Act on orders from authorities within their deadline

How to do it

Article 9 of the Digital Services Act covers orders to act against illegal content, and Article 10 covers orders to give information about a user. For both, tell the authority without undue delay whether and when you acted. Under Article 9(5), tell the user at the latest when you act, with the reasons, the ways to appeal and the order's territorial scope. The terrorist content regulation, (EU) 2021/784, is stricter. A hosting service must remove or block the content within one hour of receiving a removal order. It must also name a contact point for these orders. So the address must page someone at night, as Escalate when nobody answers arranges for outages. Each order becomes a severity 1 case in the one moderation queue. Publish the contact point as the tier rule says.

Examples

JavaScript example

const REMOVAL_ORDER_LIMIT_MS = 60 * 60_000;

export const orderProblems = (order, now = Date.now()) => [
  ...(!order.actedAt && now - Date.parse(order.receivedAt) > REMOVAL_ORDER_LIMIT_MS ? ['removal order past one hour'] : []),
  ...(order.actedAt && !order.authorityToldAt ? ['authority not told'] : []),
  ...(order.actedAt && !order.userToldAt ? ['user not told'] : []),
];

Python example

from datetime import datetime, timedelta, timezone

REMOVAL_ORDER_LIMIT = timedelta(hours=1)

def order_problems(order: dict, now: datetime | None = None) -> list[str]:
    now = now or datetime.now(timezone.utc)
    problems = []
    if not order.get("acted_at") and now - order["received_at"] > REMOVAL_ORDER_LIMIT:
        problems.append("removal order past one hour")
    if order.get("acted_at") and not order.get("authority_told_at"):
        problems.append("authority not told")
    if order.get("acted_at") and not order.get("user_told_at"):
        problems.append("user not told")
    return problems

How to check

A test sends a removal order to the orders address outside office hours. A person acknowledges it within 15 minutes, and the item is blocked within 60 minutes. The case record holds the reply to the authority and the notice to the user, each with a time.

Sources

• Digital Services Act Articles 9 and 10
• Regulation (EU) 2021/784 on terrorist content online

Related rules

• TNS-4 Work the queue in order of harm and deadline in Trust and safety
• OPS-22 Escalate when nobody answers in Operations and observability
• TNS-3 Gather every report and flag in one queue in Trust and safety
• CMP-62 Decide which Digital Services Act tier you are in in Compliance and governance