3. Transparency
3.1 should publish their content restriction policies online, in clear language and in accessible formats, keep them updated as they evolve, and notify users of changes as appropriate1.
3.2 When content is restricted in a product or service of the intermediary that allows to display a notice when trying to access, the intermediary should display a clear notice that explains what content was removed and why2.
3.3 In the actions of prioritization of online content accessible to the user (feeds, search results and others) the commercial nature of the communications, the sponsored content as well as the electoral or political propaganda should be clearly identified, identifying the contracting party and without raising doubts about its meaning3and being transparent about the content metadata (prices, etc.).
3.4 Platforms should inform their users in a clear, explicit and accessible way4, at least on what respects to:
a. What types of content and activities are prohibited in your services?
b. What are the criteria and mechanisms for curation and moderation of content? Which are directly controlled by the user and which are not?
c. In what cases, when and how does content analysis automation apply?5
d. In what cases, when and how does the human review of content apply? This question makes particular reference to the criteria for decision making to avoid affecting human rights, taking into account the context, the wide variation of idiomatic nuances and the meaning and the linguistic and cultural peculiarities of the contents subject to a possible restriction6
e. How many moderators do you have, describing in detail your professional profile (experience, specialization or knowledge), your spatial location and your distribution of tasks (in terms of themes, geographical areas, etc.)?
f. What are the rights of users regarding the content generated and published by themselves and the policies applied by the company in this regard?
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1 Manila Principles
2 Manila Principles
3 Based on Agreement between EU with Facebook, Google and Twitter, 2018 “Better social media for European consumers”
4 To «allow users to predict with reasonable certainty what content places them on the dangerous side of the line» (Regulation of content on the Internet, Special Rapporteurship on the Promotion and Protection of the Right to Freedom of Opinion and Expression, 2018)
5 Regulation of content on the Internet, Special Rapporteurship on the Promotion and Protection of the Right to Freedom of Opinion and Expression, 2018
6 Ídem
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