BSR | Human Rights Impact Assessment: Facebook in Myanmar 27 need to be greater in high-risk locations such as Myanmar than in locations with less immediate risk of harm. » The removal of senior military officials from Facebook in Myanmar was a bold move and could be a significant blow against those committing or enabling serious human rights violations. However, the risk of retaliation by the Burmese military will have a material impact on Facebook’s ability to undertake activities in Myanmar. The decision to ban 20 military individuals and organizations from Facebook in August 2018 was a strong statement of the company’s determination to act against those seeking to use Facebook in ways that spread violence and enable genocide. However, this action also increases the risk of retaliatory moves against Facebook and its partners and impacts the ability of Facebook to undertake the in-country activities proposed by BSR in the recommendations section of this assessment, at least in the near term. It will take some time for the full impact and consequences of Facebook’s actions to be known, and the reaction of local stakeholders in Myanmar remained somewhat divided and uncertain at the time of writing. » There are both advantages and disadvantages in locating Facebook staff in Myanmar and establishing a local presence. As implied above, most external stakeholders BSR spoke to expressed support for Facebook staff to be located in Myanmar itself, rather than in nearby countries. However, some did express concern that the existence of local Facebook staff may increase government leverage over content restrictions and data requests by allowing them to threaten seizure of Facebook’s IT equipment or data or place Facebook staff at safety risk. Facebook’s action against senior military officials in August 2018 also increased the risks associated with locating Facebook staff in Myanmar, at least in the near term, and it is unclear whether Facebook could have acted against the military if Facebook staff had been present in Myanmar. There are also significant advantages for some Myanmar-focused staff to be located elsewhere, such as to provide 24/7 coverage or to build closer working relationships with other key teams and decision-makers in Facebook. » Local stakeholders are the source of very specific insights into how to improve Community Standards enforcement. Interviewees raised with BSR several specific proposals for Community Standards enforcement, such as allowing content reviewers to see the whole comment thread holistically, rather than one comment in isolation, searching for “copy and paste” sharing of content, and ensuring that Myanmar-relevant posts are channeled to Myanmar reviewers. When discussing these suggestions with Facebook, it was clear that Facebook was already aware of them or has different processes in place for different types of cases. Nevertheless, the detail and specificity of these recommendations suggest that Facebook has an opportunity to continue identifying improvements to its Community Standards enforcement process by engaging directly with those impacted most by them. » Stakeholders emphasized the need for a mix of machine- and human-based approaches to Community Standards enforcement. There is considerable interest in the potential to use AI, machine learning, and other technology-based approaches to improve the speed and effectiveness of Community Standards enforcement. For

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