CSAM Policy

PawrPose Banner

1. Introduction

The purpose of this policy is to ensure that Pawrpose LLC’s platform (mobile application and website) is not used to disseminate, store, or facilitate the exchange of Child Sexual Abuse Material (CSAM). This policy establishes globally applicable principles, responsibilities, and operational practices to prevent, detect, and report CSAM in compliance with international legal obligations and human rights standards.

2. Scope

This policy applies globally to all users, employees, contractors, and third-party service providers associated with Pawrpose LLC. It covers all infrastructure, content, and interactions occurring via Pawrpose’s app, website, and backend systems, regardless of the user’s or employee’s geographic location.

3. Policy Statement

Pawrpose LLC strictly prohibits any form of Child Sexual Abuse Material (CSAM) on its platforms. As a global company, we comply with national laws in all jurisdictions where we operate and align with international efforts to combat child exploitation.

We maintain a zero-tolerance policy for CSAM, including:

  • Proactive detection and takedown of CSAM across our services.
  • Immediate reporting to legally designated national hotlines or agencies (e.g., NCMEC in the U.S., IWF in the UK, INHOPE network globally).
  • Real-time removal of illegal content and banning of associated user accounts.
  • Transparent cooperation with law enforcement and child protection agencies worldwide.

4. Key Definitions

  • CSAM: Any content that sexually exploits or abuses children, including images, videos, audio, text, and deepfake/AI-generated content.
  • UGC: User-Generated Content created or uploaded by platform users.
  • Designated Authority: The national body responsible for receiving and investigating CSAM reports (e.g., NCMEC, IWF, eSafety Commissioner).
  • INHOPE: A global network of hotlines that combat online CSAM.

5. International Legal Compliance

Pawrpose will comply with, but is not limited to, the following regulations and frameworks:

  • United States: 18 U.S.C. § 2258A, COPPA, and DOJ/FBI enforcement cooperation.
  • European Union: GDPR (with lawful basis for data processing in CSAM detection), Digital Services Act (DSA), and E-Privacy Directive.
  • United Kingdom: Online Safety Act (2023) and IWF protocols.
  • Canada: Mandatory reporting under the Protecting Children from Internet Predators Act.
  • Australia: Online Safety Act (2021), reporting via eSafety Commissioner.
  • Global: UN Convention on the Rights of the Child (UNCRC), INTERPOL alerts, and INHOPE international cooperation.

6. Detection and Prevention Controls

Pawrpose LLC uses a layered approach to detect and prevent CSAM:

  • Hash Matching: Use of globally maintained hash databases (e.g., PhotoDNA, Project Arachnid) to detect known illegal material.
  • AI-Based Detection: Use of AI/ML tools for identifying potentially abusive or manipulated content.
  • Manual Moderation: Review of flagged high-risk content by trained moderation teams.
  • Keyword Filtering: Identification of risky behaviors or terminology in chats or descriptions.
  • User Flagging Tools: In-app and on-site reporting functions that allow users to report suspected CSAM.

7. Incident Handling and Reporting

Any CSAM-related incident will be handled under strict protocols:

  1. Immediate Quarantine: Suspected content is isolated and access revoked.
  2. Internal Escalation: Content is flagged to the Security & Trust and Legal teams within one hour.
  3. External Reporting:
    • U.S.: Report to NCMEC within 24 hours.
    • UK: Notify the IWF immediately.
    • EU: Notify competent data protection authority and national CSAM hotline.
    • Other jurisdictions: Follow country-specific mandatory reporting requirements, often through INHOPE-affiliated hotlines.
  4. Evidence Handling: Logs, metadata, and evidence are encrypted and retained in accordance with jurisdictional requirements, typically 90–180 days.

8. Account Enforcement Measures

Accounts involved in CSAM violations will be:

  • Permanently banned.
  • Device and IP banned where feasible.
  • Reported to law enforcement with all relevant data.
  • Notified only if it will not compromise investigations.

9. Employee and Moderator Responsibilities

  • Employees must immediately escalate any suspected CSAM to designated internal channels.
  • Trust & Safety moderators will receive specialized trauma-informed training to handle CSAM content safely and responsibly.
  • Mandatory annual CSAM handling and detection training is required for all relevant roles.

10. Third-Party Platform & Vendor Compliance

Any third-party service providers (e.g., hosting, content moderation services, analytics) must comply with this policy and have equivalent controls for CSAM detection, reporting, and escalation. Contracts must include clauses on CSAM prevention obligations.

11. Data Privacy & Human Rights Considerations

  • All CSAM processing activities are carried out under applicable lawful bases such as legitimate interest, legal obligation, or vital interest.
  • Only the minimum data necessary will be processed and shared externally.
  • All processing respects privacy and due process rights under GDPR, CCPA, and other privacy laws.
  • Special consideration is given to automated flagging accuracy, with human review to prevent false positives.

12. Policy Violations

Any employee found violating this policy or failing to escalate suspected CSAM will face disciplinary actions up to and including termination and referral to law enforcement.

Users violating the policy will be permanently banned and reported to authorities without exception.

13. Policy Review & Updates

This policy will be reviewed at least annually, or immediately in response to:

  • Changes in applicable law.
  • Recommendations from international child protection bodies.
  • Advancements in CSAM detection technologies.

Updates will be communicated to all staff and integrated into mandatory training refreshers.

Translate »

Latest Pet Listings On Our App

Download Our App Now!

Download our app, create your profile, and we’ll donate €1 to a shelter—helping animals in need with just a few taps. Start making an impact today!

For Latest Updates, Subscribe to our Newsletter Now!