Sex Worker Search

Children’s Risk Assessment in Compliance with the Ofcom Online Safety Act

online safety act
Author: theoz
Published: 5 August 2025
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Sex Worker Search is a search engine that indexes the personal websites of independent sex workers. All of the websites indexed are owned by adults and intended exclusively for adult clients. All of the websites are text based with accompanying, non pornographic images.

I look into the web presence of each sex worker wanting to be indexed on SWS in detail before deciding whether to index their website or not. None of them are defined as harmful in the guidelines provided by Ofcom. I look into what kind of written content and accompanying images are on their sites, I check their social media and I google their contact number and/or reverse image search their main image to see what other ads they have online. Everyone with a site indexed on SWS, also has ads on escort directories where they have been age verified. None of the sex workers indexed on SWS see underage clients and none of their websites are in any way made to be appealing to anyone underage.

Sex Worker Search is not a porn website.

See page 32 for a full definition of pornography according to Ofcom.

2.2 For the purposes of the Online Safety Act 2023 (the Act), pornographic content specifically

excludes any content which:

a) consists only of text, or

b) consists only of text accompanied by:

i) identifying content which consists only of text;

other identifying content which is not itself pornographic content

 

Sex Worker Search does not contain any suicide content, self harm content, or eating disorder content. No abusive content, no content which incites hatred, no bullying content, no violent content, no harmful substances content, no dangerous stunts and challenges content. No body stigma content. No depression content.

 

I have read Ofcom's Children’s Register of Risks and I don't believe Sex Worker Search contains any non-designated content.

 

I have done my best to follow the proposed four step process.

 

I have read the Children's Register of Risks.

 

I have tried my best to read and understand the relevant parts of the Online Safety Act.

 

Sex Worker Search had 3300 visitors in the last 28 days. 314 of those visitors were from The United Kingdom.

 

As far as I can tell from Ofcom guidelines the OSA does not set a specific percentage or numeric threshold (e.g. 5%, 10%) for what constitutes a “significant number” of UK child users.

 

I estimate that approximately 0% of the 314 UK users of Sex Worker Search in the last month were children. Sex Worker Search itself is not designed to be appealing to children. Neither are any of the sites in the links. On the contrary Sex Worker Search and all sites indexed in SWS search results are designed specifically for adults.

 

U2U service Children’s Risk Profile and risk factors

  1. Is your service any of these types?
    Tick all that apply.

    Social media service

    Messaging service

    Gaming service

    Pornography service

    Discussion forum or chat room service

    Video-sharing service

    x

    None of the above

  2. Does your service include any of these user identification functionalities?
    Tick all that apply.

    User profiles

    Anonymous user profiles or users without accounts

    x

    None of the above

  3. Does your service include any of these user networking functionalities?
    Tick all that apply.

    Users can connect with other users

    Users can form closed groups or send group messages

    x

    None of the above

  4. Does your service include any of these user communication functionalities?
    Tick all that apply.

Livestreaming

Direct messaging

Commenting on content

Posting images or videos

Posting or sending location information

Re-posting or forwarding content

x

None of the above

  1. Does your service include any of the following functionalities that allow users to find or encounter content? Tick all that apply.

    x

    Searching for user-generated content

    Content tagging

    None of the above

  2. Does your service use content recommender systems?

Kind of. I offer featured listings that appear above other search results to people in exchange for displaying the sex worker search banner on their own website.

  1. Does your service have functionalities and other features that increase user engagement?

No

(U2U) Non-designated content identified for assessment

List of any kind(s) of
non-designated content you have identified for assessment:

Sex Worker Search is a search engine that indexes the personal websites of independent sex workers. All of the websites indexed are owned by adults and intended exclusively for adult clients. All of the websites are text based with accompanying, non pornographic images.

 

Explanation of how you have considered the risk of children encountering non-designated content by means of your service:

I look into the web presence of each sex worker wanting to be indexed on SWS in detail before deciding whether to index their website or not. None of them are defined as harmful in the guidelines provided by Ofcom. I look into what kind of written content and accompanying images are on their sites, I check their social media and I google their contact number and/or reverse image search their main image to see what other ads they have online. Everyone with a site indexed on SWS, also has ads on escort directories where they have been age verified. None of the sex workers indexed on SWS see underage clients and none of their websites are in any way made to be appealing to anyone underage.

Search service Children’s Risk Profile and risk factors

  1. Is your service any of the following types? neither
    Tick one option.

    General search service (including downstream general search service)

    x

    Vertical search service

  2. Does your service have any of the following functionalities?
    Tick all that apply.

Provide users with search predictions or suggestions

Allow users to search for photographs, videos or visual images

x

None of the above

(Search) Non-designated content identified for assessment

List of any kind(s) of non-designated content you have identified for assessment:

NA.

Explanation of how you have considered the risk of children encountering non-designated content by means of your service:

They can't. All sites need to be approved by myself before getting indexed. Users cannot bypass this step. I don't index porn websites or any of the other categories of sites mentioned by ofcom.

Risk levels for content harmful to children

Pornographic content

Risk level:

Zero.

See page 32 https://www.ofcom.org.uk/siteassets/resources/documents/consultations/category-1-10-weeks/statement-protecting-children-from-harms-online/main-document/childrens-register-of-risks.pdf?v=401302#page=32

for full definition of pornography according to ofcom.

2.2 For the purposes of the Online Safety Act 2023 (the Act), pornographic content specifically

excludes any content which:

a) consists only of text, or

b) consists only of text accompanied by:

i) identifying content which consists only of text;

ii) other identifying content which is not itself pornographic content

Sex Worker Search consists of text.

Search results display the website name, url, title, tagline and meta description.

No images.

SWS has a blog page.

Each blog post is text based and accompanied by one cover image. The accompanying images are sometimes artistic nudes or partial nudes but are not gratuitously sexual and not created for the sole purpose of sexual arousal.

Suicide content

Risk level:

NA. There isn't any such content on Sex Worker Search.

Self-harm content

Risk level:

NA. There isn't any such content on Sex Worker Search.

Eating disorder content

Risk level:

NA. There isn't any such content on Sex Worker Search.

Abusive content

Risk level:

NA. There isn't any such content on Sex Worker Search.

Content which incites hatred

Risk level:

NA. There isn't any such content on Sex Worker Search.

Bullying content

Risk level:

NA. There isn't any such content on Sex Worker Search.

Violent content (provides instructions for)

Risk level:

NA. There isn't any such content on Sex Worker Search.

Violent content (humans)

Risk level:

NA. There isn't any such content on Sex Worker Search.

Evidence:

Violent content (animals or fictional creatures)

Risk level:

NA. There isn't any such content on Sex Worker Search.

Harmful substances content

Risk level:

NA. There isn't any such content on Sex Worker Search.

Dangerous stunts and challenges content

Risk level:

NA. There isn't any such content on Sex Worker Search.

Evidence:

Body stigma content

Risk level:

NA. There isn't any such content on Sex Worker Search.

Depression content

Risk level:

NA. There isn't any such content on Sex Worker Search.

Additional kinds of non-designated content (copy and paste form fields as necessary for each kind)

If you have not identified any further kinds of non-designated content for assessment, you do not need to complete this section.

Kind of non-designated content:

NA. There isn't any such content on Sex Worker Search.

Demonstrate how you have had regard for section 49(5) (freedom of expression and privacy):

[How you have complied with the duty to have particular regard to the importance of protecting UK users’ (and interested persons if you are a search service) right to freedom of expression and privacy (Section 49(5) Online Safety Act).] I don't know what this means. 49(5) doesn't say anything about freedom of expression. https://www.legislation.gov.uk/ukpga/2023/50/section/49

Report activity

Date of next children’s risk assessment:

05 08 2026

Confirmation findings of the children’s risk assessment have been reported, and recorded:

Yes / No

Date the findings of the children’s risk assessment were reported, and recorded:

05 08 2025

[Keep a copy of each record of your children’s risk assessment and the date on which it was reported. Update this field for each record.]

Information on how you take appropriate steps to keep the children’s risk assessment up to date (for example, a written policy):

I have a repeating calendar entry reminding me of the next date