07 Feb RDR Raises Concerns About UNESCO’s Proposed Framework for Regulating Digital Platforms

On January 20, Ranking Digital Rights (RDR) submitted a comment to the United Nations Educational, Scientific and Cultural Organization (UNESCO) expressing concerns about the organization’s proposed “model regulatory framework for the digital content platforms to secure information as a public good.” The draft will be further discussed this month at a UNESCO conference in Paris.

The proposed framework seeks to guide the development of national laws and regulations governing online speech on the largest platforms, including Meta and Twitter, while also proposing modes of self-regulation. Positively, it encourages regulation that requires content rules compatible with human rights, transparent processes for content moderation, and systematic risk assessments. It endorses the Santa Clara Principles on Transparency and Accountability in Content Moderation, which RDR helped develop. 

RDR is an independent research program and human rights organization based at the think tank New America. We evaluate the policies and practices of the world’s most powerful tech and telecom companies and study their effects on people’s fundamental human rights, primarily through our yearly Corporate Accountability Index. Using this research, we push platforms hard to increase transparency and improve their respect for human rights. We have also conducted in-depth research on the role of the targeted advertising business model, a key driver of today’s massive proliferation of harmful content. 

We, therefore, strongly share UNESCO’s concern about the prevalence of harmful content on digital platforms, including hate speech, harassment, doxxing, misinformation, and other types of content that is damaging to freedom of expression and information, privacy, and other human rights. Much of this content disproportionately harms marginalized groups, creating additional barriers to their participation in civic discourse.

We also want to call attention to important problems with the proposed framework, and its development process, which will hamper its usefulness as a tool for addressing these shared concerns. These problems include:

• Unclear mandate: It is not clear that development of this framework is within UNESCO’s mandate. Its development should therefore not proceed without a decision by the UNESCO General Conference, the organization’s chief decision-making body. UNESCO should also cooperate closely with the UN Office of the High Commissioner for Human Rights, which could ensure that the Framework does not inadvertently harm freedom of expression. 
• Minimal consultation process: The draft was first published on December 19, 2022, with a deadline for public comment on January 20, 2023. This meant the public had only a month to provide their input, during a period when many people around the world are celebrating holidays. This truncated comment period disproportionately hampers organizations with limited resources, including those representing marginalized groups. Further, despite the fact that the framework is intended to be globally applicable, UNESCO does not seem to have proactively reached out to a diverse set of civil society stakeholders for input. 
• Neglect of the role of targeted advertising: As RDR has documented, the incentives for the amplification of harmful content stem directly from the targeted advertising business model. Among other harms it facilitates, this model rewards content providers and advertisers for publishing content (paid and unpaid) designed to attract and keep users’ attention for as long as possible. This incentive perverts the value of the internet as a trusted information source by amplifying the most sensational and extremist content to generate page views and, thus, advertising revenue. The best way to address harms without encroaching on the right to freedom of expression is by protecting the data that is used to create such advertising, and by regulating how companies and advertisers are then able to transform this data in order to target messages and ads. At minimum,  governments should require greater transparency and due diligence from tech companies about how ads are targeted and moderated. Unfortunately, the present draft framework calls only for encouraging—rather than enforcing—advertising transparency, and it does so only for political ads. 
• Lack of attention to inferred data about users: To expand the data available for targeted ads and user-generated content, platforms also often algorithmically infer information about their users. This inferred information has a high risk of being inaccurate and biased. Regulation should therefore require enhanced transparency around algorithmic inference, and the framework should incorporate guidance for how to mitigate the effects of inferred data on the amplification of hate speech, disinformation, and other information harms it seeks to address. More areas of concern are discussed in our full comment. 

We appreciate the intention of the framework’s draftees. We agree, however, with comments made by our civil society partners, such as the Global Network Initiative and Article 19, who have argued that its development should not proceed unless these issues are fully addressed.

02 Feb Proton’s Raffle: Helping RDR Keep Big Tech Accountable Globally in 2023

Back in December, our friends at secure and encrypted email service Proton Mail invited Ranking Digital Rights to be a part of their 2022 Lifetime Account Fundraiser. The Proton community was asked, in November, to select which organizations they wished to see rewarded. Money was raised through a raffle in December where winners were rewarded with a Proton Lifetime account. We were honored to be chosen, alongside 10 other fantastic organizations, including allies like Access Now and Fight for the Future. And we’re so grateful: The raffle sold 68,000 tickets and raised $784,670 total, $71,800 of which will be given to RDR.

For a decade now, RDR’s rankings have been helping push companies toward greater respect for, and protection of, people’s fundamental rights to freedom of expression and privacy. Our small team and more than a dozen researchers all over the world work relentlessly each year to produce the RDR Corporate Accountability Index, which offers a comprehensive look at the commitments to human rights of the world’s most powerful tech and telecom companies

In 2022, the RDR Index comprised the inaugural Big Tech Scorecard, released in the spring, and our first scorecard dedicated to telecom companies, the Telco Giants Scorecard, released in December. This research makes public a rich array of data on company policies, giving us and our allies the power to tell compelling stories about how telecom and tech companies are meeting (or failing to meet) their human rights obligations.

As RDR enters its 10th anniversary year, we’re focused on making sure that our standards are as accessible as possible to all those who might be able to use them to yield better human rights results in the tech sector, including policymakers, investors, companies, journalists, and, of course, our civil society partners. The generosity of Proton Mail users will go a long way in helping us achieve this goal.

This includes expanding the use of our standards by local digital rights organizations around the globe, particularly in the majority world. RDR is determined to address the information asymmetries that have allowed companies to pay less attention to human rights in parts of the world that rarely dominate tech policy headlines. This lack of dedicated resources has repeatedly resulted in human rights harms, as we’ve seen recently from Kenya to Myanmar.

Last year, we helped local digital rights organizations publish new research on the effects of telcos and tech companies in Lesotho, Angola, the Democratic Republic of Congo, Central African Republic as well as in Cambodia, Indonesia, Maldives, Nepal, Philippines, and Sri Lanka. This year, partners from Latin America to East Asia, will be releasing a total of 10 new reports using our methodology. Proton’s support will allow us to continue raising that number, bringing more local insight from those most affected by corporate behavior.

RDR’s standards and research also serve as an important touchstone for a large community of responsible investors. Over the past three years, we have recorded a number of notable achievements in this area. Our findings have directly informed a slew of recent shareholder proposals. A proposal at Meta we helped craft calling for a human rights impact assessment of its targeted advertising business model became the most successful shareholder proposal in the company’s history.

It’s only February and, RDR is already breaking new ground on upcoming proposals at Alphabet, Amazon, and Meta. But as a globally oriented human rights organization, we want to make sure that, once again, our standards are having an impact outside of the United States. Proton’s contribution will support RDR in developing ties with investors in “emerging markets” through new partnerships and collaborations. We’re also looking to expand our standards to address new technologies as they emerge. Finally, the contribution will help us bolster the use of human rights standards among ESG rating agencies, which have long been opaque about how they actually incorporate human rights criteria in their scores.

Without generous support, like that of the Proton Mail community and our other committed funders, RDR could not continue its essential work. And with that in mind, the whole RDR team wants to thank all the generous Proton Mail users who are already helping turn 2023 into a memorable year for holding the tech industry accountable for protecting our rights online.