Facebook’s Civil Rights Audit information. In other words, the label is not placed on just content that is demobilizing (e.g., posts encouraging people not to vote) or content that is likely to be misinformation or at the edge of what Facebook’s policies permit, but instead inserts the label on voting-related content. Facebook reports that this label will be placed on posts that discuss voting, including posts connecting voting with COVID-19, as well as posts that are about the election but do not use those terms (e.g., posts containing words such as ballots, polling places, poll watchers, election day, voter fraud, stolen election, deadline to register, etc.). The reaction to Facebook’s new labeling program within the civil rights community (and among the Auditors) was mixed. On the one hand, they recognize the need to ensure access to correct voting information and value the dissemination of correct information, particularly at a time when confusion about voting and the US presidential election may be rampant. On the other hand, there is concern that labeling all voting-related posts (both those that are accurate and those that are spreading misinformation) with neutral language will ultimately be confusing to users and make it more difficult for them to discern accurate from misleading information. While Facebook has asserted that it will remove detected content that violates its voter interference policy, regardless of whether it has a label, civil rights groups remain wary that Facebook could view the labeling as reducing its responsibility to aggressively enforce its Voter Interference Policy — that the company may not have a sense of urgency in removing false information regarding voting methods or logistics because those posts will already have a label directing users to the Voting Information Center. The Auditors have stressed that the new voting labels do not diminish the urgency for Facebook to revisit its interpretation of what constitutes “misrepresentations of methods for voting” under its Voter Interference Policy. For example, voting labels will not alleviate the harm caused by narrow readings of that policy that allow content such as posts falsely alleging that official ballots are illegal. These types of false statements sow suppression and confusion among voters and should be taken down, not merely given a label. Further, because of the likely saturation of labels — the frequency with which users may see them — there is concern that users may quickly ignore them and, as a result, the labels will ultimately not be effective at cabining the harm caused by false voter information. Facebook states it is researching and exploring the best way to implement the labeling program to maximize traffic to the Voting Information Center without oversaturating users. Facebook has represented to the Auditors it will observe how people interact with labels and updateits analysis to increase the labeling program’s effectiveness. 4. Voter Suppression Improvements (i) Voter Interference Policy Enforcement Guidance. In December 2019, Facebook expanded its Voter Interference Policy to prohibit content that indicates that voting will result in law enforcement consequences. On June 26, 2020, Facebook issued further guidance clarifying what that provision prohibits. Specifically, Facebook made clear that assertions indicating that ICE or other federal immigration enforcement agencies will be at polling places are prohibited under the policy (even if those posts do not explicitly threaten deportation or arrest). The Auditors believe this clarification is an important one, as it signals that Facebook recognizes that messages warning of surveillance of the polls by law enforcement or immigration officials sends the same (suppressive) message as posts that explicitly use words like “arrest” or “deportation.” 30

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