Facebook’s Civil Rights Audit dangerous and intimidating forms of suppression — especially when targeted (as they often are) toward specific communities. This new policy is supported by both proactive detection technology and human review, and violating content is removed regardless of who posts it. Notably, the policy applies equally to content posted by politicians and any other speakers on the platform. Specifically, Facebook’s new census interference policy prohibits: • Misrepresentation of the dates, locations, times and methods for census participation; • Misrepresentation of who can participate in the census and what information and/or materials must be provided in order to participate; • Content stating that census participation may or will result in law enforcement consequences; • Misrepresentation of government involvement in the census, including that an individual’s census information will be shared with another government agency; and • Calls for coordinated interference that would affect an individual’s ability to participate in the census (enforcement of which often requires additional information and context). Many in the civil rights community and the US Census Bureau lauded the policy. The Leadership Conference on Civil and Human Rights described it as industry leading: “the most comprehensive policy to date to combat census interference efforts on its platform,” and the Census Bureau thanked Facebook for the policy and its efforts to “ensure a complete and accurate 2020 Census.” Others celebrated the policy while taking a cautionary tone. Rashad Robinson of Color of Change said, “Facebook is taking an important step forward by attempting to promote an accurate Census count, but success will depend on consistent enforcement and implementation [...] This updated policy is only as good as its enforcement and transparency, which, to be clear, is an area that Facebook has failed in the past.” Enforcement of the policy had an early setback, but according to Facebook, has since improved. In March 2020, an ad was posted by the Trump Campaign that appeared to violate the new census interference policy, but it took Facebook over 24 hours to complete its internal escalation review and reach its final conclusion that the ad did, in fact, violate the new policy and should be removed. The delay caused considerable concern within the civil rights community (and among the Auditors) — concern that Facebook’s enforcement would negate the robustness of the policy. After the incident, however, Facebook conducted an internal assessment to identify what went wrong in its enforcement/escalation process and make corrections. While Facebook developed its census interference policy with expert input, it is difficult to anticipate in advance all the different ways census interference or suppression content could manifest. Because the violating content in the ad took a form that had not been squarely anticipated, Facebook’s removal of the ad was delayed. After this initial enforcement experience, Facebook focused attention on ensuring that its enforcement scheme is sufficiently nimble to promptly address interference and suppression manifested in unanticipated ways. 21