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WG1: Reporting Tools Background info This paper contains a summary of the inputs received by the industry and NGOs to the questionnaire sent after the meeting held in February and major issues and solutions amongst the stakeholders. The final aim of this document is to provide guidelines for the CEO Coalition members to facilitate the implementation of reporting mechanisms within their services when it is needed or relevant. These mechanisms should be aimed at improving the management/treatment of grounded notices, while respecting the legal framework in place and fundamental rights. Accordingly, it should be further analyzed the impact that any proposed reporting mechanisms may have on data protection. There is a power point annexed to this document which contains best practices from different sectors in relation with reporting mechanisms already working and that could be deployed among the CEO Coalition members Following the statement of purpose, we have committed: To deliver robust mechanisms for reporting content and contacts that seem harmful to kids. These should be available across specific online services and devices, covering clear and commonly understood reporting categories, while avoiding regulatory double jeopardy in areas regulated by other means. Summary of the WG questionnaire After the meeting held on the 27th February, where CEO Coalition members and 3rd parties raised their concerns with regards to reporting tools, a questionnaire was circulated to identify those areas of improving and where an action where requested in relation with the scope, categories, escalation, feedback, design and location of the reporting tools. Here below you will find the summary of the responses received classified by industry and NGOs Industry Scope: There is a certain consensus on what kind of content should be reported. However, most players underline the dramatic difference, also in view of the follow up to be given to the reporting, between what is an illegal content and what is an inappropriate/harmful content In general Potentially harmful/inappropriate content or behavior such as pornography, racism, illegal, abusive or harmful material or activity, extreme violence, discrimination, bullying, grooming, identity theft or impersonation, material affecting the user's dignity, honor or ability to use the service freely. Almost every one thinks that content to be reported should be according to the existing regulatory framework. Categories: Regarding the categories there are two different kinds of reports identified: the ones regarding illegal activities and the ones that could be harmful to children or in breach with the provider’s Term & Conditions, but not illegal indeed. Categories could be helpful to escalate the reports and/or prioritize them. Taking into consideration the multiplatform approach and the diversity of issues that may be reported there was agreement amongst industry that is important to leave categories open. It seems important to educate kids on how to use the reporting system and to offer categories on what is harmful and not allowed within the service they are using. Escalation: Concerning who and how to report there is also a consensus among providers that they should receive the reports in the first place and then escalate them to the relevant helplines/hotlines or authorities as appropriate (this does not include material such as child abuse material, where many providers forward the user directly to appropriate hotlines or the national LEAs). It is also stated that common –but flexible- criteria could help to handle different types of reports and that the mechanism should be easy and accessible. Feedback: The service provider should offer clear information to users about the reviewing process where appropriate, and depending on the design of its process, the service provider may choose to offer additional information to users. Industry will work on improving the way they give feedback, so users reporting abusive or harmful content have more information on how their reports are handled. • Proposal: o Industry will work on improving the way they give feedback, so users reporting abusive or harmful content have more information on how their reports are handled. Design: There is no consensus whether it should be a unique design (text or graphic) or if it may differ among countries, platforms, providers or websites. Location: Regarding where the button/icon should be placed, they all agree that it should be visible, some think it has to be near the content to report, others in the main menu of the web site and a third group think it should be placed on the browser so that it is available for every web site. There is no unanimity about whether the button/icon should be placed on every website or only in those that allow user generated content. • Proposal: o For certain services and devices a good example of best practices seems to be to place the icon within the browser that enables users to get in direct contact with NGOs to seek help with a single click. However we need to bear in mind that there would be different services and devices that need to be taken into account. Industry proposes to work with NGOs/Hotlines in order to provide browser extension. o Also, mobile operators and other industry stakeholders will work to provide reporting Apps for connected devices. Non-governmental Organizations Their opinion is similar to that of industry, sometimes stating more categories, but essentially about the same types of behavior/content. Categories: They also agree to establish categories in order to make reporting more efficient and easy-to-prioritize. About the way to report they all agree that the system should be easy to find –visible for every platform- and easy to use – in order to promote reporting. They also add that the system should be transparent and the person reporting should be able to know the process of his/her report and to have a feedback once the issue is being analyzed. Design: Some see value in establishing one similar icon that could be identifiable across platforms and countries; nonetheless there is no consensus on this point. In fact some think that one single button would not work at all. Location: About where it should be placed it’s agreed that it should be in a visible place in any web site where there could be potentially harmful contents or behavior to children and youngsters. There is no consensus whether websites, providers or authorities should be responsible for this icon/button. State of art: Industry responses to issues raised by NGOs NGO DEMAND INDUSTRY REPLY The report mechanism needs to be easy to It is important to stress that there is no need find. It needs to be available for all users to have reporting tool in each single website, effortlessly, where problems tend to arise. Reporting tools should be available in appropriate locations in order to allow the user to report abuses. This excludes content that is fully controlled by the service provider and, thus, is no risk to minors. An extension in the browsers could be a solution for certain services and devices in cases where there is not reporting system in place or the platform is not offering them. The reporting tool should be available for Industry will work to identify ways to non-users of the service, so adults would not enable parents, carers and teachers need to register it they wish to report. making reports without having to sign up and register to the service in question, minimizing risks of high increase in false or abusive reports." However, the risk of the number of false or meaningless reports might rise, thus making it more difficult to timely and properly support those children who really have something to report. In any case, for hosting platform or social network not supporting anonymity, anonymous reporting cannot be a solution. Again, browser extensions managed by hotlines and NGO could be a solution to offer reporting tools for non registered user and, even, anonymous reporting (if the hotline, or the NGO believe this is an important feature). However, due consideration should be given to those cases where operators receiving the reporting keep the direct contact with the LEAs, in order not to lengthen the process. Testing and evaluation of the mechanism by The CEO Coalition companies support children should be necessary; it has to be appropriate testing and evaluation of easy to use. reporting tools in order to ensure that the tools are relevant and easy-to-use. Learning how to use the reporting system to Industry will assess possibilities how to avoid misuses. provide better information for users in order to make appropriate reports. Some industries may consider to invest in user education and digital literacy programs in relation to reporting tools. It is advisable to employ reporting options Child-friendliness is important, and the reflecting children’s own conception of the reporting options have to take this into problem (e.g. “embarrassing pics”), and to account and be understandable for all users. include the most common problems faced by users of the service and common online risk identified. Industry should structure these report NGOs have called for provision of feedback to mechanism in a way they provide feedback. users reporting harmful content, in particular giving evidence of the receipt of the notice. Some social networking providers have launched pilot projects to address this concern and provide users with a tool to monitor their reports and obtain feedback on how they have been handled. It has to be noted, that individual feedback to users who report is not always possible (depending on the number of reports received). In any case, it should be ensured that any feedback do not hinder LEAs investigations and do not violate the fundamental right of data protection. . Other services – for example the gaming sector – have raised concerns because of abuse potential in particular in interactive games. More generally, this cannot always be done, particularly if a criminal act is involved so this would need to be well-circumscribed. The report mechanisms should be The answer to this question is closely related independently reviewed or evaluated. There to the overall review process within the CEO needs to be a system in place for evaluating Coalition, by a self-declaration about how these mechanisms are working and if successful implementation of agreed they are being as effective as they can be. guidelines and independent review of achievements. Where process are in place the sharing of best practices will provide continuous input for companies to improve their reporting mechanisms on an ongoing basis Categories This graphic will summarize the input received by NGOs in relation with the categories that should be taking in account for the reporting systems. However, after analyzing several sites where there is UGC the categories proposed for reporting are largely overtaken this proposal. This should be taken as minimum set of categories to propose to costumers, where appropriate. These categories shouldn’t be an option for the user Final Recommendations In order to meet the goals of the statement of purpose, we have accepted with regard to ‘simple and robust reporting tools for users’, Industry proposes the following deliverables: • Mobile operators and other industry stakeholders will work to provide reporting Apps for connected devices; • Industry will work with NGOs/Hotlines in order to provide tools such as browser apps or direct links from websites and other messaging applications where appropriate and applicable for each different sector, to enable users to get in direct contact with NGOs/Hotlines to seek help with a single click; • Industry will work on improving the way they give feedback and providing updates on reports of abuse where appropriate and applicable for each different sector, while not hindering LEAs investigations, so users reporting abusive or harmful content have more information on how their reports are handled; • A minimum set of categories is proposed within this progress report (see above) to take into account for those services where UGC are hosted. Annex I (will follow) We have pulled together a slide deck summarizing the reporting tools already existing in the market (icons on website, apps for smartphones and browser extensions) as well as current practices for reporting systems of several CEO coalition members. (Facebook, Google, Habbo Hotel, Hyves, Orange, Tuenti, Vivendi). The slide deck includes new actions undertaken by certain CEO coalition members since the launch of the Coalition, in addressing the concerns expressed by third party stakeholders for example feedback to users, browser extension or apps for smartphones.
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