U.S. TAKE IT DOWN ACT PROCESS - REQUIRED BEFORE IMAGE/VIDEO UGC

Status: P0 LAUNCH BLOCKER IF TCM ENABLES USER-UPLOADED IMAGE/VIDEO FOR U.S. USERS.

Section 3 of the TAKE IT DOWN Act is enforced by the FTC from 19 May 2026. Covered platforms must offer a clear, conspicuous, plain-language process for valid requests to remove covered non-consensual intimate visual depictions. On a valid request, covered content and known identical copies must be removed within 48 hours. [S17]

1. Product gate

Until this process is technically and operationally live, disable user-uploaded photo/video UGC for U.S. users. Text-only TCM can launch separately if all other gates are met.

2. Required public entry point

Add a clearly visible link: REPORT INTIMATE IMAGE / TAKE IT DOWN at Pending before live: URL. Do not hide it only inside generic Terms.

3. Request fields

Collect only what is necessary:

• requester name/contact or authorised representative information;
• identification of the affected person and representative authority if applicable;
• exact TCM URL/ID and enough information to locate the depiction;
• statement that the depiction is intimate and was published without consent / otherwise within TIDA coverage;
• good-faith attestation and required statutory declarations;
• minimal age information if needed to apply the law;
• do not require the victim to re-upload intimate imagery where the URL/record already lets TCM locate it.

4. Internal workflow and SLA

• timestamp request immediately;
• auto-acknowledge with case ID;
• triage as priority safety/legal queue;
• validate request without unnecessary delay;
• if valid: disable/remove covered depiction ASAP and no later than 48 hours;
• identify and remove known identical copies as required;
• preserve only legally necessary evidence with restricted access;
• record decision, timestamps, operator, hashes/identifiers used and communications;
• notify requester of completion or a specific deficiency;
• route suspected child sexual abuse material to the legally required specialist/law-enforcement reporting process with U.S. counsel guidance.

5. Privacy/safety design

Do not expose the victim's identity to the uploader unless legally required. Limit reviewers. Never put intimate images in general support tickets, analytics or training datasets.

Enforcement risk. FTC guidance states TIDA compliance is enforceable under the FTC Act framework. This policy must be validated by U.S. counsel before visual UGC launch. [S17]