The Times

https://www.thetimes.co.uk · 37/92 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 23/37 (14 failed)
Level 2 — Enhanced 8/27 (15 failed)
Level 3 — Advanced 0/10 (9 failed)

By category

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

Level 1 — Basic

Accessibility

FAIL WCAG 2.1 Level A automated testing
  • 5 WCAG 2.1 Level A violations reported by axe-core: aria-valid-attr-value, button-name, link-name, listitem, nested-interactive.
FAIL Valid semantic HTML structure
  • 5 WCAG 2.1 Level A violations reported by axe-core: aria-valid-attr-value, button-name, link-name, listitem, nested-interactive.

AI & Automation

FAIL AI use policy in place
  • policy_exists: The About Us page discusses editorial mission and key policies but contains no AI use policy or statement.
    Fix: Add a dedicated AI policy section or linked page outlining the organization's position on AI use in journalism.
  • scope_clear: The page does not mention AI at all, so the scope of AI use is not explained.
    Fix: Publish a clear statement describing where and how AI tools are used (e.g., content generation, translation, summarization) across The Times and Sunday Times.

Privacy

FAIL No tracking pixels

Security

FAIL HTTPS enforced
  • strict-transport-security: header not set on the response.

Transparency

Level 2 — Enhanced

Accessibility

Accountability

FAIL Published response timeframes
  • response_timeframe: The page lists phone opening hours but does not publish any response timeframe for emails, letters, or complaints.
    Fix: Add explicit response-time commitments (e.g., 'we aim to respond to emails within 5 business days') next to each contact channel.
  • specific: No specific response timeframes in days or hours are given for any contact method beyond phone line opening hours.
    Fix: Publish specific turnaround times such as '48 hours for complaints' or '5 working days for editorial inquiries' rather than leaving them unstated.
FAIL Documented complaints process
  • steps_clear: The page only lists email addresses for complaints without outlining the steps, required information, escalation path, or what to expect from the process.
    Fix: Include a clear step-by-step complaints procedure on this page (or a visible summary) covering how to submit, what details to include, acknowledgement, and escalation to IPSO.
FAIL Clear appeals process
  • appeals_exists: The contact page lists complaints email addresses but does not describe a documented appeals process for decisions.
    Fix: Add a clearly labeled appeals process section outlining the steps, timelines, and criteria for challenging editorial or service decisions.
  • independent: No mention of an independent reviewer or escalation path (e.g., IPSO) is provided for appeals on this page.
    Fix: Document an escalation route to an independent body such as IPSO and link to it from the contact/complaints section.

AI & Automation

FAIL Published AI use policy (detailed)
  • detailed_scope: The page contains no AI policy and therefore no detailed scope of AI use.
    Fix: Create an AI policy that enumerates specific editorial and operational use cases of AI with examples.
  • limitations: No AI limitations are acknowledged anywhere on the page.
    Fix: Include a section acknowledging known AI limitations such as hallucinations, bias, and inaccuracy risks.
  • safeguards: The page describes general editorial principles but no AI-specific safeguards or quality controls.
    Fix: Document AI-specific safeguards such as human editorial review, fact-checking workflows, and disclosure labels for AI-assisted content.
FAIL AI-assisted content clearly marked
  • marking_policy: The About page describes editorial mission and key policies but contains no policy for labelling or marking AI-assisted content.
    Fix: Add a clear statement to the Key Policies section describing how AI-assisted articles, images, or summaries are disclosed and labelled to readers.
  • consistent: Because no AI marking policy is stated, there is no evidence of consistent application of AI content labelling across the site.
    Fix: Publish and link to editorial standards showing uniform AI disclosure labels (e.g., bylines or tags) applied across all Times and Sunday Times content.
FAIL Human oversight of AI documented
  • oversight_exists: The page outlines editorial leadership and News Corp principles but does not document any human oversight process for AI outputs.
    Fix: Add an explicit statement describing how editors review AI-generated or AI-assisted material before publication.
  • review_process: No review or approval workflow for AI-generated content is described anywhere on the About page.
    Fix: Describe the step-by-step editorial review process for AI outputs, including fact-checking, editing, and sign-off responsibilities.
  • accountability: While editors and executives are named, none are identified as accountable for AI-generated content specifically.
    Fix: Name a specific role (e.g., Managing Editor or Head of Digital) responsible for AI governance and publishing accountability for AI-assisted output.

Interoperability

Privacy

FAIL No dark patterns in consent flows
  • equal_choices: The page references paying for non-personalised-ad-access but does not show any consent interface where accept and reject options could be compared for equal prominence.
    Fix: Ensure the consent banner (not shown on this terms page) offers a 'Reject All' button with equal visual prominence to 'Accept All' and link to it from the terms page.
  • no_forced_consent: The page alludes to a 'pay or consent' model ('how to pay for non-personalised-ad-access'), which bundles access to services with acceptance of personalised advertising.
    Fix: Offer a genuine free option to reject personalised advertising without requiring payment, so consent is freely given rather than conditioned on a paywall.
FAIL Advertising clearly labelled if present
  • ads_labelled: The About page contains no visible labelling or indication of advertising or sponsored content on the page.
    Fix: Add clear 'Advertisement' or 'Sponsored' labels to any promotional content and reference the site's advertising labelling policy on this page.
  • disclosure: There is no disclosure on the page about relationships between editorial content and advertisers or commercial partners.
    Fix: Include a statement (or link to a policy) disclosing how advertiser relationships are managed and distinguished from editorial content.
FAIL Cookie banner partner disclosure
  • banner_present: The extracted page content shows no visible cookie or consent banner text.
    Fix: Implement a visible cookie consent banner on the homepage that appears on first visit before non-essential cookies are set.
  • partner_sharing_mentioned: No on-page copy discloses data sharing with third-party partners.
    Fix: Add explicit language to the consent banner disclosing that user data may be shared with advertising and analytics partners, with a link to the full list.
  • partner_count_specific: No numeric count of partners is stated anywhere on the page.
    Fix: Include a specific numeric count of third-party partners (e.g., 'shared with 150 partners') in the consent banner with a link to the full vendor list.

Provenance

Security

Transparency

FAIL Funding disclosed with detail
  • detail: The page mentions subscriptions and historical advertising revenue but provides no amounts, percentages, or breakdown of funding categories.
    Fix: Add a funding breakdown showing approximate percentages or categories (e.g., subscriptions vs. advertising vs. other revenue) for the papers.
  • complete: The disclosure omits major funding streams such as advertising share, sponsored content, affiliate revenue (e.g., from Times Money Mentor), and parent-company support.
    Fix: Expand the disclosure to cover all major revenue streams including advertising, affiliate/commercial partnerships, events, and any parent-company cross-subsidies.
FAIL Algorithm explanation if applicable
  • algorithm_explained: The About page describes editorial mission and history but does not mention or explain any algorithms used on the site.
    Fix: Add a section describing any algorithms used (e.g., for content recommendation, personalization, or paywall decisions) and their purpose.
  • impact_clear: The page does not describe any impact of algorithmic decisions on users such as content ranking, personalization, or subscription prompts.
    Fix: Include a clear statement explaining how algorithmic decisions affect what users see or experience on the site.
FAIL Annual data practices statement
  • annual_statement: The About page makes no mention of any regular or periodic review of data/privacy practices.
    Fix: Add a statement describing how often the privacy/data practices are reviewed (e.g., annually) and link to the review record.
  • dated: No date or version information is provided for any data practices statement on this page.
    Fix: Publish a 'Last updated' date or version number alongside the privacy/data practices statement.

Level 3 — Advanced

Accessibility

FAIL Published accessibility statement
  • statement_exists: The page is an 'About Us' page covering editorial mission, history, and ownership, with no dedicated accessibility statement present.
    Fix: Create a dedicated accessibility statement page and link to it from the site footer and navigation.
  • known_issues: No accessibility statement exists on the page, so no known accessibility issues or limitations are acknowledged.
    Fix: Include a section in the accessibility statement listing any known conformance gaps or areas that do not yet meet WCAG standards.
  • remediation_timeline: There is no mention of any timeline or commitment for addressing accessibility issues anywhere on the page.
    Fix: Add a stated timeline or commitment describing when identified accessibility issues will be resolved.
  • feedback_channel: The page only references generic help and social media links but provides no accessibility-specific feedback mechanism with a response commitment.
    Fix: Provide a dedicated accessibility feedback contact (email or form) along with a stated response time commitment.

Accountability

FAIL Published moderation policies
  • enforcement: The page only states they reserve the right to remove content 'at any time and for any reason at our sole discretion' without explaining the enforcement process, appeals, or notification procedures.
    Fix: Add a section describing the moderation enforcement workflow, including how violations are detected, what notifications users receive, and any appeals process available.

Interoperability

Security

FAIL Incident response plan published
  • plan_exists: The About Us page covers editorial mission, policies, history, and ownership but contains no published incident response plan or policy.
    Fix: Publish a dedicated incident response plan or security policy page describing how the organization handles and manages security incidents.
  • notification_commitment: The page makes no commitment to publicly notify users of significant security or data incidents.
    Fix: Add an explicit statement committing to notify affected users and the public when a significant incident occurs.
  • timeframe: No timeframe for disclosing incidents to affected users is stated anywhere on the page.
    Fix: Specify a concrete disclosure timeframe (e.g., within 72 hours of confirming an incident) in the incident response policy.

Transparency

FAIL Algorithmic decision criteria published
  • criteria_published: No specific criteria for any algorithmic decision-making are published on the About page.
    Fix: Publish the specific criteria (e.g., recency, topic, reader history) that drive algorithmic decisions on the site.
  • weighting: The page provides no information about the weighting or priority assigned to any algorithmic criteria.
    Fix: Disclose how criteria are weighted or prioritized in algorithmic ranking or recommendation systems.
  • auditable: The page offers no technical detail, documentation, or contact route that would enable external audit of algorithmic systems.
    Fix: Provide sufficient algorithmic documentation or an audit contact/process so that independent reviewers can assess the systems.
FAIL Open source code or tech docs
  • open_source: The page does not link to any publicly available source code repositories for the site.
    Fix: Add a link to a public code repository (e.g., GitHub) for any open-source components of the site or state the code policy explicitly.
  • tech_docs: No technical documentation (APIs, data schemas, developer docs) is published or linked from the About page.
    Fix: Publish and link to technical documentation such as API references, RSS feed listings, or a developer portal from the About page.

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 for the site itself, nor any such link in the footer.
    Fix: Publish a dedicated sustainability or environmental impact statement for the website and link to it from the footer alongside the privacy and terms pages.
  • specific_metrics: No specific figures on the organisation's own carbon, energy use, or emissions appear anywhere on the page.
    Fix: Include quantified metrics such as annual carbon footprint, energy consumption, and emissions in a published sustainability report.
  • hosting_disclosure: There is no disclosure of the carbon or energy profile of the hosting infrastructure anywhere on the page.
    Fix: Add a statement describing the hosting provider's energy source and carbon profile, ideally citing green hosting certification or renewable energy usage.
FAIL Succession and continuity plan
  • plan_exists: The About page discusses company history, ownership, and mission but contains no published plan for what happens if the organisation fails or exits.
    Fix: Publish a succession or continuity plan describing what would happen to the titles and their operations in the event of closure, sale, or business failure.
  • data_and_content_fate: The page mentions digital subscriptions and archives but does not address what happens to user data or published content if the organisation ceases operating.
    Fix: Add a section explaining how subscriber data and the published journalistic archive would be preserved, transferred, or deleted should the organisation exit.
  • custodians_or_mirrors: No custodians, mirrors, or archive partners are identified to safeguard content in the event of failure, despite references to ownership under News UK.
    Fix: Name a designated archive partner, library, or custodian institution (e.g. a national archive) responsible for preserving and maintaining access to the content long-term.
FAIL Worker wellbeing policy
  • policy_exists: The Culture page and its footer contain no published policy on worker wellbeing or working conditions, only a generic 'Careers' link.
    Fix: Publish a dedicated worker wellbeing or working conditions policy and link to it from the site footer or About us section.
  • specific_commitments: There are no specific commitments regarding pay, hours, mental health, or benefits anywhere on the page.
    Fix: Add explicit commitments covering fair pay, working hours, mental health support, and employee benefits within a published policy.
  • accountability: No named role, committee, or oversight body is identified for worker conditions on the page.
    Fix: Designate and name an accountable owner or oversight body for worker wellbeing and publish their remit.