Notice and Action Policy

Status: pre-launch DSA-aligned operational draft

Last updated: 25 July 2026

1. Scope

This policy explains how any individual or entity may report specific content believed to be illegal or contrary to Underground’s policies. It is designed around the notice-and-action principles applicable to hosting services under the EU Digital Services Act.

2. Accessible electronic mechanism

Before public beta, Underground must provide a clearly labelled electronic reporting mechanism that:

is easy to access and user-friendly;
permits reports without requiring the reporter to become a customer;
accepts exact URLs or stable content identifiers;
confirms receipt electronically;
allows the reporter to provide the information listed below;
records the outcome and processing timestamps.

3. Required notice information

A notice should contain:

1. a sufficiently substantiated explanation of why the information is allegedly illegal or policy-violating;

2. the exact electronic location, URL or stable identifier;

3. the reporter’s name and email address, except where law permits or requires anonymous reporting;

4. a good-faith statement that the information is accurate and complete;

5. category of alleged illegality or policy breach;

6. supporting evidence reasonably available to the reporter.

Notices concerning imminent threats, child sexual abuse material, trafficking, terrorism or other serious offences may require immediate escalation to law enforcement or specialist channels.

4. Triage

Reports are triaged based on:

specificity and substantiation;
apparent severity and urgency;
risk to persons or evidence;
whether the reported content is accessible in the EU;
whether the report concerns law, Platform policy or both;
previous related reports or enforcement.

Incomplete reports may be closed or returned for clarification unless the available information already creates a credible risk requiring action.

5. Available measures

Possible measures include:

no action;
reduced visibility or recommendation exclusion;
age or access restriction;
temporary disablement;
removal;
upload or interaction restriction;
account suspension or termination;
evidence preservation;
referral to authorities where required.

Measures should be proportionate, consistent and limited to what is reasonably necessary.

6. Notifications and statement of reasons

Where contact information is available, Underground will confirm receipt and communicate the outcome to the reporter as required by law.

Where required and reasonably possible, an affected user will receive a clear statement identifying:

the content or account measure;
whether the decision was based on law, Terms or both;
the main facts and grounds;
whether automated means materially contributed;
the territorial scope and duration;
available review or complaint routes.

Information may be withheld where disclosure would create a safety risk, compromise an investigation or violate law.

7. Internal review

Affected users and, where applicable, reporters may request review through the published complaint channel. Review should be performed by a person not solely responsible for the original decision where operationally possible.

A request should explain the alleged error and include new evidence. Repetitive or abusive requests may be closed without full reassessment.

8. Trusted flaggers and authority orders

Notices from entities formally designated as trusted flaggers under applicable law receive the priority and treatment required by law. Orders from competent judicial or administrative authorities are handled through a verified legal channel.

9. Transparency and records

Underground will maintain records sufficient to demonstrate receipt, assessment, measures, reasons, review and timing. Transparency reporting obligations will be reassessed as the service grows; applicable exemptions for micro or small enterprises must be documented rather than assumed.

10. No general monitoring obligation

This policy does not create a general obligation to monitor all stored information or actively seek unlawful activity. Underground may nevertheless conduct targeted, voluntary and proportionate moderation consistent with law and fundamental rights.