BSR | Human Rights Impact Assessment: Facebook in Myanmar 26 minority of users is seeking to use Facebook as a platform to undermine democracy and incite offline violence, including serious crimes under international law. » Local rightsholders and stakeholders are primarily focused on the enforcement of the Community Standards, rather than their substance. BSR received many insights into how the Community Standards should be implemented at Facebook and gathered specific proposals for how the enforcement processes in Myanmar could be improved. However, while many stated that more detailed local guidance on what the Community Standards mean in practice would be helpful, the Community Standards themselves are considered largely fit for purpose. Said one interviewee, “The Community Standards are mostly fine, but they are not being enforced well enough.” BSR notes the important action taken against prominent users by Facebook before and during this assessment, including against individuals Wirathu, Thuseitta, and Parmaukkha; the groups Ma Ba Tha and the Buddha Dhamma Prahita Foundation; and senior military officials. » Implementing the Community Standards in Myanmar will continue to require substantial investment in Burmese and local staff with high-quality insight into the Myanmar human rights context. There is substantial consensus—among both external stakeholders and Facebook’s own staff—that effective implementation of the Community Standards in Myanmar requires Burmese staff with insight into the local context, such as cultural, political, conflict, ethnic, religious, and language factors. Several considerations were raised, including the need to avoid bias by hiring diverse staff, the need for a critical mass of staff to be located locally (or at least with market proximity in the same time zone), the benefits of hiring both policy- and product-oriented staff, and the desire for civil society organizations to be involved in staff training. As one interviewee remarked, staff enforcing the content standards “need to live and breathe Myanmar” and “build relationships with a wide range of organizations across Myanmar, not just the usual suspects.” BSR heard a good level of awareness of these considerations in subsequent discussions with Facebook. In addition, while keen to be a source of local insight for Facebook, local civil society organizations do not want to carry the burden of Community Standards enforcement. As one interviewee expressed, “At times it feels as if Facebook has outsourced the job to us, but we simply don’t have the resources to do it. We have a strong desire to be collaborative, but not to be relied upon.” A similar statement was shared by other interviewees involved in reporting suspected Community Standards violations. BSR notes Facebook’s significant investment in Burmese and Myanmar-focused staff underway—over 60 at the time of writing, and 100 by the end of 2018—and it will be important to revisit perceptions about the effectiveness of this investment over time. » Investment in local staff could raise expectations that Facebook will take a similar approach in other countries, so a clear human rights-based rationale will be needed. The considerable interest in Facebook investing in local country staff is unlikely to be unique to Myanmar. Indeed, one interviewee noted the 150+ countries using Facebook and speculated “whether content moderation can be scaled across all markets, and what human resource would be needed to make this happen.” Facebook can seek to apply human rights criteria when deciding whether to invest in staff with local market insights, such as the severity of the local human rights risks, Facebook’s market share in the country, and the leverage the company may have. BSR noted a good recognition among Facebook staff that the level of resources needed for Community Standards enforcement will