headquarters and the centre of Facebook’s international operations.9 Facebook’s Myanmar company, Facebook International Services (Myanmar), lists Ireland as the Principal Place of Business in Jurisdiction of Incorporation.10 Further, data relating to Facebook’s users in Myanmar is stored and controlled in Ireland.11 Facebook Ireland is also responsible for implementing key aspects of Facebook’s policy. At the time of the 2017 operations against the Rohingya, the Myanmar military’s Facebook accounts were contractually located in the Dublin offices of Facebook Ireland.12 Key decisions with respect to Facebook’s content moderation are made by its Irish subsidiary. Information regarding the policies and practices of Facebook’s content moderation, or content review, were provided to Ireland’s Oireachtas in August 2018. Two senior managers in Ireland – Niamh Sweeney, the head of public policy, and Siobhán Cummiskey, the head of content policy – told deputies that while content review policies were formulated in the USA and India, decisions with regards specific content were dealt with in Ireland. Niamh Sweeney said: “Anything that is escalated from our content reviewers, which might be unclear as to how it should be treated, is dealt with by Ms. Cummiskey’s team.” Both the content reviewers and Siobhán Cummiskey were based in Ireland.13 Facebook’s moderators for Burmese content were located in Dublin. A former content moderator from the Dublin office recently sued Facebook before Irish courts for lasting psychological trauma he endured from reviewing images relating to the 2017 operations.14 Further, there is evidence to suggest that aspects of Facebook’s policy regarding community standards, as well as for bullying and harassment, are made at its Dublin office. Facebook when engaging Civil Society over policy reform has been put in contact with employees at Facebook’s 9 Facebook to Establish International Headquarters in Dublin, Ireland, October 2, 2 October 2008 https://about.fb.com/news/2008/10/facebook-to-establish-international-headquarters-in-dublin-ireland [accessed 12 October 2021] 10 Facebook International Services (Myanmar) Company Profile, https:myco.dica.gov.mm/Corp/EntityProfile.aspx?id=2eb398b1-d6CC (Note that this is no longer available, but VAI have a copy which we can provide as an attachment.) 11 Facebook’s Privacy Policy Myanmar, available here https://my-mm.facebook.com/about/privacy/update [translated as: “How do we process and transfer data as part of our global service? In line with this policy, we are sharing information within Facebook companies, both internally and externally, and globally, as well as globally. The information controlled by Facebook Ireland [emphasis added] may be transferred or broadcast outside of the United States or other countries where you reside for purposes set forth in this policy.” “If you have any query in regards to this policy, you may reach us as given below…Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland] [accessed 14 October 2021, and translated by a native Burmese speaker] 12 Edward McGarr, ‘Ireland’s role in the Myanmar atrocities', McGarr Solicitors, 2 September 2018, viewed 25 May 2021, <https://www.mcgarrsolicitors.ie/2018/09/02/irelands-role-in-the-myanmar-atrocities/>. [accessed 25 May 2021] 13 Titled: Moderation of Violent and Harmful Content on the Facebook Platform: Discussion, available on Oireachtas website [accessed on 29 November 2021] 14 Chris Gray, ‘‘I saw horrors posted on Facebook daily…and it nearly destroyed me’: Man hired to moderate content – including beheadings, graphic sex and even child murder – says more MUST be done to block harrowing uploads’, Daily Mail, 21 June 2020, viewed 15 May 2021, <https://www.dailymail.co.uk/news/article-8441799/Man-hired-moderate-Facebook-content-says-blockharrowing-uploads.html>. [accessed 29 September 2021]; Nick Wiggins and Damien Carrick, ‘Chris sorted through the ‘blood and gore’ on social media. Now he’s suing Facebook over PTSD’, ABC News, 26 February 2020, viewed 30 June 2021, see also same story reported in ABC: <https://www.abc.net.au/news/2020-0226/ex-facebook-moderator-suing-company-over-ptsd/11972364>. [accessed 29 September 2021] 5