The Independent

https://www.independent.co.uk · 40/92 checks passed · media

Compliance report (framework 0.8)

Gate passed (every Core check must pass) · not counted towards the gate: paused 35, draft 48, ready for review 54.

Site level: 0 (no scored checks yet).

By level

LevelResult
Level 1 — Basic 24/37 (10 failed)
Level 2 — Enhanced 9/27 (12 failed)
Level 3 — Advanced 0/10 (4 failed)

By category

CategoryResult
Accessibility 7/13
Accountability 1/5
AI & Automation 3/8
Interoperability 1/3
Privacy 9/16
Provenance 0/2
Security 8/11
Transparency 4/13
Responsibility to the Future 0/3

Level 1 — Basic

Accessibility

FAIL Text alternatives for images
FAIL Decorative images properly marked

AI & Automation

Privacy

FAIL No tracking pixels
  • 63 1×1 third-party tracking pixels: https://experianmatch.info/log?pxl=1&fpid=&publisherid=MP001&dnt=null&domain=www.independent.co.uk&gdprApplies=true&tcString=CQi298AQi298AAGABCENCYFgAAAAAEPgAAwIAAARmgUAABgAUABYAFQALgAcABAACQAFQAMgAaAA9AB-AEwAJwAVQA_ACEAEcAOQAdwA8YCDgIQARYAkQBKQDOAG0APUAmQBVgC1gF5gMZAZIAywBtADgAHLAQTAjMAUEABAALAJEEgAgAXCgCQAFAAqAB6APEAhAB6gGMgOWAjMPAFAABAAUACoAHoAPwAnADxAPUAxkCMxAACASIhAHAAWAFUAPwA7gCUgG0AVYSAAgAkJgBQAAgGcAWsAxkBwBUAMAAEABQAKgFrAMZAjMWgBADuAVYAA.ILAMB5C5MQSFBKCJwIJoAQAQVwBgAIIAgAgAAAQABQBIQAIwEEAECAACAAAACAAIAAAAAIABIEABAAAAAAAABAAAAAEAAAAAAIAAAAAAAQABAAAAAAAAAUAAAAAAQAgAAgAAAQAIAQEgAAAAAAAAEIAAFAAAQAAAAAAAgQAAAAAAAgAgAkABAAAAAAAAAQBAAEAAAAAAAAIAAAAAAAAAAAAAAAAAAAACAAAAABAAAAAAABAA.YAAAAAAAAAAA, https://static.independent.co.uk/2026/04/18/11/52/2271200960-afp.jpeg?quality=75&width=640&crop=3%3A2%2Csmart&auto=webp, https://static.independent.co.uk/2026/04/17/16/2026-04-16T092634Z_1558189403_RC22QKA3BQRX_RTRMADP_3_UKRAINE-CRISIS-ATTACK-KYIV.jpg?quality=75&width=640&crop=3%3A2%2Csmart&auto=webp, https://static.independent.co.uk/2026/04/18/19/2026-04-18T183156Z_2062934730_UP1EM4I1FH6WU_RTRMADP_3_SOCCER-ENGLAND-TOT-BHA.jpg?quality=75&width=640&crop=3%3A2%2Csmart&auto=webp, https://static.independent.co.uk/2026/04/18/16/00/Paros-by-Charlotte-Hindle.jpeg?quality=75&width=640&crop=3%3A2%2Csmart&trim=287%2C0%2C49%2C0&auto=webp (+58 more).

Security

Transparency

Level 2 — Enhanced

Accessibility

Accountability

FAIL Published response timeframes
  • response_timeframe: The page provides contact emails and phone numbers but does not state when or how quickly queries will be answered.
    Fix: Add a clear statement of expected response times (e.g., 'We aim to respond within 5 business days') on the Contact Us page.
  • specific: No timeframes at all are mentioned, so none are specific in terms of days or hours.
    Fix: Publish specific numeric response windows for each contact channel (news desk, customer services, complaints) such as '48 hours' or '10 working days'.
FAIL Documented complaints process
  • steps_clear: The page tells users to use the Complaint Form for editorial issues but does not outline the actual steps, stages, or escalation path of the complaints process on this page.
    Fix: Add a brief numbered outline of the complaints procedure (submit form → acknowledgement → investigation → outcome → escalation to IPSO) directly on the Contact Us page.
FAIL Clear appeals process
  • appeals_exists: The page provides a Complaint Form and Code of Conduct links but does not describe a documented appeals process for contesting outcomes.
    Fix: Publish a clearly labeled appeals process explaining how users can challenge editorial or complaint decisions, including steps and timelines.
  • independent: There is no mention of an independent reviewer or escalation path (e.g., to IPSO or an external ombudsman) for appeals on this contact page.
    Fix: Add an escalation route to an independent body such as IPSO or an external ombudsman and link to it from the contact/complaints section.

AI & Automation

FAIL AI-assisted content clearly marked
  • marking_policy: The terms of use contain no policy or statement about marking or labeling AI-assisted content.
    Fix: Add a clear policy section stating how AI-assisted or AI-generated content will be labeled or disclosed to readers.
  • consistent: Because no AI content marking policy is mentioned, there is no evidence of consistent application across the site.
    Fix: Define and publish a consistent labeling convention (e.g., a standard byline or tag) applied uniformly to all AI-assisted articles.
FAIL Human oversight of AI documented
  • oversight_exists: The page does not document any human oversight of AI outputs used on the Website.
    Fix: Publish a statement describing that AI outputs are subject to human editorial oversight before publication.
  • review_process: No review or approval workflow for AI-generated content is described in the terms.
    Fix: Document the specific editorial review and approval steps AI-generated content must pass through before going live.
  • accountability: The terms do not identify any person, role, or team accountable for AI-generated content.
    Fix: Name a responsible editor, role, or team accountable for AI-generated content and include their contact details in the policy.

Interoperability

Privacy

FAIL Data collection limited to necessity
  • necessity: The notice does not state that data collection is limited to what is necessary; it instead describes broad uses including interest-based advertising and retargeting.
    Fix: Add an explicit data minimisation statement confirming that only data necessary for the stated purposes is collected.
  • proportionate: The notice describes extensive tracking including third-party retargeting, demographic inference, and social media ad matching without framing this as proportionate to the core service.
    Fix: Include a statement explaining how each category of data collection is proportionate to the service provided, and reduce or justify optional tracking like demographic inference.
FAIL Published data retention periods
  • retention_stated: The notice mentions that persistent cookies remain for a 'set period' but does not explicitly state retention periods for the data collected.
    Fix: Add a dedicated retention section stating how long cookie data and associated personal data are kept.
  • specific: Retention is described only vaguely (e.g., 'a set period of time specified in the cookie') with no specific durations given.
    Fix: Specify concrete retention periods (e.g., '13 months for analytics cookies', '30 days for session data') for each category of cookie or data.
FAIL No dark patterns in consent flows
  • no_dark_patterns: The notice uses manipulative framing by stating that withdrawing consent will result in access to the free service being revoked, pressuring users to consent.
    Fix: Remove coercive language tying consent withdrawal to loss of service, and allow users to reject non-essential cookies without penalty.
  • equal_choices: The page content shows no equally prominent reject option alongside accept; only a 'consent or pay' model is described, which does not present balanced accept/reject choices.
    Fix: Provide a clearly visible 'Reject All' button with equal prominence to the 'Accept All' option on the consent banner.
  • no_forced_consent: Consent is forced via a 'consent or pay' wall where users must either accept cookies or purchase a subscription to access content.
    Fix: Offer a genuine free option to decline non-essential cookies without requiring payment or bundling consent with access.
FAIL Cookie banner partner disclosure
  • banner_present: The page content only shows a notifications prompt ('Stay up to date with notifications from The Independent') and no cookie or consent banner is visible.
    Fix: Implement a visible cookie/consent banner on the homepage that appears on first visit and allows users to accept, reject, or manage cookie preferences.
  • partner_sharing_mentioned: There is no banner or on-page consent copy disclosing data sharing with third-party partners; only a generic privacy notice link is referenced.
    Fix: Add explicit disclosure within the consent banner stating that user data may be shared with third-party advertising and analytics partners, with a link to the full partner list.
  • partner_count_specific: No specific numeric count of partners is stated anywhere in the visible page content.
    Fix: Include a specific partner count (e.g., 'We and our [N] partners use cookies…') in the consent banner to meet transparency requirements.

Provenance

Security

Transparency

FAIL Algorithm explanation if applicable
  • algorithm_explained: The terms of use page does not mention or explain any algorithms or automated systems used by the Website.
    Fix: Add a section describing any algorithms used (e.g., for content recommendation, moderation, or personalization) and their purpose.
  • impact_clear: There is no description of how algorithmic decisions affect users on this page.
    Fix: Include a clear explanation of how algorithmic outputs influence what users see or experience on the site.
FAIL Annual data practices statement
  • annual_statement: The cookie notice contains no statement indicating it is reviewed annually or on any regular schedule.
    Fix: Add a sentence stating the frequency (e.g., annually) at which the cookie/privacy notice is reviewed and updated.
  • dated: The visible cookie notice shows no last-updated date, effective date, or version number.
    Fix: Include a clearly visible 'Last updated' date or version number at the top or bottom of the cookie notice.

Level 3 — Advanced

Accessibility

Accountability

FAIL Published moderation policies
  • criteria_clear: The page lists general prohibitions (offensive/defamatory usernames, illegal use, breach of community guidelines) but does not clearly articulate the specific moderation criteria applied to user content.
    Fix: Add a dedicated moderation criteria section (or link prominently to it) that enumerates the specific types of content that will be removed or result in account action.
  • enforcement: The Terms say accounts may be suspended or terminated at sole discretion but do not explain the enforcement workflow, notification, or appeals process.
    Fix: Document the enforcement steps (review, notice, suspension durations, appeal mechanism) so users understand how moderation decisions are made and contested.

Interoperability

Security

Transparency

FAIL Algorithmic decision criteria published
  • criteria_published: No specific criteria for any algorithmic decision-making are published on the page.
    Fix: Publish the specific inputs and criteria used by any algorithms that make decisions affecting users.
  • weighting: The page provides no information about how criteria are weighted or prioritized in any algorithmic process.
    Fix: Disclose the relative weighting or priority of each criterion used in algorithmic decisions.
  • auditable: The page lacks sufficient algorithmic detail to enable any external audit or review.
    Fix: Provide technical documentation or a transparency report with enough detail for independent auditors to review the algorithms.

Responsibility to the Future

FAIL Environmental / sustainability disclosure
  • disclosure_exists: The page is an environmental news section covering climate stories, but contains no published environmental impact or sustainability disclosure about the Independent's own operations.
    Fix: Publish a dedicated sustainability or environmental impact statement describing the organisation's own footprint and link it from the site footer.
  • specific_metrics: The page presents only third-party news headlines and offers no specific figures on the organisation's own carbon, energy use, or emissions.
    Fix: Include quantified metrics such as annual CO2 emissions, energy consumption, and reduction targets in a published sustainability report.
  • hosting_disclosure: There is no mention anywhere on the page of the carbon or energy profile of the website's hosting infrastructure.
    Fix: Add a statement disclosing the hosting provider's energy source and the carbon footprint of the site's infrastructure, ideally citing a green hosting certification.