BSR | Human Rights Impact Assessment: Facebook in Myanmar 48 ENGAGEMENT, TRUST, AND TRANSPARENCY Recommendation Publish a local Myanmar-specific version of the Community Standards Enforcement Report. This report would include the same metrics as in the global Community Standards Enforcement Report (i.e., prevalence, volume, detection, timeliness) but segmented to show country-level data for Myanmar and/or for the Burmese language. In addition, stakeholders expressed interest in other disclosures, such as: the number of Burmese-language content reviewers; the nature/content of government relationships; country-specific enforcement guidance (e.g., list of slurs/flagged words/cases); response times; and the extent to which the Myanmar Government makes use of the Facebook Community Standards process, rather than formal law enforcement relationship channels. We recommend a reporting format that balances both numbers and narrative; both are needed for a decisionuseful understanding of Facebook’s human rights approach in Myanmar. BSR notes the dilemma that exists in relation to increasing transparency on Community Standards enforcement, such as the risk that publishing countryspecific enforcement guidance could provide a road map for bad actors. BSR’s instinct is to err on the side of increased transparency as a contribution to longerterm and systemwide change—for example, by increasing digital literacy and the capacity of local civil society organizations. Similarly, publishing response times may increase awareness of how the most challenging edge cases are outliers. This report could be a pilot for other country-specific reports (and/or language-specific), or a country-bycountry (or language-by-language) segmentation could form part of the global Community Standards Enforcement Report. Explanation It is BSR’s observation, generated across HRIAs undertaken for many companies in many countries, that in-country stakeholders are often more diligent readers of company disclosures than international stakeholders. We view transparency as a significant opportunity to increase trust, mutual understanding, and shared awareness of Facebook’s existing Community Standards enforcement efforts among both international and local stakeholders. It would continue the trajectory of increased transparency from Facebook and other social media companies. BSR recognizes that country segmentation of data can be challenging in some instances (e.g., a post uploaded in one country by a user of a different nationality may be flagged by a user in a third country), and that language segmentation of some types of data (such as response times) may be needed instead. That said, other information (such as a description of how Facebook manages relationships with government, and key interactions during the reporting period) can be disclosed in a country-specific manner. Principle 21 of the UNGPs states that “In order to account for how they address their human rights impacts, business enterprises should be prepared to communicate this externally, particularly when concerns are raised by or on behalf of affected stakeholders. Business enterprises whose operations or operating contexts pose risks of severe human rights impacts should report formally on how they address them.” This Principle also states that companies should “provide information that is sufficient to evaluate the adequacy of an enterprise’s response to the particular human rights impact involved.” Conduct an annual (or every six months) “public briefing” on Facebook’s human rights strategy and actions in Myanmar. Several stakeholders that BSR interviewed referred to the Telenor briefings as a very helpful practice that enabled informed dialogue and built trust. These communications can take place alongside the publication of a Myanmar-specific Community Standards Enforcement Report (or equivalent) and be modeled on similar and well-received “sustainability briefings” undertaken by Telenor. For example, they may include an in-person presentation by a senior Facebook representative, audience questions, and/or a webinar. Principle 21 of the UNGPs states that “In order to account for how they address their human rights impacts, business enterprises should be prepared to communicate this externally, particularly when concerns are raised by or on behalf of affected stakeholders.” Communications should “be of a form and frequency that reflect an enterprise’s human rights impacts and that are accessible to its intended audiences;” this latter point is noteworthy, given the number of stakeholders