Children's 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.11 and Ofcom’s Protection of Children Codes of Practice

1. Trigger for this assessment

The companion Children’s Access Assessment concluded, provisionally, that the Colouring Gallery is likely to be accessed by children. This Children’s Risk Assessment identifies and rates the risks of harm to children that follow from that conclusion, and the measures in place to manage them.

2. Age groups likely to use the service

In the absence of age verification, this assessment provisionally assumes users may fall across all three of Ofcom’s age brackets (8–12, 13–15, 16–17).

3. Risk register by content category

Content category	Relevant here?	Existing mitigations	Residual risk	Notes
Primary priority content: pornographic content	Unlikely	100% pre-publication moderation prevents such content going live	Low	Content consists solely of coloured images of published Johanna Basford drawings. No user self-generated artwork is shared.
Primary priority content: suicide, self-harm and eating disorder content	Unlikely	Not consistent with colouring-image subject matter; moderation	Low	Content consists solely of coloured images of published Johanna Basford drawings. No user self generated artwork is shared.
Priority content: bullying content	Unlikely	Content standards prohibit this; moderation	Low	No comments/messaging exist
Priority content: abusive or hateful content	Low	Content standards; moderation	Low
Priority content: dangerous stunts and challenges	Not relevant	Not consistent with colouring-image subject matter	Low
Priority content: depression or body-stigma content	Low relevance	Moderation	Low
Contact risk: grooming or unwanted contact from adults	Not relevant	Registered accounts only; no open messaging	Low
Contact risk: children contacting other children unsupervised	Not relevant	As above	Low

4. Mitigations in place

Minimum age of 13 stated in the Terms of Use, with parental consent required for under-18s
100% human pre-publication moderation of every uploaded image
No anonymous accounts
Written Acceptable Use Policy prohibiting harmful or abusive content
User reporting mechanism

5. Gaps identified / recommended additional measures

No age-verification technology beyond self-declaration — no “highly effective age assurance” adopted due to the service’s size and risk level.
All images are approved prior to publishing on the site.
All images are coloured versions of existing Johanna Basford artworks – no user generated artwork.
No comments or messaging functionality exists.
Nominated person with responsibility for children’s safety and governance oversight is Johanna Basford.

6. Overall risk level

Provisionally rated LOW–MEDIUM, primarily reflecting the open questions about messaging/comment functionality and the absence of formal age assurance. Recommend confirming these points and re-rating.