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Submission to the OPC’s Consultation on Online Reputation (Facebook)


August 2016

Note: This submission was contributed by the author(s) to the Office of the Privacy Commissioner of Canada’s Consultation on Online Reputation.

Disclaimer: The opinions expressed in this document are those of the author(s) and do not necessarily reflect those of the Office of the Privacy Commissioner of Canada.

Dear Commissioner Therrien:

Facebook appreciates the opportunity to comment on the Office of the Privacy Commissioner’s (OPC) Notice of Consultation and Call for Essays concerning Online Reputation. Empowering people to control their information—both online and off—is a critical part of protecting privacy, and Facebook values the OPC’s ongoing efforts to educate Canadians about the tools at their disposal to manage their information and protect their reputations.

The Value of Connection to Preserving Reputation

Facebook’s mission is to make the world more open and connected. In service of this goal, we work to give people the power to share what they want with the people they choose, and we believe that these efforts help to improve people’s lives, as well as our society. Indeed, research shows that Facebook enriches people’s relationships and their ability to stay in touch, leading to increased feelings of connectivity.Footnote 1

Facebook also provides a platform for people to create and shape their public reputations, and to speak publicly in their own voice when they believe doing so is valuable — something that was difficult or impossible for the average person before the advent of social media, when the ability to speak publicly was not in the hands of individuals, but instead had to be done through media outlets.

Canadians engage online and on Facebook because they wish to connect with friends, family, organizations, and ideas that are important to them. They do so primarily by sharing stories and information with each other — in the form of messages, photos, videos and links to resources throughout the Internet. This desire to connect and to share online is a hugely positive and empowering human instinct, and with the information, tools and resources needed to share and connect thoughtfully and safely, people can engage in social media to profoundly positive, and sometimes transformative, effect.

Reputation—and, importantly, the costs of reputation challenges—are not uniquely “online” issues. To be sure, the Internet has increased the ease with which information can be shared and has made the world more open and connected. In many cases, it has made it easier for people to understand what information is being shared about them. But the consequences that arise from reputational harm generally manifest themselves in the offline world.

Accordingly, our approach to reputation management necessarily involves not only innovative online tools, which we discuss below, but also deep community engagement to ensure that the protections available to people do not end when a person shuts off his or her computer monitor. To that end, Facebook has made significant technological investments on our platform with respect to online safety, and works closely with organizations such as MediaSmarts, Canada’s digital literacy organization, on resources such as Think Before You Share and our Youth Tip SheetFootnote 2 to ensure that we are giving people the information, tools and resources they need to control their experience while safely enjoying all that the Internet and social media have to offer. We applaud the OPC’s proactive approach to educating Canadians about these issues and look forward to working with the OPC and other interested stakeholders in similar public education efforts in the future.

Empowering People to Control their Online Reputations

The OPC has asked what practical or technical solutions should be considered to empower people to control their reputations.

A primary reason why Canadians go online and use services like Facebook is to connect and share. We keep in touch with friends and family, engage with organizations and causes we care about, and stay up-to-date on news and entertainment. And we reap the most benefit when we have the digital literacy and tools and resources to safely and fully enjoy a more open and connected world. With over 21 million Canadians—and 1.65 billion people globally—using Facebook each month, developing tools to help people control their information on our platform is critical. That is why Facebook has made such significant investments, both through the technology we offer on our service and through public education, to promote a welcome and safe environment for everyone. We make our rules regarding content on our service based on our goal of keeping people safe, and we develop tools and resources specifically to ensure people can control their experience on Facebook and feel safe when connecting and sharing.

Putting People in Control

A core aspect of the Facebook experience is our audience control — the simple ability for people to control who can see the things they choose to share. In addition to providing this choice individually for each of a person’s posts, Facebook also allows people to exercise retroactive control by changing the audience setting for content shared in the past, as well as allowing them to delete this content entirely.

We also make it possible for people to review all of their past activity in their Activity Log, which keeps track of such Facebook activities as the posts you create, posts you are tagged in, posts you “Liked”, and the comments you have made. People can see a centralized history of their activity on Facebook from their Activity Log, where they can review, delete or change the privacy of things they’ve posted in the past. Of course, people can also choose to delete their entire Facebook profiles at any time.

Facebook provides a variety of controls for posts that are related to you but do not originate from you. These controls can be found in the Timeline and Tagging settings, and allow people to control who can post on your Timeline (the centralized feed of stories about a person that they can manage on Facebook). People also can review posts that others tag you in before they appear on their Timelines or control who can see posts on their Timelines.

In all, we have built our service in an effort to help people understand what information exists about them on Facebook and to understand the choices that they have to manage that information.

Online Privacy Tutorials and Check-ups

In order to help people identify the privacy tools that can best meet their needs, we have developed a series of interactive, animated walkthroughs to provide answers to the most common privacy questions we receive. We call these walkthroughs Privacy Basics,Footnote 3 and they are designed to help people become familiar with the controls and choices we offer before they actually try to change their settings. Since we released Privacy Basics in late 2014, we have worked to add additional content, and today the modules cover a range of topics such as audience control, account security, and an explanation of how advertising works on Facebook.

In addition to providing privacy information on demand, we affirmatively prompt each of our users to review their privacy choices through Privacy Checkup,Footnote 4 a feature that we present when people log into Facebook. When people complete the checkup, we ask people to review and confirm their choice of who can see their next post, which apps they’ve granted access to their Facebook profiles, and who can see particular information that they have included in their Facebook profiles. Nearly 9 in 10 people (86%) who start Privacy Checkup finish all three steps.

Public Education

Although we work hard to provide robust and meaningful tools that help people manage their information, we realize that one size does not fit all, and that each person will have different preferences when it comes to the choice of what to share, and with whom. Accordingly, in addition to the educational resources we offer on Facebook, we have teamed up with MediaSmarts, Canada’s digital literacy organization, to develop public education materials. Our “Think Before You Share” guide provides tips about sharing and making decisions online. The guide advises people to self-monitor the material that they post online, recognizing the potential persistence of such material. The guide also encourages people to refrain from reposting or re-sharing material that could negatively impact an individual. The guide concludes with some tips on how to mitigate damage once material has been exposed, including the steadfast rule to refrain from acting while you are over emotional. “Think Before You Share” is available in both Official Languages, as well as in Cree, Inuktitut and Ojibwe.

More recently, we worked with MediaSmarts to create a Youth Tip Sheet that was based on a survey of Canadian teens attending the Digital Youth Summit in Ottawa in October 2015 (at which the Privacy Commissioner delivered the opening address). The tip sheet provides advice from teens directly to other teens about what they consider proper online etiquette.

Key Players and Their Roles and Responsibilities

As the OPC’s discussion paper highlights, there is a range of stakeholders—from individual people to community members and sharing platforms to governments—who enable people to manage their information, both online and offline. By far, the most important player in online reputation management is the individual. Only individuals can decide what information they want to share or evaluate the context in which that information is most appropriately shared. Likewise, it is at the level of the individual—or, more specifically, interactions between individuals—that the benefits and risks of online reputation arise, and where action to manage reputation can have the most impact.

Indeed, one of the most successful methods for resolving concerns on Facebook is our social reporting feature, which allows people to communicate with friends or others on Facebook when they see something that concerns them.Footnote 5 For example, if there is a post about you that you would like to see removed, you can click the “Report post” option on the top right corner of a post. In addition to being able to block, unfollow or unfriend the person who posted the content, or report the content to Facebook, our reporting flow offers the option to communicate directly with the person who shared the content — just as people would do in the offline world.

These social reporting tools were developed after years of research in conjunction with Yale University, which found that refining the reporting process as well as refining the language used in reporting could create an environment where people (reporters) can accurately convey their feelings in a manner that allows the content creator (poster) to be highly receptive.Footnote 6 This environment encourages people to speak out and provides content creators with an opportunity to learn about how their actions affect people. Facebook provides the mechanism for direct communication between the reporter and the poster, along with suggested default language for such communication, which we found increases the success of social reports by roughly 50%.Footnote 7 We have seen nearly 85% of social reporting communications result in either the poster taking down the objectionable content or the poster responding to the reporter and engaging in a dialogue. When surveyed, 65% of posters reported positive feelings about the reporter and another 25% reported neutral feelings.Footnote 8 As the OPC continues its work on online reputation, we hope the Office will find ways to encourage more research and investment in how technology can facilitate interpersonal resolution.

Regulators like the OPC, along with community authorities such as non-governmental organizations, community advocates and others, also have an important role to play. These authorities are in the best position to deliver practical and unbiased education to the range of Canadians who connect and share online about both the consequences of sharing information—both positive and negative—and about the tools that Canadians have at their disposal to manage this information.

While the greatest focus in education must be on individuals, it is also true that individual people exist in communities. When people experience negative reputational consequences, those consequences are manifested almost exclusively in the communities in which people engage. For instance, even when bullying begins on a website, the reputational consequences generally appear in the offline world, where existing authority figures—whether teachers and administrators in a school or police officers in a community—have the best visibility into the interpersonal relationships and behaviors that impact reputation.

The Charter of Rights and Freedoms enshrines the ability of every Canadian to communicate freely, and it protects Canadians’ right to express their views, even when those views may be unpopular or controversial.Footnote 9 But when people’s conduct—whether online or offline—crosses the line from legitimate speech to criminal activity, Canadians are fortunate to live in a society that has strict and effective laws to counter misconduct, whether it takes the form of harassment or of improper discrimination in employment. Our laws do not differentiate based on whether wrongful conduct occurred online or offline, and the government officials who police our communities are empowered to enforce them where appropriate.

The operators of online sharing platforms like Facebook necessarily have a limited perspective on the implications of people’s sharing. For example we cannot, from both a privacy and practical standpoint, proactively review every piece of content that is shared on our service, so we rely primarily on reports from people who use our service and have concerns about something they have seen. Even when we do have specific content that is reported to us, it is often difficult for us to know whether reported content is benign and factual, a joke, or an instance of bullying. Despite these limitations, we understand that our success depends on people’s safety and confidence in our community, which is why we have worked hard to build rules that encourage the responsible use of Facebook.

The cornerstone of this effort is our Community Standards, which set forth the expectations that we have for everyone who communicates using our service.Footnote 10 One of our standards deals directly with bullying and harassment, specifying that Facebook will remove pages that identify and shame private individuals when reported to us. This includes altered images that degrade an individual and the sharing of personal information to harass the victim. Our Community Standards also encourage respectful behavior, and we will remove content identified as hate speech.

In addition to our social reporting tools, people can also report content in violation of Facebook’s Community Standards using the “Report post” option that accompanies content posted on Facebook. Choosing this option leads to a series of questions that help us assess the reported content and to properly classify reported content before it is reviewed. Following this classification, a team of reviewers evaluates reported content against our Community Standards, takes action as appropriate, and provides a report on the result to the person who made the report.


At Facebook, we believe strongly in empowering people to control their information and to providing a community for sharing that is safe and trustworthy. We also have found that the most effective solutions for reputation management are bottom-up, not top-down. To that end, we have invested heavily in education and have worked closely with organizations such as MediaSmarts, Canada’s digital literacy organization, on resources such as Think Before You Share and our Youth Tip Sheet.

We appreciate the OPC’s effort to highlight and evaluate the important issue of protecting people’s reputations, and we look forward to working with the OPC and other stakeholders to promote public education and digital literacy regarding these critical issues.

Respectfully submitted,

Kevin Chan
Head of Public Policy
Facebook Canada

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