Content and Moderation Policy
Effective date: 2026-10-06
This Policy supplements the Terms (§ 6, § 7, § 15) and the Privacy Policy (§ 2.4, § 7). It describes what may and may not appear on a specialist or organisation Card in the Catalog, and how the Operator moderates that content.
The document fulfils the transparency obligation under DSA Art. 14.
§ 1. Scope and purpose
This Policy applies to all Cards in the Catalog, regardless of how the Card entered (editorial sourcing, third-party nomination, or specialist self-registration).
The Policy aims to:
- keep the Catalog informational, not promotional;
- protect visitors — neurodivergent people and their families — from unsupported claims;
- ensure every moderation decision has a stated reason and an appeal path, in line with DSA Art. 17 and Art. 20.
Media on Cards (photos, logos, files) are additionally governed by copyright and image rights (Terms § 11).
§ 2. What may be published on a Card
Cards may contain:
- the specialist's or organisation's name, city, practice address (if publicly available), session format;
- public professional contact details (phone, email, website);
- licence or registration numbers where applicable;
- qualifications, trainings, memberships that can be verified against public sources;
- the methods and approaches in which the specialist is trained, with the training institution named;
- the populations the specialist works with, session languages, current availability for new clients, years of practice;
- links to the specialist's public professional profiles and publications;
- descriptions of professional practice that convey behavioral acceptance of neurodivergent clients (e.g. "I take autistic clients", "I work with ADHD adults").
The guiding principle: factual, verifiable, respectful of the person being catalogued and of the person reading.
§ 3. What may not be published
The following is prohibited on a Card:
- Curative claims about neurotypes — statements that a specialist "cures", "eliminates", or "normalises" autism, ADHD, dyslexia, Tourette's, or any other neurotype, or offers "conversion" against sexual orientation, gender identity, or neurotype.
- Efficacy claims without evidence — percentages, improvement rates, or outcome guarantees without a cited scientific source. Phrases such as "100% effective", "guaranteed result", "instant improvement".
- Unlawful advertising of healthcare services under Art. 14 of the Polish Medical Activity Act of 15 April 2011 — including financial inducements presented as public advertising, comparisons to other specialists, promises of outcomes, use of child patients' statements as promotional material.
- Violations of professional ethics — online diagnosis without consultation; identifiable case descriptions without written consent; breach of professional confidentiality.
- Methods lacking scientific support when presented as curative for a neurodivergent condition. Methods are evaluated against current review literature (Cochrane, APA, NICE) and neurodivergent-community consensus; the internal evaluation criteria are documented and available to the data subject on request.
- Content unlawful under DSA Art. 3(h) — incitement to a crime, child sexual abuse material, hate speech, trademark infringement.
Legal basis: Terms § 6(2); Polish Psychological Association Code of Professional Ethics (PTP 2024, Art. 2.3); UN CRPD Art. 25.
§ 4. How content decisions are made
Every Card is reviewed by the Operator before public publication. The review covers:
- alignment with § 2 and § 3 of this Policy;
- declared qualifications against the public registry of the relevant professional chamber;
- declared trainings against the public certificate list of the issuing institution.
The Operator may, as a result of review or of a user report (§ 5):
- publish the Card without a public note;
- publish the Card with a public informational note next to specific statements;
- not publish the Card, with a Statement of Reasons sent to the specialist (§ 6).
Guiding principle: information with a warning generally serves the visitor better than arbitrary removal. A Card may be withheld from the Catalog where the Operator considers the risk to the visitor material.
Moderation decisions are made by the Operator.
§ 5. User reports (DSA Art. 16)
Any visitor may report a Card using the "Report violation" button on the public Card, or by email to [email protected] with the subject "DSA Report".
A report should include: the location of the content (URL), the reasoning, the reporter's contact details, and a statement of good faith (DSA Art. 16(2)).
Reports are triaged in a timely, diligent, non-arbitrary and objective manner (DSA Art. 16(6)).
If a report leads to a change in how the Card is displayed, the specialist receives a Statement of Reasons (§ 6). If the reporter supplied a contact, they receive confirmation of the outcome with a brief rationale.
§ 6. Statement of Reasons and appeal (DSA Art. 17 and 20)
6.1. Statement of Reasons (DSA Art. 17)
Where the Operator restricts the visibility of a Card, suspends an Account, or declines to publish, the specialist receives a written Statement of Reasons containing:
- the facts and their source;
- the regulatory or legal basis;
- the scope of the decision;
- information on the available remedies described below.
6.2. In-platform appeal (DSA Art. 20)
The specialist may appeal the decision free of charge within six months. Appeals are sent to [email protected] with the subject "DSA Appeal" and are reviewed within a reasonable period (DSA Art. 20(4)).
Where the Operator issued the original decision, the Operator conducts a documented re-review.
6.3. Out-of-court dispute resolution (DSA Art. 21)
Certified bodies for out-of-court dispute resolution are listed by the European Commission at https://digital-strategy.ec.europa.eu/en/policies/digital-services-act.
§ 7. Specialist's rights
- Takedown of a Card sourced editorially or by third-party nomination — email
[email protected]with the subject "Takedown". Handled without undue delay, no later than within the periods required by GDPR Art. 12(3). Identity verification is required. - Correction — email
[email protected]with the subject "Card correction". - Claim — the specialist may take over an existing Card and edit it themselves after email verification.
- Right to object (GDPR Art. 21) — handled within the GDPR statutory period. The legal basis for data processing is GDPR Art. 6(1)(f), supported by a documented Legitimate Interest Assessment available to the data subject on request.
§ 8. Audit
The Operator keeps internal records of moderation decisions and user reports for the period required by applicable law. The specialist and the reporter may request extracts of records concerning them (GDPR Art. 15) at [email protected] with the subject "Data access".
§ 9. Policy changes
Changes to this Policy take effect after a 14-day advance notice via publication of the amended version at /moderation-policy. Specialists with an Account receive email notification. Each change increments the version in the document header.
§ 10. Version history
| Version | Date | Change |
|---|---|---|
| 1.0 | 2026-10-30 | Initial document |
| 2.1 | 2026-10-30 | Tightened to legally-required disclosures; language aligned to statutory wording |
In case of discrepancy between this English version and the Polish version, the Polish version prevails for matters governed by Polish law. See docs/legal/README.md for the jurisdictional-precedence policy.