F2(d). Changes to algorithmic system use policies

The company should clearly disclose that it directly notifies users when it changes its algorithmic system use policies, prior to these changes coming into effect.

Elements:

1. Does the company clearly disclose that it directly notifies users about changes to its algorithmic system use policies?
   
2. Does the company clearly disclose how it will directly notify users of changes?
3. Does the company clearly disclose the timeframe within which it directly notifies users of changes prior to these changes coming into effect?
4. Does the company maintain a public archive or change log?

Algorithmic system use policies — Documents that outline a company’s practices involving the use of algorithms, machine learning and automated decision-making.

Clearly disclose(s) — The company presents or explains its policies or practices in its public-facing materials in a way that is easy for users to find and understand.

Change log — A record that depicts the specific changes in a document, in this case, a terms of service or privacy policy document.

Directly notify/direct notification — By direct notification, we mean that when a company changes or updates its policy that applies to a particular service, we expect the company to notify users of these changes via the service. The method of direct notification may differ according to the type of service. For services that contain user accounts, direct notification may involve sending an email or an SMS. For services that do not require a user account, direct notification may involve posting a prominent notice on the main page where users access the service.

Public archive — A publicly available resource that contains previous versions of a company’s policies, such as its terms of service or privacy policy, or comprehensively explains each round of changes the company makes to these policies.

Users — Individuals who use a product or service. This includes people who post or transmit the content online as well as those who try to access or receive the content. For indicators in the freedom of expression category, this includes third-party developers who create apps that are housed or distributed through a company’s product or service.

Indicator guidance: When companies change their algorithm use policies, these changes can affect users’ freedom of expression and information as well as their right to non-discrimination. Companies therefore should commit to notify users when they change these policies and to provide users with information that helps them understand what these changes mean. This standard is in line with the Council of Europe’s Recommendation of the Committee of Ministers to member States on the human rights impacts of algorithmic systems (2020).

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