Letter - Regarding Insufficient Human Rights Due Diligence 

30 October 2024 

To Sir Nick Clegg, President of Global Affairs, Meta 

CC: Neil Potts, VP, Public Policy, Trust & Safety 

Miranda Sissons, Director of Human Rights 

Dear Sir Clegg, 

We, the undersigned civil society organizations, are writing to you to express our disappointment in Meta’s insufficient action to address key problems related to its content moderation actions as outlined in the Business for Social Responsibility’s (BSR) 2022 report Human Rights Due Diligence of Meta’s Impacts in Israel and Palestine in May 2021, including on the disproportionate over-moderation of Palestine-related content. Meta's most recent annual update and the lackluster response to some of BSR's key recommendations reflect the company's ongoing failure to uphold its essential human rights obligations. 

The publication of the BSR report back in September 2022 following a recommendation from the Oversight Board, alongside Meta's public response to the report, was a much-welcomed and reassuring step that signaled the company's seriousness towards assuming accountability for its human rights responsibilities. However, both the September 2023 and 2024 annual reports raise concerns over whether Meta is serious about implementing the report’s 21 recommendations. In addition, we note that two years since the HRDD was published and Palestine-related content is still over-moderated while inflammatory speech in Hebrew is running rampant. This is especially disappointing in the wake of recent events in Israel and Palestine, and the many documented digital rights violations that have taken place on Meta’s platforms over the last year, which put to test measures implemented by Meta since the 2022 BSR report. 

Meta's response to the 2022 BSR recommendations remains insufficient, particularly in addressing the moderation of hostile speech in Hebrew. Despite claiming improvements in routing Arabic and Hebrew content post-October 7, the updates lack transparency and tangible evidence of effective moderation. Meta’s implemented measures failed to address the proliferation of illegal and harmful content in Hebrew since October 7, including direct and public incitement to genocide by Israeli army officials and politicians.

The continued opacity around the processes and tools used for content moderation, especially regarding the handling of hate speech in Hebrew, is alarming. Meta’s efforts to expand regional Arabic dialect routing and establish Hebrew classifiers are still incomplete. Moreover, there is lack of progress on several key recommendations—such as disclosing formal reports from government entities, increasing transparency in enforcement actions, and ensuring fair application of content policies—indicating a failure to address critical gaps. These key recommendations also echo recommendations that have been made by the Oversight Board in myriad cases, including recommendations that Meta claims it has implemented or classified as work it already does. 

Though it is clear that Meta has taken action to make important changes and improvements, the level of investment and commitment is insufficient to meet the scope of the challenge. We urge Meta to continue providing updates on their progress in implementing the BSR report, but the reports should provide greater transparency, data, and accuracy metrics for changes implemented, to allow for proper public scrutiny. 

In addition to fully implementing all of the BSR reports’ recommendations, we also ask that Meta take the following actions to ensure that it is operating in accordance with the United Nations Guiding Principles on Business and Human Rights (UNGPs): 

1. Commit to prevention, mitigation and remediation of adverse human rights consequences by: 

a. Guaranteeing recurrent comprehensive, meaningful and actionable Human Rights Impact Assessments with regards to the company’s practices and policies in Israel and Palestine. The resulting continuous human rights due diligence processes should be participatory and systematically involve civil society organizations among other relevant stakeholders. HRIAs should be conflict-sensitive and take into account the company's impact on conflict dynamics. Ad hoc due diligence reports focused on human rights impact should be proactively issued after periods of crises, like the one in May 2021 in Palestine and the current war on Gaza. All mentioned assessments should reflect on the necessary mechanisms to mitigate harms that have been identified, diagnosed, and forecasted. 

b. Providing users with the chance to respond to content takedowns and notify them of the reasoning behind decisions on content moderation in all circumstances, including if the takedown was in response to a government

request invoking Meta’s Community Standards. Additionally, offer users the possibility of asking for a human review of those decisions. 

c. Investing in adequate resources and attention to guarantee a timely, uniform, and effective responses to appeals and reports from users and Trusted Partners alike. 

2. Commit to full transparency: 

a. Publish key elements of internal policies and procedures, including but not limited to data around the accuracy, precision, and recall of Meta’s Hebrew classifier, the list of Dangerous Organizations and Individuals and the designation criteria, where and how Meta platforms rely on automated decision-making for content moderation, and evidence of Meta’s claim that it monitors for over and under enforcement of policies during times of crisis. 

b. Publish complete information about the implementation of notice and takedown mechanisms, more particularly about government requests - both legal and voluntary - submitted by the Israeli government and the Israeli Cyber Unit, specifying the volume and including all data related to the request and subsequent actions taken by Meta. Furthermore, include all and any relevant information from the report directly in the Transparency Center. 

3. Commit to co-design: 

a. Commit to a meaningful co-design process with civil society and other critical stakeholders on the ground (engagement should not be limited solely to trusted partners) to improve policies and processes involving Palestinian content. 

Endorsed by: 

- 7amleh - The Arab Center for the Advancement of Social Media

- Electronic Frontier Foundation (EFF) 

- SMEX 

- Access Now 

- Digital Action 

- Gulf Centre for Human Rights (GCHR) 

- Masaar 

- ALQST For Human Rights 

- INSM for Digital Rights 

- ARTICLE 19 

- The De|Center 

- Kandoo