BSR | Human Rights Impact Assessment: Facebook in Myanmar 46 may exacerbate violence or cause offline harm, especially in the lead-up to the 2020 elections. Principle 19 of the UNGPs states that “If the business enterprise has leverage to prevent or mitigate the adverse impact, it should exercise it. And if it lacks leverage there may be ways for the enterprise to increase it.” Proactively draw upon local stakeholder insights to improve Community Standards enforcement. A theme throughout BSR’s discussions with stakeholders is that the victims of online hate speech and harassment, as well as those organizations that work with them, can provide very important insights into the Community Standards enforcement process. Several scenarios were shared with BSR where detailed changes to the enforcement system could make a big difference for at-risk rightsholders in Myanmar. Facebook can secure detailed insights directly from local stakeholders (especially vulnerable groups and those most at risk from hate speech, harassment, and other Community Standards violations) on how to improve Community Standards enforcement. In addition to the desire for detailed insights, BSR also encountered a strong desire among local stakeholders to be engaged in questions of longer-term strategy, especially on matters that raise major policy questions. Stakeholders emphasized that it will be important to engage with a diverse range of real users, including outside Yangon and Mandalay, and those not represented by major civil society organizations. Stakeholders also emphasized the importance of systematic, rather than ad hoc, consultation efforts. Examples surfaced with BSR during this engagement were: content reviewers being able to view the whole post and comment thread for full context, rather than isolated comments; the prevalence of copy/paste sharing techniques; understanding how best to increase the profile of reporting mechanisms; and understanding what content is most likely to contribute to, or exacerbate, violence and harm. Facebook is already very well aware of these issues. Nevertheless, the detail and specificity of these recommendations suggests that Facebook has an opportunity to continue identifying improvements to its Community Standards enforcement process by engaging directly with those impacted most by them. Principle 18 of the UNGPs states that human rights due diligence should “involve meaningful consultation with potentially affected groups and other relevant stakeholders.” Continue investing in AI-based and other machinebased approaches to Community Standards enforcement to improve accuracy, responsiveness, and timeliness, and share insights with stakeholders. Stakeholders raised with BSR a few scenarios where machine-based approaches or other technology-based methods (such as IP/VPN mapping) may assist with Community Standards enforcement, including repeated fake accounts, reposted identical content that has previously been removed, and automated warnings related to key words or text patterns. There was considerable interest from stakeholders in Facebook exploring how innovative technologies could be deployed proactively to increase user privacy, security, and protection. While still at the early stages, evidence is growing that AI can be deployed in ways that improve the accuracy, responsiveness, and timeliness of Community Standards enforcement. However, some stakeholders emphasized that moves beyond passive notice and takedown approaches toward more proactive content removal methods would need to be done in ways that don’t put the right to freedom of expression at undue risk, or set a precedent for overbroad restrictions in other markets. Principle 19 of the UNGPs states that “If the business enterprise has leverage to prevent or mitigate the adverse impact, it should exercise it. And if it lacks leverage there may be ways for the enterprise to increase it.”