Facebook’s Civil Rights Audit with civil rights backgrounds who sit outside the product and policy teams and whose job performance depends on successfully flagging risks — as opposed to having reviews done by those with different job goals (such as launching products) which may not always align with civil rights risk mitigation. The Auditors believe that for review processes to be most effective, those conducting civil rights screens must be able (through internal escalation if necessary) to pause or stop products or policies from going live until civil rights concerns can be addressed. The civil rights leader (and those on his/her team) will be best equipped to do so because it is aligned with their job duties and incentives. Because the civil rights leader will not be able to personally supervise reviews effectively at the scale that Facebook operates (especially if further review processes are built out) a team seems mandatory. 3. Expand Civil Rights Product Review Processes. The Auditors acknowledge that embedding civil rights considerations into existing (largely voluntary) product review processes relating to advertising, election integrity, algorithmic fairness, and News Feed is progress, and a meaningful step forward. But, as Facebook continues to develop its civil rights infrastructure, the Auditors recommend: (i) adopting comprehensive civil rights screening processes or programs that assess civil rights risks and implications across all products; and (ii) making such screens mandatory and able to require product changes. While Responsible Innovation is a positive development, it was not designed to replace a civil rights accountability infrastructure. The Responsible Innovation approach involves considering a host of dimensions or interests (which may be competing) and providing tools to help employees decide which interests should be prioritized and which should give way in making a given product decision. The framework does not dictate which dimensions need to be prioritized in which circumstances, and as a result, is not designed to ensure that civil rights concerns or impacts will be sufficient to require a product change or delay a product launch. 4. Require Civil Rights Perspective in Escalation of Key Content Decisions. Difficult content moderation questions — in particular those that involve gray areas of content policy or new applications not explicitly contemplated by existing policy language — are sometimes escalated to leadership. These “escalations” are typically reactive and time-sensitive. But, as seen with recent decisions regarding President Trump’s posts, escalations can have substantial and precedent-setting implications for how policies are applied in the future — including policies with significant civil rights impacts. To help prevent civil rights risks from being overlooked during this expedited “escalation,” the Auditors recommend that the civil rights leader be an essential (not optional) voice in the internal escalation process for decisions with civil rights implications (as determined by the civil rights leader). To the Auditors, this means that the civil rights leader must be “in the room” (meaning in direct dialogue with decision-makers) when decisions are being made and have direct conversations with leadership. 5. Prioritize Civil Rights In sum, the Auditors’ goal has long been to build a civil rights infrastructure at Facebook that ensures that the work of the Audit — the focused attention on civil rights concerns, and the company’s commitment to listen, accept sometimes critical feedback, and make improvements — continues long after the formal Civil Rights Audit comes to a close. The Auditors recognizes that Facebook is on the path toward long-term civil rights accountability, but it 18