Eligible entity criteria and procedural requirements for super-complaints under the Online Safety Act regulatory framework consultation

Thank you for the opportunity to respond to the consultation on eligible entity criteria and procedural requirements for super-complaints under the Online Safety Act. Our response to this consultation focuses on the eligible entity criteria.

Trust Alliance Group was formed in 2022 and comprises of several businesses that were previously part of Ombudsman Services including Energy Ombudsman, Communications Ombudsman, Flexible Resolution Services and Lumin (a software company). We also have a company called The Internet Commission which promotes ethical business practice to counter hate speech, abuse, fraud, algorithmic bias, and misinformation, whilst protecting privacy and freedom of expression.

Our purpose is to build, maintain and restore trust and confidence between consumers and businesses and we’re developing diverse capabilities and expertise in a range of areas including digital alternative dispute resolution and case management technology.

Q1:To what extent do you agree or disagree that the following criteria should be used to assess which organisations can submit super-complaints?

We agree with the proposed eligible entity criteria set out. It is right that organisations should demonstrate integrity and impartiality. We would expect any organisation taking on such a role to be ethical and demonstrate a strong commitment to improving consumer outcomes.

It is important that the any eligible entities have expertise in, and experience of issues relating to online safety, demonstrated through relevant publications and high quality research. In addition to that, it makes sense that the organisation should have a strong track record of working effectively and collaboratively with other stakeholders, including Ofcom.

We think that the regulatory landscape does benefit from having both super-complainants working effectively with regulators and independent bodies which resolve disputes between providers and consumers, and other industry stakeholders. In particular, we would expect that a super-complainant would be able to work closely with Alternative Dispute Resolution providers in collating their evidence.