Facebook’s Civil Rights Audit 1. Policy Review Civil rights input is critical to Facebook’s policy development process — the process by which Facebook writes new rules or updates existing ones to govern the type of content that is and is not permitted on the platform. To help ensure civil rights considerations are recognized and addressed in the policy development process, the civil rights leader will have visibility into the content policy development pipeline. In cases where a policy could have civil rights implications, the civil rights leader: (i) will be part of the working group developing that policy; and (ii) will have the opportunity to voice civil rights concerns directly to policy leadership before the policy is launched and when policy enforcement decisions that rely on cross-functional input are escalated internally. 2. Product Review An important element of an effective civil rights infrastructure is a system for identifying civil rights risks or considerations at the front end and throughout the product development process. Facebook is doing two things in this area: (i) Civil Rights Screening: Through the Audit, Facebook has committed to embedding civil rights screening criteria within certain existing product review processes so that teams can better identify and evaluate potential civil rights concerns. As a starting point, the Auditors have worked to develop civil rights issue-spotting questions that teams working on products relating to advertising, election integrity, algorithmic fairness, and content distribution (e.g., News Feed) will embed into existing product review processes. Currently, all but one of the product review processes these questions will be inserted into are voluntary, rather than mandated reviews required of all products. That being said, Facebook has authorized the civil rights leader to look for ways to further develop or improve civil rights screening efforts, and provide input into review processes both to help make sure civil rights risks are correctly identified and to assist teams in addressing concerns raised. (ii) Responsible Innovation: Independent of the Audit, Facebook has been building out a full-time, permanent team within the Product organization that is focused on Responsible Innovation — that is, helping to ensure that Facebook’s products minimize harm or negative impacts and maximize good or positive impacts. The Responsible Innovation team’s stated priorities include: (a) developing trainings and tools that product teams can use to identify and mitigate potential harms (including civil rights impacts) early on in product development; (b) helping employees understand where to go and what to do if concerns are identified; (c) tracking potential harms identified across products and supporting escalation paths to help ensure risks are effectively addressed; and (d) engaging with outside experts and voices to provide input and subject matter expertise to help product teams integrate diverse perspectives into their product development process. Facebook indicates that the Responsible Innovation team is growing but currently consists of engineers, researchers, designers, policy experts, anthropologists, ethicists, and diversity, equity, and inclusion experts. The Auditors met with key members of the team, and discussed the importance of avoiding civil rights harms in product development. The Responsible Innovation team is focusing on a handful of key issues or concepts as it builds out 16

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