@jim The Environment Agency was effectively a pollution licensing agency long before anyone squeezed its funding.

@jim @cstross Not just business model, content or users, but also - according to the theory - technical features and functionalities.There is quite a heavy emphasis on that aspect in both the Act and Ofcom’s implementation.

@bjn @cstross @jim Lastly, an earlier piece on differing views of safety by design, written before the responses to the Ofcom Additional Measures consultation discussed in the more recent piece. https://www.cyberleagle.com/2024/12/safe-speech-by-design.html

@bjn @cstross @jim The piece to which I linked also discusses how the theory of safety by design was originally crafted with a few large social media companies in mind and tends to collapse if applied beyond that.

@bjn @cstross @jim Other than ‘think about safety at the design stage’ there is little clarity about what, in the context of the Online Safety Act, safety by design is supposed to mean. In the past its proponents have seen it as an alternative to content-focused measures, but now we have suggestions that e.g. automated content filtering is a safety by design measure. If, as has recently been suggested, the OSA should formally define it, we have to understand it first. https://www.cyberleagle.com/2026/02/safety-by-design-or-systems-for-content.html

Even then, there is a more than lurking suspicion that the theory was crafted specifically with a few large social media platforms in mind, and is liable to collapse if extended beyond that. 4/4 https://www.cyberleagle.com/2026/02/safety-by-design-or-systems-for-content.html

Semi-seriously, I propose a moratorium on advocacy for online safety by design until its proponents have figured out what, concretely, it does and (perhaps more importantly) does not mean. Let’s face it, if it includes automated content filtering is it really anything more than an empty slogan? 3/4

Last year’s submissions to Ofcom’s Additional Measures consultation, however, left me thoroughly confused. E.g. 2/4 https://www.cyberleagle.com/2026/02/safety-by-design-or-systems-for-content.html