Facebook’s Civil Rights Audit its infrastructure; fairness (which includes civil rights) is one of them, along with freedom of expression, inclusive access, economic opportunity, individual autonomy, privacy, and civic participation. While not limited to civil rights or designed as a civil rights compliance structure specifically, in the Auditors’ view, Responsible Innovation is worth mentioning here because the trainings, tools, and processes that team is looking to build may help surface civil rights considerations across a wider set of products than the subset of product review processes into which Facebook has agreed to insert civil rights screening questions (as discussed above). The Auditors also recommend that Facebook add personnel with civil rights expertise to this team. C. Recommendations from the Auditors The Auditorsrecognize Facebook’s commitments as important steps forward in building a long-term civil rights accountability structure. These improvements are meaningful, but, in the Auditors’ view, they are not sufficient and should not be the end of Facebook’s progress. 1. Continue to Onboard Expertise In keeping with Facebook’s 2019 commitment to onboard civil rights expertise, the Auditors recommend that Facebook continue to bring civil rights expertise in-house — especially on teams whose work is likely to have civil rights implications (such as elections, hate speech, advertising, algorithmic bias, etc.). In the Auditors’ view, the more Facebook is able to embed civil rights experts onto existing teams, the better those teams will be at identifying and addressing civil rights risks, and the more civil rights considerations will be built into the company’s culture and DNA. 2. Build Out the Civil Rights Leader’s Team The Auditors also believe that the civil rights leader will need the resources of a team to meet the demands of the role, and allow for effective civil rights screenings of products and policies. To the first point, the Auditors believe a team is necessary to ensure the civil rights leader has the capacity to drive a proactive civil rights accountability strategy, as opposed to simply reacting to concerns raised externally or through review processes. There is a difference between working full-time (as members of the civil rights leader’s team) on identifying and resolving civil rights concerns, and having civil rights be one component of a job otherwise focused on other areas (as is the case for members of the Civil Rights Task Force). While the Auditors recognize that Facebook has agreed to allow the civil rights leader to build a team over time, they are concerned that without more resources up front, the leader will be overwhelmed before there is any opportunity to do so. From the Auditors’ vantage point, the civil rights leader’s responsibilities — identifying civil rights priorities, designing macro-level systems for effective civil rights product reviews, participating in policy development, being involved in real-time escalations on precedential policy enforcement decisions, and providing guidance on civil rights issues raised by stakeholders — is far more than any one person can do successfully, even with support. To the second point, equipping the civil rights leader with the resources of a team would likely make civil rights review processes more successful. It would allow those reviews to be conducted and/or supervised by people 17

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