Response from ITfC to the Draft 2.0 UNESCO Guidelines for Regulating Digital Platforms

Continuing our engagement with UNESCO's effort to formulate a set of ‘Guidelines for Regulating Digital Platforms’ to safeguard freedom of expression and access to information, IT for Change provided comments and recommendations on the Draft 2.0 of the Guidelines. We commend the second draft of the Guidelines for recognizing the impact of both platform content moderation and curation functions on freedom of speech and access to information, and for making a stronger reference to the UN Guiding Principles on Business and Human Rights to hold digital platforms accountable.

We appreciate the Guidelines for addressing some of the concerns that we raised about the earlier draft by incorporating the following:
•    Detailing the criteria for composition and scope of powers of independent regulators.
•    Requiring human rights compliance and transparency in respect of both content moderation and content curation functions performed by digital platforms.
•    Special attention to the employment status and conditions of work of human moderators as a factor affecting the quality of content moderation efforts.
•    Requiring digital platforms to conduct periodic undertaking of human rights due diligence of their policies and operations.
•    Specific attention to gendered disinformation and online gender-based violence.

However, we believe that the Guidelines are still not sufficiently attendant to the challenges of platform regulation, especially in the Global South; the architecture of corporate impunity that platforms benefit from and; and the need to address communication governance through a supra-liberal framework.

Read our full submission here.

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