all of you, by design
Age Assurance Policy
Binder Community Limited · No. 17058768
Overview
Binder is for adults aged 18 and over. This policy explains how we seek to ensure only adults can access the Platform, in support of our Children’s Access Assessment and our obligations under the Online Safety Act 2023.
1. The standard: Highly Effective Age Assurance (HEAA)
We aim to use age assurance that is Highly Effectiveat correctly determining whether a user is a child, within the meaning of the Online Safety Act 2023 and Ofcom’s Highly Effective Age Assurance (HEAA) standard. Under that standard, age assurance is highly effective if it is technically accurate, robust, reliable and fair.
We do not rely on self-declaration of age alone. Self-declaration is not HEAA-compliant. Our method is described in section 2.
HEAA compliance:We are satisfied that the method described in section 2 (photographic identity document verification combined with biometric liveness check by Stripe Identity) constitutes Highly Effective Age Assurance within the meaning of Ofcom’s HEAA standard under the Online Safety Act 2023.
2. Our method: Stripe Identity
Age assurance is carried out using Stripe Identity (operated by Stripe Payments UK Ltd), which performs two checks:
• Document check: the user submits a government-issued photographic identity document (for example, a passport or driving licence), which is reviewed by Stripe Identity to verify that the user is aged 18 or over.
• Biometric liveness check: the user completes a biometric liveness check (facial scan) to confirm that the document belongs to the person presenting it and that a real person is present.
Together, these constitute a photographic ID verification with biometric liveness check. This combination satisfies Ofcom’s HEAA criteria: it is technically accurate (identity document reviewed by automated and human processes), robust (liveness check prevents spoofing), reliable (enforced at the database layer — see section 3), and fair (a human review route is available: see section 5).
2.1 Biometric data processing — data protection basis
The biometric liveness check involves the processing of biometric data within the meaning of Article 4(14) UK GDPR. This is special category data (Article 9(1)). The processing is carried out by Stripe Identity as our processor. Lawful bases relied on:
• Article 6(1)(c) UK GDPR: compliance with a legal obligation (Online Safety Act 2023, HEAA duty).
• Article 9(2)(g) UK GDPR: substantial public interest (safeguarding of children and individuals at risk: DPA 2018 Schedule 1, paragraph 18), supported by our Appropriate Policy Document.
2.2 Data minimisation — what Binder retains
Binder applies strict data minimisation to age-assurance data:
• Binder retains: a confirmed 18+ status and the date of verification for each user account.
• Binder does NOT retain: copies of identity documents, biometric data, or raw verification data.
• Stripe retains:identity document and biometric data in accordance with Stripe’s privacy policy and its own data retention controls. A written Article 28 data-processing agreement is in place with Stripe Payments UK Ltd.
This minimisation approach is consistent with our Privacy Policy, Data Retention Schedule and DPIA.
3. Technical enforcement
Age assurance is technically enforced in the Platform, not merely stated as a policy:
• Access to the Platform is gated on a verified 18+ status following onboarding. Unverified users cannot access age-restricted features or content.
• A database rule ensures that no account can be marked as age-verified unless a corresponding successful Stripe Identity check is recorded. This ‘every verified user passed a check’ invariant is enforced at the data layer — it cannot be circumvented by application-level changes.
• Age-restricted Dimension contexts (for example, romantic and work Dimensions) are parked by default pending age verification, and platform-wide age verification is the effective 18+ gate.
4. Data protection and retention
We minimise age-assurance data as described in section 2.2. The retention periods for our internal age-verification record are set out in our Data Retention Schedule. In summary:
• Confirmed 18+ status and verification date: retained for the duration of the account, and for a fraud-prevention / audit period after account deletion.
• Detected illegal content and moderation records: not retained on the Platform; minimum lawful record only, as set out in the Appropriate Policy Document and Data Retention Schedule.
5. Fairness, accessibility and human review
We seek to apply age assurance fairly and to avoid unlawfully excluding adults who are able to prove their age by legitimate means. In particular:
• An adult whose verification is declined may request human review of the decision.
• We take reasonable steps to accommodate users who face barriers to identity document verification (for example, Equality Act 2010 considerations).
This human-review right also supports the Article 22 UK GDPR safeguards applicable where automated processing has significant effects — although we are satisfied that our age-verification process does not engage Article 22 (verification is a pass/fail gate, not a decision about the user’s legal rights), the right to human review is provided regardless.
6. Re-verification and reports
We may re-verify age where there is reason to doubt that a user is 18 or over. We act on reports that a user may be under 18 (see our Community Guidelines and Privacy Policy). Where an account is removed on age grounds, we may retain limited identifiers to prevent the user re-registering (see Privacy Policy and Terms of Service).
7. Safeguarding — link to CSAM detection and reporting
Age assurance is one layer of our safeguarding framework. It operates alongside:
• Proactive CSAM detection: Microsoft PhotoDNA scans all uploaded images against databases of known illegal imagery before display (fail-closed). Confirmed matches are reported to the National Crime Agency (CEOP) under section 67 of the Online Safety Act 2023.
• Illegal Content Risk Assessment (ICSRA) and Children’s Access Assessment (CAA): maintained and reviewed in accordance with OSA obligations.
• Content moderation: automated and human review of reported content.
Together these measures form our OSA safeguarding stack. Our DPIA documents the risks and mitigations across all layers.
8. Record-keeping and review
We maintain this policy, our Children’s Access Assessment, and our DPIA as live documents, reviewed at least annually or following a material change to the Platform or to regulatory guidance. This policy is made available to Ofcom and the ICO on request.