Transparency Requirements for Digital Social Media Platforms: Recommendations for Policy Makers and Industry

Abstract

This paper sets out a framework for transparency on the part of the larger digital social media companies in connection with their content moderation activities and the algorithms and data that involve the distribution of problematic content on their systems. It departs from the movement in many countries for content regulation and mandated take-downs, preferring instead to focus on creating a balanced and clear legal structure for disclosure that can help to restore public trust in digital platforms and provide assurances that they are operating in the public interest. It recommends a tiered system of transparency. Disclosures about content moderation programs and enforcement procedures and transparency reports are aimed at the general public. Disclosures about prioritization, personalization and recommendation algorithms are provided to vetted researchers and regulators. Vetted researchers are also given access to anonymized data for conducting audits in connection with content moderation programs, while personal data and commercially sensitive data are available only for regulators. This recommended transparency approach could be started through voluntary measures undertaken by the larger social media companies in conjunction with public interest groups and researchers, but its natural home is within a comprehensive system of regulation for the larger social media companies overseen by a government agency.

Keywords: social media, regulation, transparency, accountability, due process, content moderation