Age Verification Policy

PRE-LAUNCH NOTICE: This page is a working draft covering a transitional state. The honest disclosure of the current click-through gate (§3) and the planned move to an Ofcom-accredited "highly effective" vendor (§4) both require specialist counsel sign-off before this is the live policy. A regulated UK media or T&S solicitor must confirm the framing of "transitioning", the lawful-basis statement, and the vendor data-processing summary. Remove this notice after sign-off.

1. Why We Age-Verify

MintedModels is an 18+ platform. Some sections of the site contain or relate to adult material. The UK Online Safety Act 2023 ("OSA"), in particular Part 5 (services publishing pornographic content) and related duties under Part 3, requires us to take steps to prevent under-18s from encountering adult content. Beyond the statutory duty, we believe keeping minors out of an adult marketplace is a baseline ethical commitment.

2. What Ofcom Means by "Highly Effective"

Ofcom's guidance on age assurance describes a "highly effective" check as one that is technically accurate, robust, reliable, and fair. In practice, self-declaration ("tick a box to confirm you are 18") is not highly effective. Highly-effective methods include:

• Photo-ID + liveness check (passport, driving licence) processed by an accredited vendor.
• Open-banking age verification (a regulated bank confirms the account holder is 18+).
• Mobile-network operator age check.
• Facial age-estimation technology that meets Ofcom's accuracy thresholds.
• Credit-card check combined with one of the above.

We will adopt one or more of these methods through an accredited vendor. The vendor must hold an independent "highly effective" certification or pass an Ofcom equivalence test.

3. Current State — Honest Disclosure

Today MintedModels uses a click-through age gate — you confirm you are 18 by pressing a button. This is not a "highly effective" check by Ofcom's standard. We are telling you this plainly because hiding it would be wrong, and because Ofcom's transparency duty (OSA s.71) requires us to.

We mitigate the limitations of the click-through gate with the following controls:

• The gate is required on every adult-content page for un-authenticated visitors.
• Adult content is hidden by default in directory listings until users opt-in.
• Account registration requires a date-of-birth field validated against an 18+ minimum both client-side and server-side.
• Uploaded content is moderated before being publicly visible, with adult-content tags applied at upload time and re-checked by human reviewers.
• Reports of suspected underage users are treated as a top-priority complaints category — see /legal/complaints.

We are transitioning to highly effective age assurance and we have a scheduled programme of work to do so — see §4 below. We are not claiming to be compliant with the OSA Part 5 viewer-side duty under the click-through gate alone.

4. Future State — Accredited Vendor

Before we open adult areas to the public, we will integrate an Ofcom-accredited age-assurance vendor (e.g. Yoti or equivalent). All access to adult content will then require either:

• A valid age-assurance pass token issued by the vendor (typically valid 12 months); or
• Re-verification on demand if any signal suggests the account has changed hands.

The launch date for vendor integration will be published here when fixed. Until then, adult-area access is restricted to private testing and pre-approved beta cohorts.

5. Data Minimisation

Where we use a third-party vendor, the goal is that MintedModels never sees your ID document, your face image, or your bank details. The vendor processes the source material under its own privacy policy and returns to us a minimal verification token containing:

• A pass / fail signal (you are 18+ or you are not).
• The method used (e.g. "photo-ID + liveness").
• A timestamp and a vendor reference ID we can use for audit.

This token is the only piece of age-assurance data MintedModels stores against your account. The vendor handles ID retention under its own data-processing agreement, which is reviewed by us before integration.

6. Lawful Basis Under UK GDPR

We rely on the following lawful bases under UK GDPR for age-assurance processing:

• Article 6(1)(c) — legal obligation. The OSA Part 5 statutory duty obliges us to age-verify users for adult-content access.
• Article 6(1)(f) — legitimate interests. For the operational run-time of the check (passing the token between vendor and us, storing the pass/fail flag).
• Article 9(2)(g) — substantial public interest. Where the vendor processes biometric data (e.g. facial age estimation), this special category is processed under the substantial-public-interest condition aligned with statutory child-safety duties.

The vendor is a data processor acting under our written contract (Article 28 DPA). We retain the role of data controller for the verification result.

7. Your Rights

All UK GDPR rights apply. In particular:

• You can re-verify. If your initial check fails (false negative, changed appearance, expired ID), you can re-attempt or use an alternative method. Manual review is available on request to safety@mintedmodels.com.
• You can object to a method. If you do not want to use a particular method (e.g. facial age estimation), an alternative method must be available and we will route you to it.
• You can request deletion. Of the verification token we hold against your account at any time. If you do, your access to adult areas will be revoked until a new check is passed.
• You can complain to the ICO. ico.org.uk if you believe your data has been mishandled.

8. Under-18 Redirect

If a check fails or you confirm you are under 18, we redirect you to a safe-exit landing page. We do not retain personal data from a failed check beyond what is needed to prevent the same account from re-attempting before any cooldown lapses. Children or young people who need support can contact Childline free on 0800 1111.

9. Related Policies

• Privacy Policy — how we handle personal data generally.
• Complaints & Reporting — how to report a suspected underage user or any other safety concern.
• Terms of Service — the eligibility rules that bind every account.

10. Updates

This policy will change when we move from the click-through gate to the accredited vendor. The transition will be flagged on this page and notified to active users by email. The "Last updated" date above is authoritative.