BSR | Human Rights Impact Assessment: Facebook in Myanmar 45 COMMUNITY STANDARDS ENFORCEMENT Recommendation Continue building a cross-functional team that understands the local context to lead the implementation of Community Standards in Myanmar. This team would provide insights into the local context (i.e., cultural, political, conflict, ethnic, religious, and language factors) that influence effective enforcement of the Community standards. This team would develop and apply more detailed guidance on Community Standards implementation and stay well-informed of emerging risks by engaging extensively with local civil society organizations, government entities, and other influential stakeholders. Some key considerations when hiring this team include: hiring a diversity of staff with a mix of ethnicities, languages, and perspectives; ensuring capability for both policy and product/engineering disciplines; ability to understand different Burmese dialects; ensuring 24/7 coverage for responsiveness; and undertaking spot checks for potential bias. BSR recommends that—as a long-term ideal, rather than a short-term measure—Facebook locate a small portion of this team in Myanmar, with the remainder located in other Facebook locations (such as Singapore, the U.S., and Ireland). The former will help ensure connectivity with the local context, while the latter will help ensure integration into important company decision-making processes and effective collaboration with other Facebook teams. There are risks associated with a Myanmar presence, such as increased government leverage over content restrictions and data requests, less room to take strong action against powerful military figures, or staff safety and security. For this reason, we recommend that various risk-mitigating approaches are taken (such as hiring expats able to leave the country at short notice) and that the Myanmar presence is reviewed periodically. The recent removal of senior military officials from Facebook will significantly delay the assignment of in-country staff. Implement a stricter interpretation of Facebook’s credible violence policy as it relates to misinformation. Community Standards enforcement often requires challenging judgements, and some so-called “edge cases” can create difficult dilemmas and nuanced choices for Facebook. BSR recommends that, in consultation with local civil society organizations, Facebook lower the threshold for misinformation that Explanation The creation of a dedicated in-country team was a near-uniform recommendation of almost every stakeholder BSR engaged with. This step is viewed as an essential precondition to a real understanding of the local context and the effective mitigation of human rights risk in Myanmar. However, it would be wrong to assume that an incountry team alone is sufficient, and there is a strong case for staff to be located in other Facebook locations as well. Moreover, risks associated with an in-country team are significant, and for this reason BSR is recommending a balanced approach that is reviewed periodically. We also believe that the in-country element of this recommendation should be delayed for some time following the removal of military officials from Facebook. BSR recognizes that Facebook has a virtual presence in nearly 200 countries and that this recommendation is not necessarily scalable globally. For this reason, BSR recommends taking a human rights-risk approach, where the creation of local teams is informed by criteria such as the severity of the local human rights risks, Facebook’s market share in the country, and the leverage the company may have to address human rights. These factors point toward the creation of a local team in Myanmar. Principle 19 of the UNGPs states that companies should “integrate the findings from their impact assessments across relevant internal functions and processes,” that “responsibility for addressing impacts is assigned to the appropriate level and function within the business enterprise,” and that “Internal decisionmaking, budget allocations and oversight processes enable effective responses to such impacts.” The majority of rightsholders and stakeholders that BSR engaged emphasized that too much harmful content was being allowed to remain on the platform. They emphasized the significant evidence that exists about the link between deliberate misinformation online and offline harms. This link was emphasized, for example, in the UN Human Rights Council Fact-Finding Mission on Myanmar.