Age Assurance

Why we verify age

neurobetter exists to support neurodivergent people with their mental health. Some of the topics we cover - including self-harm, suicidal ideation, eating disorders, and trauma - are sensitive and potentially distressing. We take our responsibility to protect everyone who uses our services seriously.

We verify the age of our users for three reasons.

It is the law. The Online Safety Act 2023 requires services like ours to assess whether children are likely to access our platform and, where they are, to take steps to protect them from harmful content. 1www.ofcom.org.uk/online-safety/protecting-children/age-checks-to-protect-children-online">Ofcom’s guidance sets out what “highly effective” age assurance looks like, and we follow it.

We want to serve young people too. In the future, we plan to offer services specifically designed for under-18s - including age-appropriate mental health content, peer support, and access to counsellors. To do that safely, we need to know who is a child and who is an adult, so we can tailor the experience and protections appropriately.

We care about vulnerable people. Many of the people who use neurobetter are neurodivergent, may be experiencing mental health difficulties, and may be vulnerable. Age assurance is one part of a broader safeguarding framework that helps us provide the right level of support to the right people. You can read more on our Safeguarding page.

What is age assurance?

Age assurance is a general term for methods used to check or estimate how old someone is. It includes age verification (confirming your exact age using a document or data source) and age estimation (estimating your age range using technology like facial analysis).

Ofcom requires that age assurance methods used to protect children are “highly effective” - meaning they meet four criteria:²

• Technical accuracy - the method correctly identifies whether someone is a child or an adult
• Robustness - the method cannot be easily bypassed or tricked
• Reliability - the method produces consistent results over time
• Fairness - the method does not discriminate against particular groups of people

We use providers and methods that meet these standards.

How we verify your age

We offer several ways to verify your age. You only need to complete one. All methods are designed to be quick, private, and accessible.

Luciditi (primary provider)

Our main age verification partner is Luciditi, a UK-based digital identity and age assurance provider. Luciditi offers four methods:

Face age estimation - Uses AI to estimate your age from a selfie photo. No documents are required. The image is processed in real time and then discarded - it is not stored. This is the quickest option.

Digital identity - Verifies your age through a digital identity provider such as GOV.UK digital identity. This provides the highest confidence level of verification.

Open banking - Confirms your age through a secure, read-only connection to your bank account, which holds verified date-of-birth data. No documents to upload, no images required.

ID document - You upload a photo of a government-issued ID (passport or driving licence). Luciditi processes the document and returns the result to neurobetter. The document image is not retained by neurobetter.

Yoti (secondary provider)

Yoti provides an additional verification option:

Digital ID via mobile app - You verify your age through the Yoti app on your phone. Yoti confirms your age to neurobetter without sharing your full date of birth.

Manual document upload (fallback)

If you are unable to use the automated methods above, you can upload a photo of a government-issued ID directly to neurobetter. A trained member of our team will review the document and confirm your age manually. This option exists to make sure no one is excluded from our services because of technology barriers.

Your privacy

We take data protection seriously. Our approach to age assurance follows the principles set out by both Ofcom and the Information Commissioner’s Office (ICO).

• We do not store identity documents. When you verify through Luciditi or Yoti, documents are processed by the provider and not retained by neurobetter.
• We collect the minimum data needed. When you verify with a third party provider, we only receive a confirmation of your age band (over 18 or under 18) - not your full date of birth.
• Your data is protected. All age verification data is encrypted in transit and at rest. We follow data protection by design principles as required under UK GDPR.
• You can choose your method. Different methods share different amounts of information. Face age estimation, for example, does not require any documents at all.

For full details, see our Privacy Policy.

Risk assessments

Under the Online Safety Act, neurobetter is required to carry out and maintain risk assessments relating to both illegal content and content that may be harmful to children.³

We have completed:

• A children’s access assessment to determine whether children are likely to access our services
• An illegal content risk assessment identifying risks of illegal content appearing on our platform
• A children’s risk assessment identifying risks to children from content on our services

These assessments inform how we design and operate our services, including the age assurance methods we use and the content safeguards we put in place.

If you would like to know more about our risk assessments, please contact us at team@neurobetter.org.

The law

The Online Safety Act 2023 is the UK’s primary legislation for regulating online services. It places duties on platforms like neurobetter to protect users - especially children - from harmful content.

Key provisions relevant to our services include:

• Part 3, Section 11 - requires user-to-user services likely to be accessed by children to carry out children’s risk assessments
• Part 3, Section 12 - sets out safety duties to protect children, including preventing children from encountering primary priority content harmful to children
• Part 3, Section 9 - requires all regulated services to assess risks of illegal content

Ofcom is the regulator responsible for enforcing the Act. Non-compliance can result in fines of up to 10% of global revenue or GBP 18 million (whichever is higher).⁴

For more information:

• Online Safety Act 2023 (full text)
• Ofcom: Age checks to protect children online
• Ofcom: Quick guide to highly effective age assurance
• Gov.uk: Online Safety Act explainer