Would Torn implement age verification?

This is currently correct, unless the laws change then we have no reason to implement it. 

 

If we did there are probably a few things we'd try first. If we had age verification it would probably only be required to restrict social area, chats/forums etc locked behind age verification.

 

We'd only have that as a last resort if legally required though. 

Game age ratings are largely irrelevant for our intents and purposes, they are only a factor from a publishing perspective.

 

Firstly though age ratings aren't an international standard, they're a country's restrictions for publishing - we can be one rating in one country and another somewhere else - realistically the only area this affects us is Googleplay listings.

 

We have a few markers there which most places will just outright define as an "adult" rating, although where you are again will vary what age restriction applies here. US "M" for mature audiences is 17, EU/UK PEGI ratings are 18.

 

The main factors are:

• Simulated gambling
• Drug use & Drug use for tangible benefit
• Alcohol use & Alcohol use for tangible benefit
• Tobacco products (since we have cigars) 

 

Governments with a strict Muslim or religious background can be quite strict when it comes to the alcohol, drugs and gambling parts, and as a result we are "unrated" and cannot publish on Googleplay in United Arab Emirates, Algeria, Iran, Jordan, Libya, Oman, Palestine, Qatar, Saudi Arabia, Syria, Tunisia and Yemen. 

 

Other countries like Australia are unreasonably strict when it comes to drug use, in scenarios where there are "real" drugs for in game benefits they consider it unrateable and we therefore cannot publish there either.

 

South Korea also have their own ratings agency (GRAC) that require us to jump through a whole bunch of extra hoops, we just never felt the need so we do not list there either.

 

When it comes to the UKOSA the only thing I have had to do for that so far was to complete a risk assessment of the priority illegal content, specific risk factors/service type factors, user base and general risk factors. 

 

The specific points I have referenced in Torn's assessment are:

Terrorism
Child Sexual Exploitation and Abuse (CSEA)
Grooming
CSAM (including image-based CSAM and CSAM URLs)
Encouraging or Assisting Suicide (or attempted suicide)
Hate
Harassment, Stalking, Threats, and Abuse
Controlling or Coercive Behaviour
Drugs and Psychoactive Substances
Firearms, Knives, and Other Weapons
Human Trafficking
Unlawful Immigration
Sexual Exploitation of Adults
Extreme Pornography
Intimate Image Abuse
Proceeds of Crime
Fraud and Financial Services
Foreign Interference Offence
Animal Cruelty

 

With considerations here for mail/chat services, forum, image hosting, external URLs and age ranges on the site . 

 

Some are obviously considerably lower/near zero risk, but since we have a chat and social features we are basically required to list them all and determine a level of risk, and in my opinion none of these reach Ofcom's expectations of "high" risk, but I can err on the side of caution with a few to list as medium - For example - Grooming, since this is a legitimate concern as we have under 18s here and we can have cases for that we will pass to police, but it is not a case where we just allow this to happen and will actively moderate for it. Firearms/Drugs as medium since we have "real world" examples in the game. Hate, because y'all are toxic af sometimes and P&L exists.

 

Most others are obviously low risk but never zero, terrorism/human tricking being curious examples here, since we have a chat there is technically a risk of the platform being used for that, or things such as animal cruelty because its possible to share images here.