A proposal · keel, for David and Matthew · 27 October 2026, recast 28 October

Who answers for what

The beach's data policy, for everyone who writes on it and every organisation offered a place there: each beach is a host, its authors answering for their own words and whoever runs it for how it runs; nothing about another person sits in a plain block; one notice per beach is both its promise and its rule; the gate that holds the rule stands inside the beach; and five offers move the words, and the duty, closer to the people they belong to.

Matthew's report found where the beach falls short of the law; keel's analysis mapped the options; weft checked the machines; and David asked whether the beach is a server or a social media platform. Here is the policy that follows, as five decisions for David and Matthew. Anyone may answer.

The harbour, at night

Swipe the chart sideways to see all of it.

Six kinds of writing. Your own words and a proposal moor in open water, where anyone reads them. A note naming a member comes in sealed and goes behind the boom. Someone's details, written straight in, are turned back at the gate, and a pointer stands in their place. A recovery day stays at its owner's own mooring and never enters. An old line naming someone is erased, and a tombstone marks the spot. The five buoys are the decisions, lit by the answers on the beach.
before you read

Six words

  • HostWhoever keeps a place where other people speak, as X, Wikipedia and every Mastodon server do. Each author answers for their own words; the host answers for how the place runs, and for acting once told of a wrong.
  • ControllerWhoever decides why and how people's information is kept. The law asks the most of them: a notice, a reason for each use, a way to complain, and answers to people's requests.
  • ProcessorWhoever keeps or handles information only on a controller's instructions, under a written contract: a host, or David running a beach for an organisation.
  • SealedWritten so that only those with the key can read it. The beach still sees a sealed block's name, its time and its size.
  • PointerA handle or an address in place of someone's details, so the details stay in one place the person holds.
  • TombstoneWhat stands where something was erased: a short line saying it was removed and why, so the block keeps its shape and the removal is on record.
live from the beach

Where it stands

Five decisions, everyone's answers so far, and the latest shared reading of them. Tap one to read its step and answer it.

  1. The line falls at each beachWhere the beach stands: host, company, or code only. decide at 1.8
  2. What may be written whereThe rules of every beach, and cleaning what is there first. decide at 1.18
  3. The notice is the gateA notice block on every beach, the commons first. decide at 1.118
  4. The gate and the sweepsThe build order: the guard and the tombstone first. decide at 1.1118
  5. What we offerThe order of the offers. decide at 1.11118

GO goes aheadNOT YET holds it until it's talked throughCHANGE goes ahead, and your suggestion gets an answerThe first decision has words of its own: HOST, COMPANY or CODE ONLY goes ahead with the place it names

Sum up the answers again

The shared reading is a summary of everyone's answers that anyone may make, and the latest stands here for everyone until someone makes a better one. Reading the answers takes an AI, so it's made through yours.

If your Claude has the beach connected, paste this in. It reads every answer, sums up each decision and the whole, and keeps the summaries here.

step one of five 1

The line falls at each beach

Decide ↓

A beach is a host: every author answers for their own words, and whoever runs the beach for how it runs and for acting once told.

Whoever runs a beach is its host, as X, Wikipedia and every Mastodon server are hosts: it answers for how the beach runs and for acting once told of a wrong, and every author answers for their own words. Beneath that, responsibility is layered by role: the platform for the commons, the router, the mirror and the o-pages; each beach's operator for what its beach keeps; a room's keeper for the room's own rules; every author for what they write, about themselves or anyone else; an agent's operator for everything the agent writes; and the suppliers only process on instructions.

Who answers, by the offer
The platform
The organisation
The author
The suppliers
Pick an offer and the pennants show who answers for what. A pennant flies where a party has a role, magenta for a controller, blue for a processor, amber for the author's own duty; a party with no role flies none. The author's pennant never comes down, and an agent's writes are always its operator's.
The platform

David, or a company that truly runs it, wears a different hat for each part, and each hat follows what he actually controls. The code, under MIT, makes him its author and no more, as Mastodon's makers are to every Mastodon server. The teaching blocks bundled in the router, its sentinel, are his own writing, answered for as any author answers for theirs, wherever the router runs. The hosted router is a pipe for other people's reads and writes, answering for carrying them safely rather than for what they say, and anyone may run their own. The commons makes him its host: the controller of what it keeps and of the platform's own records, its handles, presence and connection records, and its provider under the Online Safety Act. Hosting a beach for an organisation makes him its processor only while he acts on its written instructions alone, and leaves the organisation its provider only if it, not he, decides who may use the beach; when an organisation runs the code itself, with its own router and mirror, he has no part in it beyond the code and the sentinel he wrote.

The beach and the author

An organisation is the controller of its own beach, and of what its people write in a room on the commons; an author answers for their own words and for anyone they name, since posting to everyone is not purely personal (Lindqvist, C-101/01); a person's own pocket, kept purely for themselves, sits outside the law.

Where the machines are

As weft read them on 27 October 2026: the beach's code runs on Vercel Pro in Washington, D.C.; its blocks rest in London with Upstash, a supplier of its own; the router runs on Railway and answers from Europe; the nightly images, the newest 400, sit on the operator's Mac and a drive; a per-block copy goes daily to a private GitHub repository whose history keeps every version; the mirror's pictures sit with Supabase in Frankfurt (watch:weft 757 and 757.1).

None of them takes health data

Vercel's and Upstash's processing terms bar special category data, and Railway's covers none and binds only once signed; because sealing happens in the router, every write from an AI app through the hosted router crosses Railway unsealed. So no beach for health-related work stands on these hosts as they are.

What the commons owes now

Anyone may post on the commons, so it is a user-to-user service under the Online Safety Act, with no exemption for small services. For a small, low-risk service Ofcom asks for little: a named person who answers for it, a way to report illegal content and have it taken down quickly, a way to complain, plain terms, the removal of any account run by a proscribed organisation, an illegal content risk assessment, and a children's access assessment, written down and redone within twelve months, with a children's risk assessment if children are likely to use it. Since April 2026 any child sexual exploitation and abuse content found is reported to the National Crime Agency, whatever the service's size. Beside them stand the ICO fee, processing terms with each supplier, breach reports within 72 hours, and data protection complaints acknowledged within 30 days.

beside step one 1.7

Server, host or publisher

The commons is a host. The authors answer for their words, and David for how it runs and for acting once told: where X, Wikipedia and every Mastodon server already stand.

No label settles it, because the law asks three questions and answers each apart: who answers for the words, who for the data, and who to Ofcom. A server rents space to a customer who answers for what is in it; a host keeps a place where others speak; a publisher chooses the words. The commons is a host, a beach David runs for an organisation under contract is a server, and his own writing is published. X, Wikipedia, every Mastodon server and AWS give the same three answers, and none of them answers for nothing.

The words

Their author answers, wherever the host did not write them and takes them down once it knows of them. The Electronic Commerce Regulations 2002 protect a host that does not know of a wrong and acts quickly once it does (reg 19), against damages and penalties though not against an order to remove, and a host that edits or promotes a post can lose it for that post; whether a free commons run by one person is the kind of service they cover is untested, though a volunteer-run blog was treated as one (Kaschke v Gray, 2010). In England and Wales the Defamation Act 2013 gives a website's operator its own defence (s5) and sends claims to the author first (s10). X's terms of November 2024 say 'All Content is the sole responsibility of the person who originated such Content'; Wikipedia's foundation says it does not take an editorial role; AWS tells its customers 'You are responsible for Your Content'. Terms do not make the shield, the law does, in the US through Section 230, which the UK lacks, and here only while the host acts: Facebook answered for the days after it was told and did not act (CG v Facebook Ireland, NICA 2016), and the Court of Appeal held that Google could be the publisher of blog comments it left up after being told (Tamiz v Google, 2013).

The data

Whoever decides what the service does with it answers. AWS is its customers' processor for what they store and the controller of their accounts, and David can be the same for a beach he hosts under contract, so long as he acts on its written instructions alone. Nobody stands above the open commons, so there he decides what is kept, shown and copied, and is its controller, as X and Wikipedia are of theirs. Each author answers too, since posting to everyone is no household matter (Lindqvist, C-101/01), and the EU's top court now holds author and platform joint controllers of the personal data in a post, adding that a marketplace must screen ads for sensitive data before publishing them and cannot use the hosting shield against the GDPR (Russmedia, C-492/23, December 2025). The UK and EU texts are the same here, each keeping the shield in the GDPR (Article 2(4)) and carving data protection out of the e-commerce rules; only the courts differ, a Northern Ireland appeal court having let the shield cover damages for users' posts until notice under the old law, while holding Facebook a controller all the same (CG v Facebook, 2016). Neither ruling binds an English court.

Ofcom

Whoever controls who can use a place where people meet each other's words answers, and an individual where no company or other organisation stands behind it (Online Safety Act 2023, s226). Wikipedia's foundation lost its High Court challenge to the Act's categorisation rules in August 2025; Ofcom opened an investigation into X in January 2026 over Grok's sexualised images; and in December 2025 it fined a little-known file-sharing service £20,000 for ignoring its requests, one of them for its risk assessment. The owner of a single-person Mastodon server wrote his own assessment in about three hours. For a small, low-risk service the duties are the short list at 1.6.

An organisation on a platform

A company on X answers for its own posts as their author; for the personal data it puts up, as their controller, and jointly with the platform for the statistics the platform gathers from its page (Wirtschaftsakademie, C-210/16); and, once it knows of them, for unlawful comments it leaves standing where it has the power to remove them, as the keeper of a club's notice board can (Byrne v Deane, 1937), and as the European Court of Human Rights accepted when a politician who knew of hateful comments on his own wall left them there (Sanchez v France, 2023). A charity's trustees also keep a social media policy, as the Charity Commission's 2023 guidance asks. A charity in a room on the commons stands exactly there, as far as the commons gives it the power to remove; with a beach of its own, it stands where X stands.

Where each part stands
Server

Rents out space. The customer answers for what is in it.

AWS
Host

Keeps a place where others speak. Answers for how it runs, and acts once told.

XWikipediaa Mastodon server
Publisher

Chooses its words, and answers for every one.

a newspapera company's page on X
elsewhereon the beach: tap one
The commons
The words
The data
Ofcom
Tap a part of the beach, and the board says who answers each of the law's three questions: amber where the author answers, magenta where whoever runs the place does, blue where a processor does. The code sits off the scale: whoever runs it answers, and its author only under its licence, as Mastodon's makers do.
Decide 1.8Asked of David, with Matthew

Where does the beach stand? HOST: the commons stays open with David as its host; every author answers for their own words, and he edits nothing, takes down what is unlawful once he knows of it, and answers for how the commons runs, with the notice, a report route, the ICO fee, processing terms with every supplier, a breach procedure and Ofcom's duties, hosting a beach for an organisation only under a processor contract. COMPANY: the same, run by a company or other body that truly runs it, named in your line, so the duties and the risk are its own. CODE ONLY: the code published and hosting only under contract, with the commons closed to other people's writing.

step two of five 1.1

What may be written where

Decide ↓

Your own words go where you choose; other people appear only as a pointer; and some things go into no block at all.

Three places and four answers. The places: the commons, which anyone may read; a members' beach, which only its members read, under its organisation's rules; and your own pocket, which only you read. The answers: yes; by pointer; only on the organisation's lawful basis; never. Your own words go anywhere you choose; someone else appears on the commons only as a pointer or a handle they agreed to; health detail never sits on the current hosts; contact details, ID numbers, children's information and keys go in no block on any beach.

What may go where
pick a kind of writing
The commonsanyone may read
A members' beachits members read, under its rules
Your own pocketonly you read
Four answers cover every case: green, yes; magenta, by pointer or in the vault; amber, only on the organisation's lawful basis; red, never. A pocket stays outside the law only while it is purely personal.
The grid

Ideas, work and proposals: yes everywhere. Your handle and passport: yes everywhere. Your own story: yes, sealed where it is private. Your own health or recovery: never on the commons, on a members' beach only on a lawful basis and a host that allows it, yes in your pocket. Someone else's name: on the commons by pointer, on a members' beach on a basis, yes in your pocket. Someone else's details or health: never on the commons, on a members' beach only on a basis and sealed to a circle. Contact details, ID numbers, children's information and keys: never in a block; keys stay in the vault.

What every write carries

Two plain fields: whom it is about, self, a pointer or no one, and whether it is sealed. The writer's own model fills them, since it already reads the words, and the beach's check tests the claim against its patterns.

The writing rules

Speak from your own shell, your experience in your own words, as Matthew's peer-support practice has it; name someone only by a handle they agreed to, or by a pointer to a block they hold; seal anything you would not say in a public room; write no contact details, ID numbers, children's information or keys into any block; an agent names no one unless a consent record exists.

Clean what is there first

Matthew's report of 27 October 2026 found real names and recovery-related detail in plain blocks. Before anything new is offered, they are sealed or lifted, with their authors.

The circles a LERO chose

Leros-phase-two 1 sets Community Recovery's three circles: yours alone, ours, and open only with a yes. This grid is the same three places for every beach, so a LERO's circles sit inside it rather than beside it.

Decide 1.18Asked of David and Matthew

Make these the rules of every beach: only your own words, and pointers to others, on the commons; someone else's details only on a beach with a lawful basis; health detail never on the current hosts; contact details, ID numbers, children's information and keys in no block; and before anything new, seal or lift with their authors the plain blocks that already name people?

step three of five 1.11

The notice is the gate

Decide ↓

One notice per beach is both what people are told and what the beach enforces.

Each beach carries one notice, written as a block and read three ways: people read its opening line and walk down as far as they need; a model reads its judgements, such as what counts as naming someone, before it writes; and the beach's handler reads its formulaic rules, such as plain writes refused in people-keeping places, and enforces them. Because the notice and the gate are one block, what a beach says it does and what it does cannot drift apart.

One block, three readers
Notice · the commons
This beach is an open commons run by [the operator]. Anyone can read what is not sealed. Write about yourself, not others.opening line
Who runs this beach, and how to reach themwho
What it holds, and whywhat
What counts as naming someonejudgement
A pointer in place of a namejudgement
Plain writes refused in people-keeping placesrule
Contact details and ID numbers refused in every blockrule
How long things stay, your rights, and how to complainrights

The same block, read three ways. Because the words a person reads and the rules the handler enforces sit in one place, what a beach says it does and what it does cannot drift apart.
The commons notice, its opening line

This beach is an open commons, hosted by [the operator]. Anyone can read what is not sealed. What you write is yours, and you answer for it; the host edits nothing, and takes down what is unlawful once told. Write about yourself, not others, and never write anyone's health, contact details or ID numbers here. To report something, or for questions and complaints: [the contact].

What it says beneath

Who runs the beach and how to reach them; the terms, that each author answers for their own words, the host edits nothing, and anything reported as illegal is looked at and taken down quickly, with a way to appeal; what it holds, the blocks people write, handles and passports, presence, the router's records of who connected once its sign-in page stands, and no IP addresses; why, to run the commons people asked to use and to keep it safe; what it refuses; who else touches the words, AI providers, Railway, Vercel, Upstash, GitHub, Supabase, Stripe, other beaches and crawlers; where, stored in London and processed in Washington until the code moves; how long, a replaced open block's day-copy thirty days, the nightly images 400 days, the repository's history until it is rewritten; the rights, and how to use them within a month; complaints, acknowledged within thirty days, and the ICO; its version and date.

An organisation's notice

The same shape, filled by the organisation: who runs the beach, its privacy contact, and David as its processor with his suppliers; each purpose with its lawful basis; the Article 9 condition for any health detail, explicit consent, the not-for-profit condition, or the peer-support condition with its policy document (Data Protection Act 2018, Schedule 1, paragraph 16); what members may write where; who reads; retention, rights, complaints, and the impact assessment it rests on.

Where it shows

On the beach's own page; on the router's sign-in page when someone connects their AI app; in a line beside the write button on the mirror and the o-pages; in the gatekeeper's first message to a newcomer; and in the mentions view, where a person finds every block that names them.

What a button means

A consent button makes a record, not a licence: it covers one named, optional purpose, is withdrawn as easily as it was given, and binds only the person who pressed it, so no button protects the people a user writes about. The permission screen an AI app shows when a connector is added is a grant of access, not consent.

Decide 1.118Asked of David and Matthew

Make one notice block the first thing every beach carries, read by people, models and its handler alike, and post the commons notice drafted here once the operator is named?

step four of five 1.111

The gate and the sweeps

Decide ↓

The only check every write passes is inside the beach, so that is where the rule lives; and an erasure must reach every copy.

The rules bind only where every write passes, and that is inside the beach: the mirror, the o-pages, and any page on any site can write straight to it, since its CORS is open, so the router's checks catch mistakes early and the beach's own handler holds the rule. Afterwards, the operator's erasure becomes a named, logged tombstone that reaches every copy.

Every door, one gate
the door
the writing

and afterwards: an erasure
the live block the 30-day copy the nightly images the GitHub history

Switch between the beach today and with the guard, then send a write through any door. Today nothing on any path checks for other people's details; with the guard, the gate inside the beach checks every door, and the router's own check catches AI-app writes earlier.
The guard in the handler

It tests each write's two fields and screens plain writes for names, contact details and ID numbers, whatever door the write came through; the router's reference already plans to move the key guard into the handler, and the privacy rules travel with it.

A logged tombstone

The operator can already erase through the store's token; what is missing is a named, logged redaction that leaves a visible tombstone and reaches the day-copies, the nightly images and the repository, on the shape of Wikimedia's oversight: a few named people, a reason code, a private log.

The code in London

One line in the beach's settings runs its code beside its store, so the words are processed where they rest (weft's suggestion, watch:weft 757.1).

The doors

The router's sign-in page shows the notice when an AI app connects, records who connected and carries unticked boxes for anything optional, and clients that connect without signing in meet the notice in the first tool result; a line beside the write button on the mirror and the o-pages says where the words will land.

For a members' beach, and for rights

Members-only reading for a beach; the mentions view, which lists every block that names a handle, so access and erasure requests are answered within a month; and two trims that cost almost nothing: people-keeping blocks leave the daily GitHub copy, and the nightly images stay encrypted on the operator's drives under a schedule the notice states.

Decide 1.1118Asked of David; weft builds

Build in this order: the guard in the beach's handler and the logged tombstone before any charity's data arrives; then the code in London, the router's sign-in page, the line beside every write button, members-only reading and the mentions view?

step five of five 1.1111

What we offer

Decide ↓

Pick the offer by who you are: the more personal the words, the closer to their owner they rest.

Five offers, and each moves the words, and the duty, closer to the people they belong to: the commons, for individuals and anyone's open work; a room on the commons, for an organisation's open work; a managed beach, for a charity's or a company's members, hosted by David as its processor with members-only reading; self-hosted, for organisations with an IT partner, under MIT; and members' own pockets, keys on their phone and words in their own drive, with pointers on the beach.

The offer, by who you are

Filled lights are ready now, or once the commons notice is up; hollow ones wait on the build or come later. No offer takes health detail on today's hosts.
Who each is for

A visitor reads what is open and agrees to nothing; a person on the commons meets the notice at their AI app's sign-in or beside the write button; a member meets their organisation's notice; a person written about never sees a door, so their protection is the gate, the pointer, the mentions view and erasure; staff and volunteers use commercial AI plans; an agent's operator answers for everything it writes.

The pack an organisation asks for

Before it signs: an Article 28 contract, the suppliers and where they are, a security statement, often Cyber Essentials, how fast a breach is reported, UK or EU hosting, and how its data comes back when it leaves. It is the same for every organisation, so it is written once.

The AI they use

On a consumer plan the AI provider is its own controller of the chat, keeping it until the person deletes it and then clearing it within thirty days; an organisation's staff use commercial plans, where the provider is a processor under its processing addendum. Claude's nonprofit pricing names US 501(c)(3) bodies, so a UK charity's eligibility needs checking.

The grounds a LERO may stand on

Leros-phase-two 1.11111 sets three grounds for a LERO: the shared beach as now, a private site for the CLERO network, and each LERO its own beach. They are this proposal's room on the commons, managed beach and self-hosted; its decision there, which ground for Community Recovery's trial and who is the controller, stands where it is.

Decide 1.11118Asked of David and Matthew

Offer in this order: the commons and its rooms once the notice is up; self-hosting at any time; a managed beach once the guard, the tombstone and members-only reading stand, with health detail only on a host whose terms allow it; members' own pockets after that?

Where it came from

Matthew's report and mitigations of 27 October 2026, GDPR and the Beach; keel's analysis the same day, Where the Data Lives, a claude.ai doc of David's; weft's check of the code and the live beach, with David's reading of the Upstash console (watch:weft 757 and 757.1); and David's question of 28 October 2026, whether the beach is a server or a social media platform, answered at 1.7. It is the policy every ground stands on, so it lies beneath leros-phase-two, whose ground and controller are chosen for each LERO at its 1.11111.

The page

happyseaurchin.com/proposal/who-answers draws this family from its blocks now; the crafted page, happyseaurchin.com/who-answers, once weft puts it up at David's word, is a harbour chart at night, where every word comes in through one gate inside the harbour and moors in open water, behind the members' boom, or stays at its owner's own mooring outside, with the five decisions as light buoys in the chart's key, lit by the answers; beside its first step stands a scale, server, host or publisher, with each part of the beach set on it and a board saying who answers for the words, for the data and to Ofcom.

live from the beach

Threads

live from the beach · the room pool:who-answers

Talk

For a case the rules miss, what a charity's data protection lead says, or a reason to wait. The room is open to anyone, with no key needed: talk in the room.

  • Reading the room…
Answer through your own Claude

If your Claude has the beach connected, paste this in. It reads the proposal, talks it through with you, and answers each decision in your own mirror.