UN Special Rapporteur on Minority Issues
[DRAFT FOR GLOBAL CONSULTATION]
feedback on these two notions and international law that would strengthen the current framing
would be appreciated.
Guideline 6
10. To what extent, should moderation systems (automated and human) incorporate different
languages and thus protection of a greater number of communities/societies around the world?
Any suggestions how this should be determined in a proportionate way would be instructive to
us.
Guideline 7
11. SMCs are asked to consult with those likely to be affected by online hate speech and in
particular minorities. What would be the best way to make this expectation measurable rather
than just aspirational?
Guideline 8
12. Can SMCs improve accessibility to and understandability of their policies on hate speech for nonEnglish speaking societies and minorities around the world where they operate? In such
markets, what should be expected of them?
Guidelines 9 and 10
13. These focus on ‘transparency’ reporting and increasing ‘researcher access’, specifically with the
reduction of hate speech and the protection of minorities in mind. Apart from recommending
the disaggregation of data by group/region and facilitating 3rd party independent research, are
there any other ways to strengthen these two Guidelines?
Guidelines under consideration and suggestions for additional Guidelines
14. There are a number of relevant issues that the Special Rapporteur is still undecided on the
necessity of dedicated Guidelines. These include:
o The right to redress and whether and how liability should be legally provided for failure
to comply with international human rights obligations,
o The ability to appeal to a 3rd party and
o Whether SMCs should be expected to proactively initiate public awareness and
education campaigns to help community members better understand hate speech
policies and for those likely to post such content to be dissuaded from doing so.
The Special Rapporteur would welcome views on whether any of these merit inclusion or there
are other significant omissions which he should consider adding to the Guidelines.
15. Connected to the above, the Special Rapporteur would welcome any views on whether SMCs
should be asked to conduct independent human rights assessments and how best to ensure that
they include considerations around hate speech generally and specifically about minorities.
16. The Special Rapporteur would also appreciate any views on whether the Guidelines would
benefit from a section that pointed to how ‘other actors’ could use the Guidelines in their
engagement with SMCs such as, but not limited to, advertisers, infrastructure providers,
intermediaries or gatekeeper (e.g. app stores), governments, regulators, international
organisations, civil society groups.
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