’s lawyer needs input.

(According to the UK’s Ofcom, a full geoblock is enough to comply. “if a service feels the best way to comply is to geoblock the UK, that is sufficient to meet the regulations.” Video source here, originally found on Lobsters.)

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Challenging unjust or badly-written laws is often a really important thing to do, but I’d humbly suggest a nonprofit with $40k in revenues and $10k in assets focusing on incredibly niche subject matter is probably not the best plaintiff for that kind of strategy.

This is generally how it works (which is probably good, since otherwise regulating giant corporations would be even more challenging than it already is!) Well-written legislation takes the cost of compliance into account, and has a sliding scale for bigger and smaller organizations – there’s some of that in OSA, to be fair, as larger sites and ones that are higher-risk for the kind of content/activity being regulated have increased obligations. As you say, the “have a complaint process in place” stuff probably isn’t too bad; the triggers for what you need to do if you’re hosting the wrong kind of content are pretty intense.

Nah, that’s just the legislative definitions, which are densely cross-referencing other legislation (which is good – having two different statutes with two different definitions of the same offence is a very bad idea!) The regulators have a plain-language summary:

  1. terrorism
  2. child sexual exploitation and abuse (CSEA) offences, including grooming, image-based child sexual abuse material (CSAM), CSAM URLs
  3. hate
  4. harassment, stalking, threats and abuse
  5. controlling or coercive behaviour
  6. intimate image abuse
  7. extreme pornography
  8. sexual exploitation of adults
  9. human trafficking
  10. unlawful immigration
  11. fraud and financial offences
  12. proceeds of crime
  13. drugs and psychoactive substances
  14. firearms, knives and other weapons
  15. encouraging or assisting suicide
  16. foreign interference
  17. animal cruelty

There’s also a long guide unpacking each of these.

To be clear, I think the substance here is kinda nuts, and the fact that different items are just included on the same list when the relevant standards and regulations, as I understand it, vary quite a lot (the UK laws around CSAM are not, I don’t think, the same as those around unlawful immigration!)

That’s precisely backwards – except for government lawyers for whom the state is their client. But given how potentially ruinous an international enforcement action could be, a lawyer who failed to inform their client about those risks would be behaving unethically. And of course a lawyer can’t really recommend illegal conduct; they can say “if you break the law, here are the likely consequences and what kind of defenses you could bring”, and for a deep-pocketed client (not IFTF) they could assist in bringing a pre-implementation challenge, though.

Anyway, I understand the frustration at the OSA and I share it. But given that we just last week saw how a comparatively tiny number of complaints can pose an existential threat to IF platforms, I’m can’t criticize the IFTF for deciding not to white-knuckle this.

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I for one love to advocate for organizations to engage in illegal actions on a public platform with an obvious paper trail :slight_smile: This is a good idea because I think it should be a good idea :slight_smile: and I am smart :slight_smile: so the things that I think should be true are true

cia agent monitoring my online activity this is scarcasm

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Off the top of my head, I think this approach is clever, primarily because it makes our opponent face the consequences of their choices while saving our own energy by not having to constantly satisfy everyone’s demands. Regulations always reflect the balance of power, and when you’re not the strongest, it’s a good idea to dodge when you have the chance.

This is especially true since, technically speaking, it is still relatively easy to circumvent such a prohibition. Having said that, I am infinitely less knowledgeable than many people here about the specifics of this issue, so it is entirely possible that important parameters are escaping me.

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I think this approach [geoblocking indefinitely] is clever, primarily because it makes our opponent face the consequences of their choices while saving our own energy by not having to constantly satisfy everyone’s demands.

Well, it’s not something that I came up with personally, so I might as well present the downsides too.

The big challenge in carrying out a hard geoblock is that other countries have similar laws in the works, some of which have failed in the past but might succeed now that lawmakers are advancing them again. That includes the US (KOSA), Canada (Online Harms Act), and Australia (Online Safety Amendment), and probably others.

If those laws are put in place quickly in most users’ countries, people would also have to support a total geoblock against their own country.

Which would basically mean shutting down the community temporarily while IFTF etc. works on things privately with the expectation of reopening the community in who knows how long — months? years?

This strategy would really have to be coordinated strategically with larger trends and movements if it was pursued.

(This is assuming all IF sites have to impose restrictions, which isn’t clear yet).

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“your” technology secretary… but who are “yours” ?

“secretary” points to US (in UK is “ministry”), but the topic raise the ambiguity…

best regards from Italy,
dott. Piergiorgio.

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Rabbit’s in the UK, which is why I said “your” - I was referring to this story:

(Screw Nigel Farage, to be clear, but the stuff Kyle is saying seems to target a much broader range of critics)

I admit that I don’t know why some UK cabinet members are called “ministers” and some are “secretaries” - apparently some things are ministries and some things are departments? Probably there was some relevant stipulation at the Hanoverian Succession :slight_smile:

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I will never understand how that BNP party survived the demise of the mother party… but let’s remain IT.

on your question, nothing related to the UK peculiarities: in UK (and EU) the secretaries are what in US are called undersecretary (with the unusual exception of Italy, where the UK/EU secretary are called “Sottosegretario”, that is, undesecretary, as in US.)
BTW, on this side of the Atlantic pond the US departments are called “ministries”, and yes, this can explain the lexical discrepancy on Gov’t organisations.

Later I’ll look into that new issue (currently, outside IF, I’m watching & monitoring the final proceedings around some large Italian warships, soon to be laid down…) and perhaps I’ll give my opinions.

Best regards from Italy,
dott. Piergiorgio.

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At risk of drifting off topic - alas, it’s not so simple, the Brits have Cabinet-level positions like Home Secretary and Foreign Secretary as well as various secretaries of state with specific portfolios who report only to the PM (this includes the fellow here at issue); while as you say informally the organizations they head tend to be called “ministries” in the UK, they have a range of formal names, and the results, at least to my American ears, frequently make little sense: the Defence Secretary is over the Ministry of Defense, while the Foreign Secretary runs the Foreign Office and the Health Secretary supervises the Department of Health. I suppose we’ll have to allow them their foibles!