Childrens Risk Assessment

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TalkMH Children's Risk Assessment

This assessment records the risks of harm to children who may access TalkMH, including the likelihood and impact of encountering content harmful to children, the way TalkMH's design and functionality affect those risks, and the controls used to mitigate them.

Service: TalkMH
Service type: User-to-user mental health discussion forum
Intended audience: Adults aged 18+
Public assessment owner: TalkMH Administration
Internal accountable person: Named individual recorded in the private compliance register
Assessment version: 1.0
Assessment date: 7 August 2026
Routine review: At least annually, and sooner where a review trigger applies

Children's Access Assessment Outcome

TalkMH is intended for adults aged 18+ and registration requires confirmation of adult status. TalkMH does not currently rely on highly effective age assurance to prevent children from accessing the service.

For the purposes of this assessment, TalkMH therefore takes the conservative position that the service is likely to be accessed by children, particularly because public forum content can be viewed without registration. The protection-of-children duties are consequently treated as applicable unless and until a future Children's Access Assessment, supported by appropriate evidence or highly effective age assurance, reaches a different lawful conclusion.

Purpose and Scope

TalkMH provides peer-to-peer discussion around mental health and general life experiences. It is not a medical service, therapy provider, crisis service, safeguarding authority or emergency response service.

This assessment covers public discussions, replies, user profiles, media and links, forum search, private communications where available, moderation processes, registration controls and other features through which a child could encounter user-generated content.

The assessment separately considers each kind of primary priority content, each kind of priority content, and the non-designated content identified as relevant to TalkMH. It also considers different child age groups and the effect of TalkMH's design and use on the level of risk.

Method and Evidence Considered

Ofcom's Children's Risk Assessment Guidance and Children's User-to-User Risk Profile have been consulted.
TalkMH's purpose as a mental-health discussion forum has been treated as a material service characteristic.
The existing adult-only rule, registration declaration, community rules, reporting tools, moderation controls, suicide/self-harm policy and account restrictions have been considered.
Public accessibility of forum pages, user profiles, commenting/replies, user-generated content search and private messaging where enabled have been considered.
The absence of highly effective age assurance has been treated as an access-risk factor rather than assuming the 18+ rule prevents child access.
Existing moderation experience, user reports, complaints and incident records should be reviewed alongside this assessment and retained as supporting evidence.
Where evidence is limited or inconclusive, the assessment errs on the side of the higher reasonable risk level.

Overall Child Risk Position

TalkMH is not designed for children and does not target them. However, the subject matter of the service means that a child who accesses public content could encounter discussions concerning suicide, self-harm, depression, medication, addiction, trauma, abuse, body image and other sensitive matters.

The highest inherent risks are therefore suicide content and self-injury content. TalkMH is assessed as a multi-risk service for child-safety purposes because at least two kinds of content are assessed at Medium or High risk. Existing rules and moderation reduce risk, but they do not remove the possibility of a child encountering harmful user-generated content before staff become aware of it.

Consideration of Different Age Groups

Age group	Foreseeable use / exposure	TalkMH assessment
0-5	Independent intentional use is unlikely; incidental exposure through a shared device remains possible.	Low likelihood of use, but harmful content may still have significant impact if encountered.
6-9	Independent browsing is more plausible, including discovery through search engines or shared links.	Low to Medium access likelihood; limited ability to contextualise adult mental-health discussions increases potential impact.
10-12	Greater independent internet use and ability to search for mental-health topics.	Medium access likelihood; elevated vulnerability to harmful self-harm, body-image, bullying and despair-related content.
13-15	Could deliberately search for mental-health support or attempt to register despite the 18+ rule.	High relevance to TalkMH's subject matter; elevated risk from suicide, self-harm, eating-disorder, bullying and depression content.
16-17	Most likely child age group to intentionally seek peer mental-health support and to appear similar to adult users.	Highest foreseeable child-access likelihood. Risk controls must not assume that a near-adult user is necessarily 18+.

Primary Priority Content

Children of every age must be protected from encountering primary priority content. Each kind is assessed separately below.

Content harmful to children	Likelihood	Impact	Risk	TalkMH rationale and controls	Residual risk
Pornographic content Pornographic user-generated images, video or links.	Low	High	Medium	Pornography and explicit sexual content are not part of TalkMH's purpose and are prohibited. User content and links can be reported. Explicit material is removed when identified and accounts may be restricted or banned. Media/upload functionality must be reviewed if materially expanded.	Low
Suicide content Content encouraging, promoting or providing instructions for suicide.	Medium	Very High	High	Mental health and suicidal thoughts may legitimately be discussed, making this subject foreseeable on the service. TalkMH's dedicated policy prohibits methods, instructions, encouragement, pressure, pacts and other content that assists suicide. High-risk content is removed or hidden promptly when identified. Users can report content and repeat/deliberate offenders may be restricted or banned. Crisis and urgent-support information is made available without presenting TalkMH as an emergency service.	Medium
Self-injury content Content encouraging, promoting or providing instructions for deliberate self-injury.	Medium	Very High	High	Supportive discussion of self-harm experiences is foreseeable because of the service's subject matter. Instructions, methods, encouragement, graphic content and content intended to increase harm are prohibited. Reports receive priority moderation and harmful content is removed or restricted when identified. Rules distinguish legitimate support-seeking from harmful encouragement or instruction.	Medium
Eating-disorder content Content encouraging, promoting or providing instructions for an eating disorder or associated behaviour.	Low to Medium	High	Medium	Eating disorders and body-image concerns may arise in mental-health discussions. Content encouraging harmful behaviours or presenting instructional material may be removed. Users can report dangerous or triggering material. Supportive recovery discussion is distinguished from content that promotes an eating disorder.	Low to Medium

Priority Content

The eight kinds of priority content specified in Ofcom's children's risk-assessment framework are assessed separately.

Content harmful to children	Likelihood	Impact	Risk	TalkMH rationale and controls	Residual risk
Abusive content targeting protected characteristics	Low to Medium	High	Medium	Identity-based abuse is prohibited. Members can report abusive replies. Moderators may remove content and restrict repeat or severe offenders.	Low to Medium
Content inciting hatred against protected groups	Low	High	Medium	Hate speech and incitement are prohibited. Reported material is removed and serious/repeated breaches may result in permanent bans.	Low
Content encouraging serious violence against a person	Low	Very High	Medium	Threats and encouragement of violence are prohibited. Credible threats receive urgent review and may be escalated where lawful and necessary. Accounts may be immediately restricted.	Low
Bullying content	Medium	High	High	Vulnerable users may be particularly affected by repeated hostility or dogpiling. Harassment and bullying are prohibited. Report and block/ignore tools are available. Threads may be locked and accounts warned, restricted or banned.	Medium
Realistic serious violence or graphic injury involving a person	Low	High	Low	Graphic harmful material is not part of the service purpose. Graphic content may be removed or restricted when identified. Users can report disturbing media or links.	Low
Realistic serious violence or graphic injury involving animals or fictional creatures	Low	Medium to High	Low	Such content is unrelated to TalkMH's purpose. Disturbing or graphic material may be removed and reported accounts restricted.	Low
Dangerous stunts and challenges	Low	High	Low	Content encouraging dangerous conduct capable of serious injury is prohibited or removed. The forum has no feature specifically designed to promote challenges or viral trends.	Low
Harmful substances content Content encouraging harmful self-administration of substances or harmful quantities.	Low to Medium	High	Medium	Medication, addiction and substance-use experiences may be discussed as peer support. Dangerous dosage instructions or encouragement of harmful use may be removed. TalkMH does not present user posts as medical advice. Users are directed toward appropriate professional support where necessary.	Low to Medium

Non-Designated Content

Ofcom has identified body-stigma content and depression content as kinds of non-designated content that may present a material risk of significant harm to children. Both are relevant to the subject matter of TalkMH and are therefore assessed below. The presence and incidence of non-designated content must be recorded and notified to Ofcom where the applicable duty is triggered.

Non-designated content	Likelihood	Impact	Risk	Controls / rationale	Residual risk
Body-stigma content Content that shames or stigmatises body types or physical features.	Medium	High	Medium	Body image and identity can arise naturally in mental-health discussions. Targeted abuse and humiliation are prohibited. Members can report harmful content and moderators can remove it.	Low to Medium
Depression content Content that promotes depression, hopelessness or despair.	Medium	High	High	Depression is a core subject of TalkMH, so children could encounter emotionally intense discussion. Supportive discussion of depression is not treated as harmful merely because it describes lived experience. Content that glorifies, encourages or deliberately intensifies hopelessness may be restricted or removed. Suicide/self-harm rules and crisis signposting provide additional controls where despair content escalates into higher-risk material.	Medium

Service Design and Use Risk Factors

Characteristic / functionality	Risk effect	Assessment / control
Discussion forum service	Increases relevance to suicide/self-harm and eating-disorder risk profiles because users can create and respond to sensitive discussions.	Material risk factor. Strong moderation rules and reporting are required.
Publicly viewable user-generated content	A child may encounter content without registering or declaring an age.	Material access risk. The 18+ registration rule does not itself prevent public viewing.
User profiles	May expose personal information and facilitate unwanted attention or relationship-building.	Profile information should be minimised; users should be discouraged from publishing identifying information.
Replies / comments	Can enable support, but also bullying, encouragement of harm, abusive responses or reinforcement of dangerous ideas.	Report function, moderation, thread locks and account restrictions mitigate the risk.
Private messaging, where enabled	Reduces public visibility of conduct and may facilitate grooming, exploitation, coercion or harmful encouragement.	Users must be able to report private conduct; new-account or trust-based restrictions should be considered and kept under review.
User-generated content search	Can make sensitive historic discussions easier to locate intentionally.	Searchable harmful content remains subject to rules and moderation; archival content should be reviewed where risks are identified.
Images / media / external links	Can introduce pornography, graphic content, harmful instructions or malicious destinations.	Report/removal procedures apply; expansion of media functionality triggers reassessment.
Recommender systems	Algorithmic amplification can repeatedly expose children to harmful content.	No material algorithmic recommendation system is relied upon in this assessment. Any future introduction triggers a new assessment before launch.
Engagement features	Notifications, reactions and activity feeds can increase repeated exposure.	Avoid design that gamifies crisis, self-harm, eating-disorder or despair-related content. Review changes to engagement systems before deployment.
Adult-only positioning without HEAA	May deter some children but does not reliably identify or exclude them.	Treated as a partial control only. Child access remains foreseeable.
Mental-health subject matter	Creates an elevated likelihood of sensitive lived-experience content, particularly suicide, self-harm and depression.	Core inherent risk and the principal reason for High/Medium ratings in this assessment.

Additional Risks to Child Users

Risk	Assessment	Control
Child misrepresenting age	Foreseeable, particularly for 16-17 year olds seeking support.	Accounts reasonably believed to belong to under-18s may be restricted or removed; staff must not assume self-declaration is conclusive.
Adult-to-child contact	Potentially serious if a child gains access while presenting as an adult.	Exploitative, coercive, sexual or predatory conduct is prohibited; private-message reports receive priority review.
Disclosure of personal information	A distressed child may disclose location, school, identity, contact details or other sensitive information.	Remove identifying information where necessary, discourage oversharing and enforce anti-doxxing rules.
Misleading medical advice	A child could treat peer experience as professional advice.	Prominent peer-support disclaimer; dangerous prescriptive advice may be removed; professional support signposted.
Emotional escalation / contagion	Repeated exposure to hopeless, graphic or mutually reinforcing crisis discussion may worsen distress.	Dedicated suicide/self-harm rules, moderation intervention, restrictions on graphic/instructional content and appropriate support signposting.

Required Child-Safety Controls

Maintain a clear 18+ rule and age declaration while recognising these are not highly effective age assurance.
Maintain accessible terms, community rules and a dedicated suicide/self-harm policy.
Use proportionate systems and processes designed to prevent children from encountering primary priority content.
Maintain effective content moderation for harmful content identified in this assessment.
Provide a simple reporting mechanism for public content and private communications where private messaging is available.
Maintain an accessible complaints and moderation-appeals process.
Maintain procedures for urgent threats, CSEA/CSAM, grooming, exploitation and serious illegal content.
Restrict or remove accounts reasonably believed to belong to children where consistent with TalkMH's adults-only policy.
Consider proportionate limits on new-user private messaging and other functionality capable of facilitating private adult-to-child contact.
Ensure moderation decisions and serious incidents are recorded.
Monitor complaints, reports, moderator observations and other available evidence for changes in child-risk levels.
Maintain the separate Children's Access Assessment and review it in accordance with applicable requirements.
Record any applicable Protection of Children Code measures implemented by TalkMH and the rationale for any alternative measures.
Notify Ofcom of relevant non-designated content identified as present on the service where required.

Child-Safety Response Levels

Level	Example	Response
Low	Possible under-18 account with no immediate safeguarding concern	Review available information; restrict account where appropriate under the 18+ policy; record action if material.
Medium	Bullying, body shaming, unsafe medical advice, harmful substance encouragement	Remove/restrict content as appropriate, warn or restrict account, preserve relevant moderation record.
High	Suicide/self-harm encouragement, grooming indicators, predatory contact, serious threat	Immediate content/account restriction, senior moderation review, preserve necessary records and consider external escalation where lawful and necessary.
Critical	CSEA/CSAM, credible immediate threat to life, serious criminal exploitation	Immediate safeguarding/content action, prevent further dissemination, preserve only necessary records and report/escalate where legally required.

Record Keeping and Governance

A written record of this assessment and every revision is retained in an easily understandable form.
The private compliance record identifies who completed the assessment, the named person responsible for it and who approved it.
Records show that Ofcom's Children's Risk Profiles were consulted and identify the evidence used to reach each risk conclusion.
Relevant user reports, complaints, moderation data and serious incidents are retained as supporting evidence where appropriate.
The findings are reported through TalkMH's internal online-safety governance arrangements.
The public version may identify the responsible function as TalkMH Administration; the legally required named individual is retained in the private compliance record.

Review Triggers

At least annually as part of the routine review cycle.
Before any significant change to TalkMH's design or operation.
A significant change to Ofcom's Children's Risk Profiles that relates to TalkMH.
Introduction or major change to private messaging, image/video uploads, live chat, anonymous posting, groups, recommendations, search, tagging or other engagement functionality.
A material change to the service's size, audience, business model or moderation arrangements.
Evidence that children are accessing or attempting to register for TalkMH in greater numbers than previously understood.
A serious child-safety, suicide/self-harm, grooming, exploitation, CSEA or other harmful-content incident.
A significant increase in complaints, user reports or moderator observations concerning content harmful to children.
Evidence that existing controls are ineffective or being circumvented.
A relevant change to UK law, Ofcom Codes of Practice, guidance or enforcement expectations.

Assessment Conclusion

TalkMH is intended for adults, but in the absence of highly effective age assurance it is reasonable to treat child access as foreseeable. The forum's mental-health subject matter creates particular inherent risk in relation to suicide content, self-injury content, bullying and depression content.

TalkMH's rules, moderation, reporting arrangements, account controls and dedicated suicide/self-harm policy materially reduce these risks. They do not eliminate them. TalkMH must therefore continue to maintain and test proportionate child-safety systems, monitor evidence of child access and harmful-content incidence, and review this assessment when required.

Public assessment owner: TalkMH Administration
Version: 1.0
Last reviewed: 7 August 2026
Next routine review due: 7 August 2027
Status: Active
Private compliance record: Named accountable individual and approver retained separately