Colouring Gallery — Johanna Basford Ltd (www.johannabasford.com)
Prepared: 2 July 2026 | Legal basis: Online Safety Act 2023, s.37 and Ofcom’s Guidance on Children’s Access Assessments
1. Purpose
This assessment determines whether the Colouring Gallery is “likely to be accessed by children” for the purposes of the Online Safety Act 2023 (“OSA”). This conclusion determines whether the service must also carry out a Children’s Risk Assessment and comply with the children’s safety duties in the OSA and Ofcom’s Protection of Children Codes of Practice.
2. Service description
- Service: the Colouring Gallery, a feature of www.johannabasford.com operated by Johanna Basford Ltd.
- Function: registered users upload photographs of their colouring artwork, which (once approved) are displayed publicly to all site visitors.
- Registration requires: full name, username and email address.
- Moderation: every uploaded image is reviewed by a member of the team (including, where applicable, a freelance contractor) before it is published; unapproved images are never made public.
- No date of birth information is collected
- No Comments, messaging or direct contact functionality exists between users.
3. The four-question test
Ofcom’s guidance asks providers to work through the following questions.
| Question | Answer | Notes |
| Q1. Does the service use highly effective age assurance to prevent children from accessing it (or the relevant part of it)? | No | Only a self-declared minimum age of 13 is stated in the Terms of Use; this is not “highly effective age assurance” as defined by Ofcom. |
| Q2. Do the terms of use ban children, and is this enforced by means other than age assurance? | Partially | The Terms of Use set a minimum age of 13 and require parental consent under 18, but this is not independently verified. |
| Q3. Is a significant number of the service’s UK users children, or does the service target children? | No | No user-age data is currently reviewed as part of this assessment. Recommend checking account data/analytics if available. |
| Q4. Is the service of a kind likely to appeal to children (because of its content, functionalities or how it is promoted)? | Likely yes | Colouring is an activity strongly associated with children; the operator’s wider catalogue includes titles aimed at children and family audiences, which may draw a child audience to the Gallery even without targeted marketing. |
4. Provisional conclusion
On the basis of the above, and in the absence of highly effective age assurance, the provisional conclusion is that the Colouring Gallery is LIKELY TO BE ACCESSED BY CHILDREN for the purposes of the OSA.
This means the service must also complete a Children’s Risk Assessment (see companion document) and comply with the children’s safety duties in the OSA and Ofcom’s Protection of Children Codes of Practice.
5. Review
This assessment should be reviewed:
- at least annually;
- whenever Ofcom publishes a significant change to its risk profiles or guidance; and
- whenever the service’s design, functionality or user base changes materially (for example, adding messaging, comments, or age-verification technology).
6. Sign-off
| Completed by: | Johanna Basford | Date: | 3/7/26 |
| Approved by: | Date: |
