1. Service description
Bloom for Mums Ltd provides the 2am Club, an anonymous, moderated peer-support online space for mothers and pregnant people in the UK. The service is small (single-founder, low traffic), free and designed and targeted at users aged 18 and over. The service does not provide direct messaging, private groups, user profiles, content recommendation systems, livestreaming, image, audio or video uploads, or monetisation features.
It is a user-to-user service under the Online Safety Act 2023. Users are provided with a chat room service which allows them to send or post messages that can be read by other users, allowing users to interact with each other. The peer-support rooms only allow text content to be posted, meaning no images, videos or files can be uploaded and shared, nor can livestreams be shared in the 2am Club.
The 2am Club is anonymous by design. Users do not create an account. Users are given a randomly generated flower nickname (e.g. Wildflower-7a3b).
Posts are only published for a 30-day period, after which they are auto-deleted, unless an exception applies in accordance with our Data Retention Policy and Schedule.
2. Risk profile
Based on Ofcom’s Protecting People from Illegal Harms Online: Risk Assessment Guidance and Risk Profiles, the 2am Club is assessed as follows:
Specific risk factors
The 2am Club consists of a chat room service, which is likely to have an increased risk of harm as it may be used by potential perpetrators to discuss and share illegal content.
Nevertheless, the likely increase in harm is reduced, as there is no private messaging, no live streaming, no media uploads, no monetisation, and no algorithmic recommendation.
The 2am Club is anonymous by design, which is likely to increase the risk of harm, as anonymity could be used as a tool for users to protect themselves from being identified and targeted for their views, making it more difficult to identify users who post illegal content.
Nevertheless, the likely increase in harm is reduced, as content is monitored and users can report illegal content.
General risk factors
User base demographics: the 2am Club is designed for mothers and pregnant people in the UK to provide peer-support rooms, which is likely to increase the risk of harm as they may be considered vulnerable users experiencing anxiety, depression, postnatal mental health issues, social isolation or emotional distress.
Business model: the 2am Club is a small service (single-founder, low traffic and few users) and is free to use, which is likely to decrease the risk of harm as there is not a revenue-generating model.
Commercial profile: Bloom for Mums Ltd is an early-stage service, which may increase the likelihood of different illegal harms as there are limited financial resources to introduce effective risk management. Nevertheless, this is reduced by engagement with volunteer solicitors, simple functionality, a limited user base and active moderation processes.
3. Priority illegal content — likelihood of risk of harm
| Offence category | Likelihood | Why |
|---|---|---|
| Terrorism | Low | No content of this nature observed; topic mismatch; pre-moderation; takedown on report; Community Guidelines prohibit such content. |
| Child Sexual Exploitation and Abuse (CSEA / CSAM) | Low | Although image uploads are impossible, text-only services can still be used for sharing links or discussing CSEA. Risk is mitigated by text-only use; no image uploads; 18+ gate; prohibition on third-party information; pre-moderation; takedown on report; and Community Guidelines. |
| Sexual exploitation of adults | Low | Topic mismatch; pre-moderation; takedown on report; Community Guidelines prohibit such content. |
| Encouraging suicide or self-harm | Medium | Topic-relevant audience. Some users may experience distress, depression, loneliness, pregnancy-related mental health difficulties or postnatal mental health conditions. Risk is mitigated by crisis-keyword screening replaced with support resources; Community Guidelines; pre-moderation; and takedown on report. |
| Harassment / stalking / threats / abuse | Low | No private messaging; nicknames rotate; reporting; pre-moderation; takedown on report; Community Guidelines prohibit such content. |
| Hate offences | Low | Pre-moderation; Community Guidelines prohibit such content; takedown on report. |
| Drugs / firearms / fraud / immigration / proceeds of crime | Low | Topic mismatch; no private messaging; pre-moderation; takedown on report; Community Guidelines prohibit such content. |
| Controlling or coercive behaviour | Low | No private messaging; no group formation outside open rooms; pre-moderation; takedown on report; Community Guidelines prohibit such content. |
| Extreme pornography / intimate-image abuse | Negligible | Text-only; no image uploads; Community Guidelines prohibit such content. |
4. Safety measures in place to address the risk of harm
- Automated pre-publication moderation of every post using content identification technologies. All user-generated content is reviewed through automated moderation systems before publication and may be blocked where indicators of prohibited or illegal content are detected.
- Automated crisis-keyword screening that replaces a post with Samaritans 116 123 and 999 resources.
- Plain-English Community Guidelines which prohibit illegal content and form part of the Terms of Use.
- The service is designed and targeted to users aged 18 and over. Users self-declare that they are 18 or over before they can use the 2am Club.
- An easy-to-use in-app report button on every post for illegal content reporting. Reports are reviewed by moderators within defined internal response times.
- An appeal route with a 10-working-day response target for removed content.
- 30-day auto-deletion of posts as a default.
Taking into account the nature, functionality and user base of the 2am Club, as well as the safety measures in place, Bloom for Mums considers the risk of most categories of priority illegal content to be low, with a medium risk identified in relation to content encouraging suicide or self-harm due to the nature of the service and its audience.
5. Governance
The Founder is the responsible person for Online Safety Act 2023 compliance. Moderators apply the Community Guidelines and escalate safeguarding concerns in accordance with the internal procedure. The risk assessment is reviewed at least annually and after any safeguarding incident or material service change.
6. Children’s access assessment
The Service is not designed for or directed at children. It is directed at users aged 18 or over with a self-declaration of age before being allowed to use the 2am Club service. In addition, there is a contractual restriction on use of the service by children. As this is based on self-declaration, it would be possible for children to access the service. Nevertheless, it would deter some children from accessing it.
The 2am Club does not meet the “children user condition” as it contains no functionality that would attract children. It does not provide benefits to children, its content is not likely to appeal to children and the service is not designed for children.
Bloom’s current assessment is that the service is unlikely to attract children, although children could technically access the service due to the absence of highly effective age assurance.
We will repeat this children’s access assessment annually.