Illegal Content Risk Assessment - Johanna Basford : Illustrator & Colouring Book Maker

Colouring Gallery — Johanna Basford Ltd (www.johannabasford.com)

Prepared: 2 July 2026 | Legal basis: Online Safety Act 2023, s.9

1. Purpose and scope

All regulated user-to-user services must carry out a “suitable and sufficient” illegal content risk assessment, covering the risk that the service is used to commit or facilitate a priority offence, or to host other illegal content, and must keep it up to date.

2. Service characteristics

Feature	Present?	Notes
User registration	Yes	Full name, username, email address
Public content upload	Yes	Photographs of coloured Johanna Basford artwork
Pre-publication moderation	Yes	100% human review before content goes live
Direct messaging between users	No
Public comments on images	No
Search / discovery of other users	Yes	Only by username.
Anonymous posting	No	Requires a registered account
Livestreaming	No

3. Risk register

Risk area	Likelihood	Impact	Existing mitigations	Residual risk	Further action
Child sexual exploitation & abuse (CSEA) content, including images of children uploaded in a way that could be exploited	Low	High	100% human pre-moderation before publication; registered accounts only (no anonymity)	Low	Give the moderator a written escalation procedure: report suspected CSEA material to the IWF/NCA and preserve evidence rather than simply deleting it
Harassment, stalking, abusive comments	Low	Medium	Acceptable Use Policy prohibits abusive content; moderation	Low	Confirm whether comments/messaging exist; if so, add reporting/blocking tools
Hate offences	Low	Medium	Content standards prohibit hate speech; moderation	Low	Ongoing moderator training/refreshers
Encouraging or assisting suicide/self-harm	Low	High	Unlikely subject matter for colouring images; moderation would catch incidental disclosures	Low	Brief the moderator on a referral pathway if a user discloses risk of harm via any text field
Fraud / scams	Low	Low	No payment or marketplace functionality on the Gallery	Low	No further action
Extreme pornography / non-consensual intimate images	Low	High	Moderation before publication prevents any such image reaching public view	Low	Maintain moderation as the primary control; keep a log of decisions
Intellectual property infringement / impersonation	Low	Low	Terms of Use prohibit infringing content	Low	No further action

4. Overall risk level

Provisionally assessed as LOW, on the basis that 100% of content is reviewed by a human moderator before publication and the service does not support anonymous posting. No messaging, comments or contact between users

5. Mitigation measures already in place

Mandatory account registration (no anonymous uploads)
100% pre-publication human moderation of every image
Written content standards (Acceptable Use Policy)
User reporting/flagging route ([email protected])
Right to remove content and suspend accounts
Escalation route to law enforcement / the Internet Watch Foundation for the most serious content