A woman whose intimate images were posted online without her knowledge or consent is taking her fight for justice to Ofcom, challenging the media watchdog to use its new Online Safety Act powers to save her and others from further violation.
The woman, who we have called Jane, was informed by a friend that intimate photos of her were on an “anonymous” image-based board website, one of several sites where images of women and girls are “traded” and “shared” between users, many of whom leave derogatory and threatening comments, including of rape.
Jane wants Ofcom to take action under the Online Safety Act to investigate the site, to hold it to account for the dissemination of her intimate pictures without her consent and to prevent the images of her and other women and girls being shared any further.
She is one of a group of women from the same area in the UK whose photos and videos have been shared on the online image board accused of fostering a “collector culture” as anonymous users post sexual and explicit photos.
The images appear to have been obtained when some of the women’s personal Facebook and Snapchat accounts were hacked in 2022. At the time several of the women were aged under 18 and intimate images of them as minors were posted on the forum.
The hacking was reported to the social media platforms and passwords were changed, but only late last year did the women whose accounts had been hacked discover that their personal images, including explicit material relating to girls under 18 years old, had been posted on the forum.
The site is notorious for hosting intimate images of women without their consent. The images are searchable by specific categories such as university residence hall, school, or local area, and are often uploaded together with identifying personal data including full names, schools, relatives and links to social media profiles. The comments on the images frequently contain vulgar and misogynistic slurs and encourage users to upload more intimate images of particular women.
Jane’s images were shared alongside her full name and were “grouped” in a thread with images of the other women whose images had been hacked, according to their location. The thread includes comments from anonymous users asking for more images of the women by name/and or personal details.
Since then, Jane and some of the other women have been approached via social media by men who it is understood have seen the videos and photographs online. Comments have been posted on the forum and Jane suspects many of the comments are from local men, who have identified the women and where they live. The site hosts thousands of similar forums, on which threats have been identified including of rape to the women pictured.
Jane took the matter to the police, but they have been of little help and even warned her off researching where her personal pictures may have been shared because they said that would put her at risk of breaking the law.
Now Jane is represented by law firms Leigh Day and Mishcon de Reya in her fight to hold the forum and its users to account and to regain control of her own pictures.
The legal team says publicly accessible information indicates that the site is responsible for numerous police reports over a period of several years. Repeated concerns have been raised about the presence of intimate images being shared without the subject’s consent and the presence of sexual images and videos of children.
Even though each of the women made a report to her local police force and a police investigation was led by a regional police force, the legal team understands that the complaints have all been closed, with police citing a lack of evidence and insufficient avenues for investigation.
The Revenge Porn Helpline gave assistance by way of reverse image searches and contacting a number of the sites hosting the images directly.
Leigh Day human rights team partner Tessa Gregory has written to Ofcom on Jane’s behalf, challenging the media and communications watchdog to use its extensive enforcement powers, granted recently under the Online Safety Act, against service providers that perpetrate harm against women and girls.
In line with Ofcom’s Online Safety Enforcement Guidance, Leigh Day has asked Ofcom to take the following action:
- Investigate the site, along with similar sites and forums, including sites and search engines which point users to this content
- Use its full powers to gather evidence as part of a further formal investigation
- Consider issuing a business disruption order
- Consider using its powers to issue the site with fines, pay compensation to the women whose images have been posted and ensure that it operates within the law in future.
Tessa and her team will also write to the local police force that closed the investigation into Jane’s case and ask them to carry out a full and effective investigation with suitably skilled investigators.
At the same time, lawyers at Mishcon de Reya are writing to Google demanding that the site is urgently delisted. It is highly concerning that such a website is currently accessible via a Google search. The site flagrantly violates Google's own policies and terms of service which prohibits content relating to intimate images shared without consent and sexual images of children under 18. Under the new provisions of the Online Safety Act coming into force on 17 March 2025, service providers such as Google will be under an obligation to protect users from such illegal content, by proactively removing it and preventing it from appearing in the first place. Otherwise, they may face sanction by Ofcom which can include fines of up to 10 per cent of worldwide revenue.
Mishcon de Reya is also writing to Spaceship Inc, which – according to ICANN – is the domain registrar of the site, and Cloudflare Inc, which – according to ICANN – is the host and provides the server for the site. Again, it is highly concerning that such well-regarded companies are providing services to a website that contains illegal content and is in clear breach of their respective terms of service.
Jane said:
“Crimes that disproportionately affect women — such as rape, harassment, and image-based sexual abuse (often mislabelled as "revenge porn") — are often met with victim-blaming. Society shifts responsibility onto women, framing their victimisation as a result of poor choices or naivety, rather than holding perpetrators and platforms accountable for their actions. This deflection not only reinforces the harmful perception that women somehow deserve abuse, but focuses on their perceived promiscuity, rather than the actions of those who endanger them, leaving women and girls more vulnerable than ever. Action must be taken to tackle the misogyny that allows these crimes to take place in the first place.
“In many cases, including my own, these images are shared not out of revenge but for sexual gratification, peer networking, and the social status derived from their abusive context. Like thousands of other women, I have been left vulnerable, with my face and location easily accessible, while those who circulate these images remain anonymous and unaccountable.”
Leigh Day partner Tessa Gregory said:
“This forum is one of multiple image-based boards accessible in the UK which, as our client’s experience shows, pose a grave threat to the safety of women and girls. It hosts thousands of intimate images which have been posted and shared without consent.
“As a matter which falls squarely under the regulation of websites and online content, we turn to Ofcom as the UK regulator, to take swift and decisive action to address the harms posed by these sites to our client, and to all women and girls in the UK.
“We note that the sharing of intimate images without consent has recently been classified as a “priority offence” under the Online Safety Act, accordingly, this is a real test as to whether Ofcom is going to live up to its promises.”
Mishcon de Reya partner, Harry Eccles-Williams, said:
"Thousands of women and girls suffer at the hands of these misogynistic image-sharing sites. Due to the anonymous nature of these sites, it has been near impossible for victims to seek redress and protect their privacy.
“We hope that this will now change. Ofcom has been empowered by Parliament under the Online Safety Act to create a safer digital space for women and girls in the UK. It needs to act now.
"It is also imperative that internet service providers, such as Google, take their own steps to ensure that they are not facilitating these illegal and deeply harmful sites."
Jane is represented by Leigh Day partner Tessa Gregory and solicitor Claire Powell who have instructed Helen Law from Matrix Chambers and Natasha Simonsen from Blackstone Chambers. Jane is further represented by partner Harry Eccles-Williams and associate Katie Mehew at Mishcon de Reya, who are acting pro bono in this matter.