www.glass-uk.org

Not in-scope

www.trailwise2.co.uk

Application Description

TrailWise2 (TW2) is a Graphical Information System (GIS) provided by the Green Lane Association exclusively for its members. It is a digital map of Public Rights of Way within England and Wales with additional data concerning current and historical condition.

Service types to be assessed
U2U User to User

1. Does your service incorporate any of these types?
Discussion Forum / Chat Room

2. Do child users access some or all of the service?
No

3. Does your service include any of these user identification functionalities?
User profiles

4. Does your service include any of these user networking functionalities?
Users can connect with other users
Users can form closed groups or send group messages

5. Does your service include any of these user communication functionalities?

Commenting on content
Posting or sending images or videos (either open or closed channels)
Posting or sending location information
Re-posting or forwarding content

6. Does your service allow users to post goods and services for sale?
No

7. Does your service include any of the following functionalities that allow users to find or encounter content?
Hyperlinking

Consideration of illegal harms

Harm #1 Terrorism

Terrorism Risk level: Low
Terrorism Risk factors considered:
1e All posts are moderated before they are made visible to other users. Our moderators will remove and report illegal content.
4a Our users can follow each other in disqus.com to see what posts they have made.
4b Posts can be viewed by members, the group being all members, after the post has been moderated.
5d Members can make posts that comment on the posts of others but these are 100% moderated.
5e All image and video content will be moderated before display to members.
7b Moderators will check all hyperlinks.

Terrorism Additional characteristics considered:
All posts are moderated before they are made visible. Terrorism is not related in any way to our content.

Terrorism Existing controls considered:
We have 100% moderation of content by a trained human volunteer.

Terrorism Evidence:
We have no evidence of any terrorist activity.

Category of service provider: All other categories of service provider
Kind of illegal harm: #1 Terrorism
Risk of illegal harm: Low

ICU A2
Name of accountable person: Chris Mitchell
Status: Already implemented
Effective from: March 16, 2025

ICU C1
Content moderation policy: https://www.greenlaneassociation.uk/content-policy/
Name of moderator assessing content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU C2
Name of moderator taking down content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU D1
Complaints enabled?: Yes
Status: Already implemented
Effective from: March 16, 2025

ICU D2
Complaint handling procedure: https://www.greenlaneassociation.uk/complaints/
Easy to find complaints system?: Yes
Easy to access complaints system?: Yes
Easy to use complaints system?: Yes
Status: Already implemented
Effective from: March 16, 2025

ICU D7
Appropriate action: Yes
Complaint process URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU D9
Appropriate action for appeals: Yes. Appeals are considered
Complaint appeal process URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU D10
Action following appeal determination: Yes. Follow up action is taken
Appeal determination process URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU D11
Complaints about technology: Yes. Action is taken about technology complaints
Complaints about technology URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU D12
Action taken for all other complaints: Yes. Action is taken for all other complaints
Procedure for all other complaints URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU D13
Unfounded complaints: We have a process for dealing with unfounded complaints
Unfounded complaints process URL: https://test.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU G1
Terms of service URL: https://www.greenlaneassociation.uk/terms-of-use/
Status: Already implemented
Effective from: March 16, 2025

ICU G3
Clarity of terms of service: The clarity is good
Accessibility of terms of service: Accessibility is good
Status: Already implemented
Effective from: March 16, 2025

ICU H1
Removing proscribed organisations: Yes, accounts belonging to users of proscribed organisations are removed
Status: Already implemented
Effective from: March 16, 2025

Harm #2a CSAM

CSAM Risk level: Low

CSAM Risk factors considered:
1e All posts are moderated by a human before they are approved and displayed.
4b The only user group is the entire membership of the association
4b The only group that can be messaged is the entire association.
5e All posts are moderated by a human before they are approved and displayed.

CSAM Additional characteristics considered:
There are no child users on TrailWise2. Moderators will remove any post containing illegal content.

CSAM Existing controls considered:
TrailWise2 is moderated by humans. All posts are moderated before they are displayed to others.

CSAM Evidence:
We have no prior evidence of CSAM occurring on trailwise.

Name of in-scope service: TrailWise2
URL of in-scope service: https://trailwise2.co.uk
Type of in-scope service: U2U - User to User
Do children use the service: No
Content recommender system in use: No
Category of service provider: All other categories of service provider
Kind of illegal harm: #2a Image based CSAM
Risk of illegal harm: Low

ICU A2
Name of accountable person: Chris Mitchell
Status: Already implemented
Effective from: March 16, 2025

ICU C1
Content moderation policy: https://www.greenlaneassociation.uk/content-policy/
Name of moderator assessing content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU C2
Name of moderator taking down content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU D1
Complaints enabled?: Yes
Status: Already implemented
Effective from: March 16, 2025

ICU D7
Appropriate action: Yes
Complaint process URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU D13
Unfounded complaints: We have a process for dealing with unfounded complaints
Unfounded complaints process URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU G1
Terms of service URL: https://www.greenlaneassociation.uk/terms-of-use/
Status: Already implemented
Effective from: March 16, 2025

ICU G3
Clarity of terms of service: The clarity is good
Accessibility of terms of service: Accessibility is good
Status: Already implemented
Effective from: March 16, 2025

Harm #2b CSAM URL

CSAM URL Risk level: Low

CSAM URL Risk factors considered:
1e All posts are moderated by a human before they are approved and displayed.
4b The only user group is the entire membership of the association
4b The only group that can be messaged is the entire association.
7b All posts are moderated by a human before they are approved and displayed. Hyperlinks will be checked by the moderator.

CSAM URL Additional characteristics considered:
There are no child users on TrailWise2. Moderators will remove any post containing illegal content.

CSAM URL Existing controls considered:
TrailWise2 is moderated by humans. All posts are moderated before they are displayed to others.

CSAM URL Evidence:
We have no prior evidence of CSAM occurring on TrailWise2.

ICU A2
Name of accountable person: Chris Mitchell
Status: Already implemented
Effective from: March 16, 2025

ICU C1
Content moderation policy: https://www.greenlaneassociation.uk/content-policy/
Name of moderator assessing content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU C2
Name of moderator taking down content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU D1
Complaints enabled?: Yes
Status: Already implemented
Effective from: March 16, 2025

ICU D7
Appropriate action: Yes
Complaint process URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU G1
Terms of service URL: https://www.greenlaneassociation.uk/terms-of-use/
Status: Already implemented
Effective from: March 16, 2025

ICU G3
Clarity of terms of service: The clarity is good
Accessibility of terms of service: Accessibility is good
Status: Already implemented
Effective from: March 16, 2025

Harm #2c Grooming

Grooming Risk level: Low

Grooming Risk factors considered:
1e All posts are moderated before display. Moderators will remove illegal content.
3a All user profiles are for adults. The association does not have members under the age of 18.
3a All user profiles are for adults. All are identifiable from home address associated with membership payment method. No fake users.
4a There are no child users to connect with to groom.
4b There is only one user group, the entire membership.
4b The only group that can be messaged is the entire membership and then only after a moderator has approved their post.
5d Comments on previous posts are also 100% moderated before display.
5f Locations can be derived from the map but the poster is unlikely to still be there as the locations are on journeys.

Grooming Additional characteristics considered:
There are no child users on this service.

Grooming Existing controls considered:
100% moderation in operation. No post can be displayed without a moderator approving it.

Grooming Evidence:
We have no evidence of grooming occurring previously. It would be difficult to do as we have no child users.

ICU A2
Name of accountable person: Chris Mitchell
Status: Already implemented
Effective from: March 16, 2025

ICU C1
Content moderation policy: https://www.greenlaneassociation.uk/content-policy/
Name of moderator assessing content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU C2
Name of moderator taking down content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU D1
Complaints enabled?: Yes
Status: Already implemented
Effective from: March 16, 2025

ICU D7
Appropriate action: Yes
Complaint process URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU G1
Terms of service URL: https://www.greenlaneassociation.uk/terms-of-use/
Status: Already implemented
Effective from: March 16, 2025

ICU G3
Clarity of terms of service: The clarity is good
Accessibility of terms of service: Accessibility is good
Status: Already implemented
Effective from: March 16, 2025

Harm #3 Encouraging or Assisting Suicide

Suicide Risk level: Low

Suicide Risk factors considered:
1e All posts are moderated before display. Moderators will remove illegal content.
4b There is only one user group, the entire membership.
5d Comments on previous posts are also 100% moderated before display.
5e All image and video content will be moderated before display to members.
5g It is not possible to repost without moderator approval, reposts are usually deleted for unnecessary duplication of content.
7b All posts are moderated by a human before they are approved and displayed. Hyperlinks will be checked by the moderator.

Suicide Additional characteristics considered:
Our service provides an activity that has been said by many members will improve their mental health.

Suicide Existing controls considered:
Our comment system is 100% moderated. All posts are read by a human moderator before publication. The moderators apply our content policy in their decision making.

Suicide Evidence:
We have no evidence that our commenting system in TrailWise2 has ever been used to promote or assist suicide.

ICU A2
Name of accountable person: Chris Mitchell
Status: Already implemented
Effective from: March 16, 2025

ICU C1
Content moderation policy: https://www.greenlaneassociation.uk/content-policy/
Name of moderator assessing content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU C2
Name of moderator taking down content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU D1
Complaints enabled?: Yes
Status: Already implemented
Effective from: March 16, 2025

ICU D7
Appropriate action: Yes
Complaint process URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU G1
Terms of service URL: https://www.greenlaneassociation.uk/terms-of-use/
Status: Already implemented
Effective from: March 16, 2025

ICU G3
Clarity of terms of service: The clarity is good
Accessibility of terms of service: Accessibility is good
Status: Already implemented
Effective from: March 16, 2025

Harm #4 Hate

Hate Risk level: Low

Hate Risk factors considered:
3a Users can opt to put as much or as little as they want into their profile. Some use a personal photo, some use an avatar. It is possible for an individual to be targetted based on their profile info. If a user was to become a target for illegal harm, we have a complaints process and a terms of use that would result in the illegal harm being removed and the member banned.
4b The only user group is the entire membership of the association.
5d Commenting is 100% moderated by human moderators that follow our content policy. It would be difficult for messages of hate to be sent to an individual as all messages that are approved are visible to the entire membership.
5e Commenting is 100% moderated by human moderators that follow our content policy. It would be difficult for a hateful image or video to be posted to an individual as all messages that are approved are visible to the entire membership.

Hate Additional characteristics considered:
The association, by it's nature has enemies within certain groups. It is possible for them to spend their own money to join the association and attempt to post hateful content but it will be removed by our moderators and the culprit will be banned and reported to the authorities.

Hate Existing controls considered:
Our commenting system is 100% moderated by human moderators that follow our content policy.

Hate Evidence:
We have no evidence that hate has previously occurred on our comment system.

ICU A2
Name of accountable person: Chris Mitchell
Status: Already implemented
Effective from: March 16, 2025

ICU C1
Content moderation policy: https://www.greenlaneassociation.uk/content-policy/
Name of moderator assessing content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU C2
Name of moderator taking down content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU D1
Complaints enabled?: Yes
Status: Already implemented
Effective from: March 16, 2025

ICU D7
Appropriate action: Yes
Complaint process URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU G1
Terms of service URL: https://www.greenlaneassociation.uk/terms-of-use/
Status: Already implemented
Effective from: March 16, 2025

ICU G3
Clarity of terms of service: The clarity is good
Accessibility of terms of service: Accessibility is good
Status: Already implemented
Effective from: March 16, 2025

Harm #5 Harassment

Harassment Risk level: Low

Harassment Risk factors considered:
3a Users can opt to put as much or as little as they want into their profile. Some use a personal photo, some use an avatar. It is possible for an individual to be targetted based on their profile info. If a user was to become a target for illegal harm, we have a complaints process and a terms of use that would result in the illegal harm being removed and the member banned.
3a Fake user profiles: All of user profiles trace back to a membership account paid from a verified funding source. However, we have no control of other accounts created on disqus.com which could be fake.
4a The user has to take responsibility for their own actions when deciding to open a connection with another user on disqus.com . We have no control over who can or cannot make contact with another user on disqus.com .
5d Commenting is 100% moderated by human moderators that follow our content policy. It would be difficult for messages of hate to be sent to an individual as all messages that are approved are visible to the entire membership.
5e Commenting is 100% moderated by human moderators that follow our content policy. It would be difficult for a hateful image or video to be posted to an individual as all messages that are approved are visible to the entire membership.
5f Users can post location information relevant to a lane but it is usually of a position on a previous journey. Location information given in a comment will be moderated. If the location is not appropriate to the map it would be removed.
5g Our service does not have a built in method of making a message viral, in fact we discourage information about individual lanes from becoming viral as it often causes problems with over use. Members reposting info from other sites will have that information moderated. If it is appropriate it will be published, if not it will be removed.

Harassment Additional characteristics considered:
It may be possible to conduct a harassment campaign using disqus.com, if so, the administrators of disqus.com may be able to change the online identity of the individual to prevent further harassment. This is outside of our control.

Harassment Existing controls considered:
Our moderators are able to prevent harassment that may appear in posted comments before they are published.

Harassment Evidence:
We have no evidence of harassment occurring on TrailWise2 before.

ICU A2
Name of accountable person: Chris Mitchell
Status: Already implemented
Effective from: March 16, 2025

ICU C1
Content moderation policy: https://www.greenlaneassociation.uk/content-policy/
Name of moderator assessing content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU C2
Name of moderator taking down content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU D1
Complaints enabled?: Yes
Status: Already implemented
Effective from: March 16, 2025

ICU D7
Appropriate action: Yes
Complaint process URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU G1
Terms of service URL: https://www.greenlaneassociation.uk/terms-of-use/
Status: Already implemented
Effective from: March 16, 2025

ICU G3
Clarity of terms of service: The clarity is good
Accessibility of terms of service: Accessibility is good
Status: Already implemented
Effective from: March 16, 2025

Harm #6 Controlling or coercive behaviour

Coercion Risk level: Low

Coercion Risk factors considered:
3a Fake user profiles: All of user profiles trace back to a membership account paid from a verified funding source. However, we have no control of other accounts created on disqus.com which could be fake.
4a The user has to take responsibility for their own actions when deciding to open a connection with another user on disqus.com . We have no control over who can or cannot make contact with another user on disqus.com .
4b The only user group is the entire membership of the association.
5e Commenting is 100% moderated by human moderators that follow our content policy. It would be difficult for a coercion to take place.
5f Users can post location information relevant to a lane but it is usually of a position on a previous journey. Location information given in a comment will be moderated. If the location is not appropriate to the map it would be removed.

Coercion Additional characteristics considered:
Controlling behaviour is unlikely to occur on the comment system. Calls for volunteers to step forward to participate in lane maintenance or to complete a public consultation cannot be considered coercion as they are requests to participate as a member of our community. The member ultimately has a choice and we do not pressure any member to do so using the comment system in TrailWise2.

Coercion Existing controls considered:
As the comment system is 100% moderated by human moderators, it is unlikely that coercion would go undetected, and unlikely that it would occur.

Coercion Evidence:
We have no evidence of coercion taking place on the TrailWise2 comment system.

ICU A2
Name of accountable person: Chris Mitchell
Status: Already implemented
Effective from: March 16, 2025

ICU C1
Content moderation policy: https://www.greenlaneassociation.uk/content-policy/
Name of moderator assessing content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU C2
Name of moderator taking down content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU D1
Complaints enabled?: Yes
Status: Already implemented
Effective from: March 16, 2025

ICU D7
Appropriate action: Yes
Complaint process URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU G1
Terms of service URL: https://www.greenlaneassociation.uk/terms-of-use/
Status: Already implemented
Effective from: March 16, 2025

ICU G3
Clarity of terms of service: The clarity is good
Accessibility of terms of service: Accessibility is good
Status: Already implemented
Effective from: March 16, 2025

Harm #7 Drugs and psychoactive substances

Drugs Risk level: Low

Drugs Risk factors considered:
3a Users can opt to put as much or as little as they want into their profile. Some use a personal photo, some use an avatar. It is possible for an individual to be targetted based on their profile info. If a user was to become a target for illegal harm, we have a complaints process and a terms of use that would result in the illegal harm being removed and the offending member banned.
4a The user has to take responsibility for their own actions when deciding to open a connection with another user on disqus.com . We have no control over who can or cannot make contact with another user on disqus.com .
4b The only user group is the entire membership of the association.
5e Commenting is 100% moderated by human moderators that follow our content policy. It would be difficult for the sale of drugs to take place on the comment system.
7b All posts are moderated by a human before they are approved and displayed. Hyperlinks will be checked by the moderator.

Drugs Additional characteristics considered:
Whereas it might be possible to connect with other disqus.com members in order to buy or sell drugs, our moderators would notice if this was happening on the TrailWise2 comment system and remove that content.

Drugs Existing controls considered:
We have 100% moderation of comments by human moderators on TrailWise2. It is unlikely that the moderators would not be able to spot content of illegal harm within the comments submitted by members.

Drugs Evidence:
We have no prior evidence of drugs being bought or sold on the TrailWise2 comment system.

ICU A2
Name of accountable person: Chris Mitchell
Status: Already implemented
Effective from: March 16, 2025

ICU C1
Content moderation policy: https://www.greenlaneassociation.uk/content-policy/
Name of moderator assessing content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU C2
Name of moderator taking down content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU D1
Complaints enabled?: Yes
Status: Already implemented
Effective from: March 16, 2025

ICU D7
Appropriate action: Yes
Complaint process URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU G1
Terms of service URL: https://www.greenlaneassociation.uk/terms-of-use/
Status: Already implemented
Effective from: March 16, 2025

ICU G3
Clarity of terms of service: The clarity is good
Accessibility of terms of service: Accessibility is good
Status: Already implemented
Effective from: March 16, 2025

Harm #8 Firearms, knives and other weapons

Weapons Risk level: Negligible

Weapons Risk factors considered:
The OFCOM risk factors did not consider that our comments system had any risk factors regarding firearms, knives and other weapons. Marking this risk level as negligible.

Weapons Additional characteristics considered:
Our user base demographics is a majority of England resident, male adults. The only language that we use on TrailWise2 is English. We have members that live in other parts of the United Kingdom and overseas. We have no ability in TrailWise2 to accurately determine a user's adult age, sex or disability as the system does not collect or use that data . All users are treated equally. Our business model is to increase the size of our membership, increasing our financial resources. This enables us to repair lanes and bring legal action against those neglecting their duty to keep public rights of way open to the public without discrimination of the users. Our members are from all walks of life, covering a variety of adult age groups, and abilities. All messages on TrailWise2 are moderated. It is unlikely that any advertiser would be able to deviate our members from the topic of green laning.

Weapons Existing controls considered:
The comment system is 100% moderated by human moderators that follow our content policy. It is unlikely that weapons will be promoted, bought or sold using the TrailWise2 comment system.

Weapons Evidence:
We have no prior evidence of firearms, knives or other weapons being bought or sold through the TrailWise2 comment system.

ICU A2
Name of accountable person: Chris Mitchell
Status: Already implemented
Effective from: March 16, 2025

ICU C1
Content moderation policy: https://www.greenlaneassociation.uk/content-policy/
Name of moderator assessing content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU C2
Name of moderator taking down content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU D1
Complaints enabled?: Yes
Status: Already implemented
Effective from: March 16, 2025

ICU D7
Appropriate action: Yes
Complaint process URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU G1
Terms of service URL: https://www.greenlaneassociation.uk/terms-of-use/
Status: Already implemented
Effective from: March 16, 2025

ICU G3
Clarity of terms of service: The clarity is good
Accessibility of terms of service: Accessibility is good
Status: Already implemented
Effective from: March 16, 2025

Harm #9 Unlawful Immigration

Immigration Risk level: Low

Immigration Risk factors considered:
3a Users can opt to put as much or as little as they want into their profile. Some use a personal photo, some use an avatar. It is possible for an individual to be targetted based on their profile info. If a user was to become a target for illegal harm, we have a complaints process and a terms of use that would result in the illegal harm being removed and the offending member banned.
4b The only user group is the entire membership of the association.
5e Commenting is 100% moderated by human moderators that follow our content policy. It would be difficult for unlawful immigration to be depicted on the comment system.

Immigration Additional characteristics considered:
Our user base is predominantly UK nationals.

Immigration Existing controls considered:
Our comments system is 100% moderated by human moderators working to our content policy. No comment can be published until it is approved by a moderator.

Immigration Evidence:
We have no prior evidence of unlawful immigration on our comment system.

ICU A2
Name of accountable person: Chris Mitchell
Status: Already implemented
Effective from: March 16, 2025

ICU C1
Content moderation policy: https://www.greenlaneassociation.uk/content-policy/
Name of moderator assessing content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU C2
Name of moderator taking down content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU D1
Complaints enabled?: Yes
Status: Already implemented
Effective from: March 16, 2025

ICU D7
Appropriate action: Yes
Complaint process URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU G1
Terms of service URL: https://www.greenlaneassociation.uk/terms-of-use/
Status: Already implemented
Effective from: March 16, 2025

ICU G3
Clarity of terms of service: The clarity is good
Accessibility of terms of service: Accessibility is good
Status: Already implemented
Effective from: March 16, 2025

Harm #10 Human Trafficking

Trafficking Risk level: Low

Trafficking Risk factors considered:
3a Users can opt to put as much or as little as they want into their profile. Some use a personal photo, some use an avatar. It is possible for an individual to be targetted based on their profile info. If a user was to become a target for illegal harm, we have a complaints process and a terms of use that would result in the illegal harm being removed and the offending member banned.
4b The only user group is the entire membership of the association.
5e Commenting is 100% moderated by human moderators that follow our content policy. It would be difficult for human trafficking content to be published.
5f Users can post location information relevant to a lane but it is usually of a position on a previous journey. Location information given in a comment will be moderated. If the location is not appropriate to the map it would be removed. Hardly, useful for a human trafficker.

Trafficking Additional characteristics considered:
Our user base demographics is a majority of England resident, male adults. The only language that we use on TrailWise2 is English. We have members that live in other parts of the United Kingdom and overseas. We have no ability in TrailWise2 to accurately determine a user's adult age, sex or disability as the system does not collect or use that data . All users are treated equally. Our business model is to increase the size of our membership, increasing our financial resources. This enables us to repair lanes and bring legal action against those neglecting their duty to keep public rights of way open to the public without discrimination of the users. Our members are from all walks of life, covering a variety of adult age groups, and abilities. All messages on TrailWise2 are moderated. It is unlikely that any advertiser would be able to deviate our members from the topic of green laning.

Trafficking Existing controls considered:
We have 100% moderation of messages posted. A message must be approved by a moderator to be published. Illegal content will be stopped by the moderators.

Trafficking Evidence:
We have no prior evidence of human trafficking occurring on the TrailWise2 commenting system.

ICU A2
Name of accountable person: Chris Mitchell
Status: Already implemented
Effective from: March 16, 2025

ICU C1
Content moderation policy: https://www.greenlaneassociation.uk/content-policy/
Name of moderator assessing content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU C2
Name of moderator taking down content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU D1
Complaints enabled?: Yes
Status: Already implemented
Effective from: March 16, 2025

ICU D7
Appropriate action: Yes
Complaint process URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU G1
Terms of service URL: https://www.greenlaneassociation.uk/terms-of-use/
Status: Already implemented
Effective from: March 16, 2025

ICU G3
Clarity of terms of service: The clarity is good
Accessibility of terms of service: Accessibility is good
Status: Already implemented
Effective from: March 16, 2025

Harm #11 Sexual exploitation of adults

SEOA Risk level: Low

SEOA Risk factors considered:
3a Users can opt to put as much or as little as they want into their profile. Some use a personal photo, some use an avatar. It is possible for an individual to be targetted based on their profile info. If a user was to become a target for illegal harm, we have a complaints process and a terms of use that would result in the illegal harm being removed and the offending member banned.
5e Commenting is 100% moderated by human moderators that follow our content policy. It would be difficult for sexual exploitation of adults content to be published.

SEOA Additional characteristics considered:
Our user base demographics is a majority of England resident, male adults. The only language that we use on TrailWise2 is English. We have members that live in other parts of the United Kingdom and overseas. We have no ability in TrailWise2 to accurately determine a user's adult age, sex or disability as the system does not collect or use that data . All users are treated equally. Our business model is to increase the size of our membership, increasing our financial resources. This enables us to repair lanes and bring legal action against those neglecting their duty to keep public rights of way open to the public without discrimination of the users. Our members are from all walks of life, covering a variety of adult age groups, and abilities. All messages on TrailWise2 are moderated. It is unlikely that any advertiser would be able to deviate our members from the topic of green laning.

SEOA Existing controls considered:
Our comment system is 100% moderated. Messages must be approved by a moderator in order to be published.

SEOA Evidence:
We have no prior evidence of sexual exploitation of adults occurring on the TrailWise2 commenting system.

ICU A2
Name of accountable person: Chris Mitchell
Status: Already implemented
Effective from: March 16, 2025

ICU C1
Content moderation policy: https://www.greenlaneassociation.uk/content-policy/
Name of moderator assessing content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU C2
Name of moderator taking down content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU D1
Complaints enabled?: Yes
Status: Already implemented
Effective from: March 16, 2025

ICU D7
Appropriate action: Yes
Complaint process URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU G1
Terms of service URL: https://www.greenlaneassociation.uk/terms-of-use/
Status: Already implemented
Effective from: March 16, 2025

ICU G3
Clarity of terms of service: The clarity is good
Accessibility of terms of service: Accessibility is good
Status: Already implemented
Effective from: March 16, 2025

Harm #12 Extreme Pornography

Pornography Risk level: Low

Pornography Risk factors considered:
5e Commenting is 100% moderated by human moderators that follow our content policy.

Pornography Additional characteristics considered:
Our user base demographics is a majority of England resident, male adults. The only language that we use on TrailWise2 is English. We have members that live in other parts of the United Kingdom and overseas. We have no ability in TrailWise2 to accurately determine a user's adult age, sex or disability as the system does not collect or use that data . All users are treated equally. Our business model is to increase the size of our membership, increasing our financial resources. This enables us to repair lanes and bring legal action against those neglecting their duty to keep public rights of way open to the public without discrimination of the users. Our members are from all walks of life, covering a variety of adult age groups, and abilities. All messages on TrailWise2 are moderated. It is unlikely that any advertiser would be able to deviate our members from the topic of green laning.

Pornography Existing controls considered:
Our comment system is 100% moderated. All messages have to be approved to be published.

Pornography Evidence:
We have no prior evidence of extreme pornography on the TrailWise2 comment system.

ICU A2
Name of accountable person: Chris Mitchell
Status: Already implemented
Effective from: March 16, 2025

ICU C1
Content moderation policy: https://www.greenlaneassociation.uk/content-policy/
Name of moderator assessing content: Charlie Moore
Status: Already implemented: ICU C1 Effective from: March 16, 2025

ICU C2
Name of moderator taking down content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU D1
Complaints enabled?: Yes
Status: Already implemented
Effective from: March 16, 2025

ICU D7
Appropriate action: Yes
Complaint process URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU G1
Terms of service URL: https://www.greenlaneassociation.uk/terms-of-use/
Status: Already implemented
Effective from: March 16, 2025

ICU G3
Clarity of terms of service: The clarity is good
Accessibility of terms of service: Accessibility is good
Status: Already implemented
Effective from: March 16, 2025

Harm #13 Intimate Image Abuse

Intimate Image Abuse Risk level: Low

Intimate Image Abuse Risk factors considered:
1e All posts are moderated by a human before they are approved and displayed. Moderators follow our Content Policy. The risk is low for moderators missing an illegal post.
4b The only user group is the entire membership of the association. TrailWise2 does not have a feature for creating private user groups. The risk is negligible for the creation of private user groups.
4b The only group that can be messaged is the entire association. TrailWise2 only has one user group for members, the entire Green Lane Association membership. There is a separate user group for moderators and another for administrators. The risk is low for group messaging to be used for illegal content.
5g TrailWise2 does not have a feature of re-posting to make a message become viral. In fact, we discourage information about individual lanes from becoming viral as it often causes problems later with over use and damage.

Intimate Image Abuse Additional characteristics considered:
Our user base demographics is a majority of England resident, male adults. The only language that we use on TrailWise2 is English. We have members that live in other parts of the United Kingdom and overseas. We have no ability in TrailWise2 to accurately determine a user's adult age, sex or disability as the system does not collect or use that data . All users are treated equally.

Our business model is to increase the size of our membership, increasing our financial resources. This enables us to repair lanes and bring legal action against those neglecting their duty to keep public rights of way open to the public without discrimination of the users. Our members are from all walks of life, covering a variety of adult age groups, and abilities. All messages on TrailWise2 are moderated. It is unlikely that any advertiser would be able to deviate our members from the topic of green laning.

Intimate Image Abuse Existing controls considered:
The commenting system on TrailWise2 is moderated by human volunteers. Our moderators follow our Content Policy. Every message posted must be approved by a moderator in order for it to be displayed to others. We consider this to be 100% moderation. Posts are often delayed from publication due to the availability of moderators. We do not have an automated or 24x7 moderation system.

Intimate Image Abuse Evidence:
We have no prior evidence of the TrailWise2 commenting system being used to post illegal content.

ICU A2
Name of accountable person: Chris Mitchell
Status: Already implemented
Effective from: March 16, 2025

ICU C1
Content moderation policy: https://www.greenlaneassociation.uk/content-policy/
Name of moderator assessing content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU C2
Name of moderator taking down content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU D1
Complaints enabled?: Yes
Status: Already implemented
Effective from: March 16, 2025

ICU D7
Appropriate action: Yes
Complaint process URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU G1
Terms of service URL: https://www.greenlaneassociation.uk/terms-of-use/
Status: Already implemented
Effective from: March 16, 2025

ICU G3
Clarity of terms of service: The clarity is good
Accessibility of terms of service: Accessibility is good
Status: Already implemented
Effective from: March 16, 2025

Harm #14 Proceeds of Crime

Proceeds Risk level: Low

Proceeds Risk factors considered:
3a Users can opt to put as much or as little as they want into their profile. Some use a personal photo, some use an avatar. It is possible for an individual to be targetted based on their profile info. If a user was to become a target for illegal harm, we have a complaints process and a terms of use that would result in the illegal harm being removed and the offending member banned.
3a Fake user profiles: All of user profiles trace back to a membership account paid from a verified funding source. However, we have no control of other accounts created on disqus.com which could be fake.

Proceeds Additional characteristics considered:
Our user base demographics is a majority of England resident, male adults. The only language that we use on TrailWise2 is English. We have members that live in other parts of the United Kingdom and overseas. We have no ability in TrailWise2 to accurately determine a user's adult age, sex or disability as the system does not collect or use that data . All users are treated equally.

Proceeds Existing controls considered:
The commenting system on TrailWise2 is moderated by human volunteers. Our moderators follow our Content Policy. Every message posted must be approved by a moderator in order for it to be displayed to others. We consider this to be 100% moderation. Posts are often delayed from publication due to the availability of moderators. We do not have an automated or 24x7 moderation system.

Proceeds Evidence:
We have no prior evidence of the TrailWise2 commenting system being used to post illegal content.

ICU A2
Name of accountable person: Chris Mitchell
Status: Already implemented
Effective from: March 16, 2025

ICU C1
Content moderation policy: https://www.greenlaneassociation.uk/content-policy/
Name of moderator assessing content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU C2
Name of moderator taking down content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU D1
Complaints enabled?: Yes
Status: Already implemented
Effective from: March 16, 2025

ICU D7
Appropriate action: Yes
Complaint process URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU G1
Terms of service URL: https://www.greenlaneassociation.uk/terms-of-use/
Status: Already implemented
Effective from: March 16, 2025

ICU G3
Clarity of terms of service: The clarity is good
Accessibility of terms of service: Accessibility is good
Status: Already implemented
Effective from: March 16, 2025

Harm #15 Fraud and Financial Services

Fraud Risk level: Low

Fraud Risk factors considered:
3a Users can opt to put as much or as little as they want into their profile. Some use a personal photo, some use an avatar. It is possible for an individual to be targetted based on their profile info. If a user was to become a target for illegal harm, we have a complaints process and a terms of use that would result in the illegal harm being removed and the offending member banned.
3a Fake user profiles: All of user profiles trace back to a membership account paid from a verified funding source. However, we have no control of other accounts created on disqus.com which could be fake.
4a The user has to take responsibility for their own actions when deciding to open a connection with another user on disqus.com . We have no control over who can or cannot make contact with another user on disqus.com .
4b The only user group is the entire membership of the association.
4b The only group that can be messaged is the entire association.
5d Commenting is 100% moderated by human moderators that follow our content policy. It would be difficult for messages of hate to be sent to an individual as all messages that are approved are visible to the entire membership.
7b All posts are moderated by a human before they are approved and displayed. Hyperlinks will be checked by the moderator.

Fraud Additional characteristics considered:
Our user base demographics is a majority of England resident, male adults. The only language that we use on TrailWise2 is English. We have members that live in other parts of the United Kingdom and overseas. We have no ability in TrailWise2 to accurately determine a user's adult age, sex or disability as the system does not collect or use that data . All users are treated equally.

Fraud Existing controls considered:
The commenting system on TrailWise2 is moderated by human volunteers. Our moderators follow our Content Policy. Every message posted must be approved by a moderator in order for it to be displayed to others. We consider this to be 100% moderation. Posts are often delayed from publication due to the availability of moderators. We do not have an automated or 24x7 moderation system.

Fraud Evidence:
We have no prior evidence of the TrailWise2 commenting system being used to post illegal content.

ICU A2
Name of accountable person: Chris Mitchell
Status: Already implemented
Effective from: March 16, 2025

ICU C1
Content moderation policy: https://www.greenlaneassociation.uk/content-policy/
Name of moderator assessing content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU C2
Name of moderator taking down content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU D1
Complaints enabled?: Yes
Status: Already implemented
Effective from: March 16, 2025

ICU D7
Appropriate action: Yes
Complaint process URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU G1
Terms of service URL: https://www.greenlaneassociation.uk/terms-of-use/
Status: Already implemented
Effective from: March 16, 2025

ICU G3
Clarity of terms of service: The clarity is good
Accessibility of terms of service: Accessibility is good
Status: Already implemented
Effective from: March 16, 2025

Harm #16 Foreign Interference

Foreign Interference Risk level: Low

Foreign Interference Risk factors considered:
1e All posts are moderated by a human before they are approved and displayed. Moderators follow our Content Policy. The risk is low for moderators missing an illegal post.
3a Users can opt to put as much or as little as they want into their profile. Some use a personal photo, some use an avatar. It is possible for an individual to be targetted based on their profile info. If a user was to become a target for illegal harm, we have a complaints process and a terms of use that would result in the illegal harm being removed and the offending member banned.
3a Fake user profiles: All of user profiles trace back to a membership account paid from a verified funding source. However, we have no control of other accounts created on disqus.com which could be fake.
4a The user has to take responsibility for their own actions when deciding to open a connection with another user on disqus.com . We have no control over who can or cannot make contact with another user on disqus.com .
4b The only user group is the entire membership of the association.
5e Commenting is 100% moderated by human moderators that follow our content policy.
5g TrailWise2 does not have a feature of re-posting to make a message become viral. In fact, we discourage information about individual lanes from becoming viral as it often causes problems later with over use and damage.
7b All posts are moderated by a human before they are approved and displayed. Hyperlinks will be checked by the moderator.

Foreign Interference Additional characteristics considered:
Our user base demographics is a majority of England resident, male adults. The only language that we use on TrailWise2 is English. We have members that live in other parts of the United Kingdom and overseas. We have no ability in TrailWise2 to accurately determine a user's adult age, sex or disability as the system does not collect or use that data . All users are treated equally.

Foreign Interference Existing controls considered:
The commenting system on TrailWise2 is moderated by human volunteers. Our moderators follow our Content Policy. Every message posted must be approved by a moderator in order for it to be displayed to others. We consider this to be 100% moderation. Posts are often delayed from publication due to the availability of moderators. We do not have an automated or 24x7 moderation system.

Foreign Interference Evidence:
We have no prior evidence of the TrailWise2 commenting system being used to post illegal content.

ICU A2
Name of accountable person: Chris Mitchell
Status: Already implemented
Effective from: March 16, 2025

ICU C1
Content moderation policy: https://www.greenlaneassociation.uk/content-policy/
Name of moderator assessing content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU C2
Name of moderator taking down content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU D1
Complaints enabled?: Yes
Status: Already implemented
Effective from: March 16, 2025

ICU D7
Appropriate action: Yes
Complaint process URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU G1
Terms of service URL: https://www.greenlaneassociation.uk/terms-of-use/
Status: Already implemented
Effective from: March 16, 2025

ICU G3
Clarity of terms of service: The clarity is good
Accessibility of terms of service: Accessibility is good
Status: Already implemented
Effective from: March 16, 2025

Harm #17 Animal Cruelty

Animal Cruelty Risk level: Low

Animal Cruelty Risk factors considered:
4b The only user group is the entire membership of the association.
5d Commenting is 100% moderated by human moderators that follow our content policy. It would be difficult for messages of hate to be sent to an individual as all messages that are approved are visible to the entire membership.
5e Commenting is 100% moderated by human moderators that follow our content policy.

Animal Cruelty Additional characteristics considered:
Our user base demographics is a majority of England resident, male adults. The only language that we use on TrailWise2 is English. We have members that live in other parts of the United Kingdom and overseas. We have no ability in TrailWise2 to accurately determine a user's adult age, sex or disability as the system does not collect or use that data . All users are treated equally.

Animal Cruelty Existing controls considered:
The commenting system on TrailWise2 is moderated by human volunteers. Our moderators follow our Content Policy. Every message posted must be approved by a moderator in order for it to be displayed to others. We consider this to be 100% moderation. Posts are often delayed from publication due to the availability of moderators. We do not have an automated or 24x7 moderation system.

Animal Cruelty Evidence:
We have no prior evidence of the TrailWise2 commenting system being used to post illegal content.

ICU A2
Name of accountable person: Chris Mitchell
Status: Already implemented
Effective from: March 16, 2025

ICU C1
Content moderation policy: https://www.greenlaneassociation.uk/content-policy/
Name of moderator assessing content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU C2
Name of moderator taking down content: Charlie Moore
Status: Already implemented
Effective from: March 16, 2025

ICU D1
Complaints enabled?: Yes
Status: Already implemented
Effective from: March 16, 2025

ICU D7
Appropriate action: Yes
Complaint process URL: https://www.greenlaneassociation.uk/complaints/
Status: Already implemented
Effective from: March 16, 2025

ICU G1
Terms of service URL: https://www.greenlaneassociation.uk/terms-of-use/
Status: Already implemented
Effective from: March 16, 2025

ICU G3
Clarity of terms of service: The clarity is good
Accessibility of terms of service: Accessibility is good
Status: Already implemented
Effective from: March 16, 2025

Urgent messages

www.glass-uk.org

www.trailwise2.co.uk

Application Description

Consideration of illegal harms

Harm #1 Terrorism

Harm #2a CSAM

Harm #2b CSAM URL

Harm #2c Grooming

Harm #3 Encouraging or Assisting Suicide

Harm #4 Hate

Harm #5 Harassment

Harm #6 Controlling or coercive behaviour

Harm #7 Drugs and psychoactive substances

Harm #8 Firearms, knives and other weapons

Harm #9 Unlawful Immigration

Harm #10 Human Trafficking

Harm #11 Sexual exploitation of adults

Harm #12 Extreme Pornography

Harm #13 Intimate Image Abuse

Harm #14 Proceeds of Crime

Harm #15 Fraud and Financial Services

Harm #16 Foreign Interference

Harm #17 Animal Cruelty

Urgent messages