This is a web page hosted on Amazon S3: a major file-sharing service. As an internet service which allows users to upload content, such as messages and images, and allows other users to encounter that content, S3 is a "user-to-user service" under the UK Online Safety Act. Since S3 is broadly used throughout the UK (including by the UK government) it likely "has links with the United Kingdom", and ought to qualify as a "regulated user-to-user service". Note that under the OSA, a "user" of the service can be any visitor; "it does not matter whether a person is registered to use a service."
This web page also displays a pornographic image. Like all content on S3, it does not require any form of age assurance to view it. It would appear that Amazon S3 is therefore in breach of its safety duty under the OSA to implement highly effective age assurance to control access to pornographic user-to-user content.
As the UK telecommunications regulator, Ofcom has launched a series of investigations into file-sharing services and other services which allow pornography, which may ultimately culminate in fines of up to 18 million pounds, 10% of worldwide revenue, or forcing UK ISPs to block those services. The question is whether Ofcom is willing to take these actions against Amazon—potentially breaking a good swath of the UK internet in the process.
As a major file-sharing service, S3 is positively chock-full of pornography. Here, for example, is a fisting photograph from Robert Mapplethorpe's X Portfolio, helpfully uploaded by Sotheby's. Mapplethorpe's art famously spurred a cultural and legal struggle over obscenity law and censorship in the USA, paving the way for broader artistic expression. As a fellow leatherman (but far less-talented photographer) I hope this work can follow in his footsteps.
Sincerely,
—Kyle Kingsbury
