Joint-Civil Society Response on the Commission’s Guidelines for Providers of Very Large Online Platforms and Very Large Online Search Engines on the Mitigation of Systemic Risks for Electoral Processes

This response was prepared by more than a dozen civil society organisations working across Europe. Together we commend the Commission for its efforts to protect elections.

We would like to draw attention to an area critical to achieving this aim: recommender system safety.

Ensuring recommender systems are designed safely is crucial for preserving electoral integrity. In addition to the safety measures the Commission proposed, such as introducing friction and circuit breakers, which we wholly support, we urge the following two critical steps for Very Large Online Platforms (VLOPs) to address the problem at its heart:

1. disable profiling-based recommenders by default - prioritising privacy, preventing exploitation.

2. move away from engagement-based ranking - away from a system designed to favour and incentivise extreme and emotive content.

Long-term, we call for the creation of alternative, rights-respecting recommender systems that promote active user choice, allow third-party content curation, and eliminate predatory and addictive design elements.

Click here to read our full letter.

Signed,

1. AI Forensics
2. Centre for Peace Studies from Croatia
3. Defend Democracy
4. Digital Action
5. Ekō
6. Eticas Foundation
7. Foundation The London Story
8. Global Witness
9. Institute for Strategic Dialogue (ISD)
10. Irish Council for Civil Liberties
11. #jesuislà
12. Real Facebook Oversight Board
13. The Citizens
14. Panoptykon Foundation
15. People vs Big Tech
16. Politiscope

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Democracy is in crisis and 2024 will be its biggest test yet. With critical elections due to take place across the world amid the wrecking ball of viral disinformation and deepening polarisation, the choices made by social media companies – and those who regulate them – will have profound consequences for years to come.

As Europe faces crucial elections, and alarmed by the backward slide of our democracies, 56 organisations are urgently calling on European leaders to meet this challenge head on. We ask you to take decisive action to safeguard the integrity of the election information environment, protect people’s rights as voters and set a global standard that others may follow.

The critical first step is for the European Commission to use its new powers under the Digital Services Act to require Big Tech companies to publish robust and comprehensive election plans - outlining publicly how they intend to mitigate “systemic risks” in the context of upcoming national and EU elections.

As a minimum, election plans must include meaningful transparency and mitigation measures to:

1. Deamplify disinformation and hate

Tech platforms have shown they can switch on measures to make content less viral at critical moments. They must, as a matter of course:

• Make their recommender systems safe-by-design, by default and all the time (not just during election periods), including measures to suppress the algorithmic reach and visibility of disinformation and hate-spreading content, groups and accounts.
• Implement meaningful user control features, including giving users clear options to choose over which types of data are used for ranking and recommending content and the ability to optimise their feeds for values other than engagement.

2. Ensure effective content moderation in every European language

The tragic impacts of viral hate speech in Ethiopia, Myanmar and countless other places show content moderation is worthless if not properly and equitably resourced. Tech platforms must:

• Properly resource moderation teams in all languages, including both cultural and linguistic competency
• Make content moderation rules public, and apply them consistently and transparently.
• Pay moderators a decent wage, and provide them with psychological support.

3. Stop microtargeting users

The potential to exploit and manipulate voters with finely targeted election disinformation is an existential danger for democracy. The solution is to:

• End processing of all observed and inferred data for political ads, for both targeting and amplification. Targeting on the basis of contextual data would still be permitted.
• Enforce the ban on using sensitive categories of personal data, including data voluntarily provided by the user, for both targeting and amplification.

4. Build in transparency

Elections are for the people, not social media companies. Tech platforms must not be allowed to shape the fate of elections behind closed doors – instead, they must:

• Be fully transparent about all measures related to political content and advertisements, including explanations of national variations in the measures they put in place, technical documentation about the algorithms used to recommend content, publication of ad libraries and their functionality (as well as ad financing) and full disclosure of content moderation policies and enforcement including notice, review and appeal mechanisms.
• Allow researchers and wider civil society to independently monitor the spread of dis/misinformation and potential manipulation of the information space by sharing real-time, cross-platform data, including: content meta-data; information on content that is demoted, promoted and recommended and tools to analyse data.
• Provide training for researchers, civil society, independent media and election monitors to monitor activity on the platforms.
• Facilitate independent audits on the effectiveness of mitigation measures adopted in the context of elections and publish their results.

5. Increase and strengthen partnerships

Companies are not experts in elections. They must work with those who are.

• Companies must meaningfully engage with partners such as fact-checkers, independent media, civil society and other bodies that protect electoral integrity, taking into account partners’ independence and reporting on their engagement in a standardised format.
  

Alongside the European elections, over 50 other countries will be going to the polls in 2024 – and even in the remainder of this year, several crucial elections are due to take place. Very large online platforms pose significant global risks if they fail to safeguard people and elections in the coming year. In making full use of its powers, the European Commission has a critical opportunity to lead the way globally in demonstrating that platforms can bring their operations in line with democracy and human rights.

Signed, the following organisations active in the EU,

AI Forensics

AlgorithmWatch

Alliance 4 Europe

Association for International Affairs (AMO) in Prague

Avaaz Foundation

Centre for Peace Studies

Centre for Research on Multinational Corporations (SOMO)

Checkfirst

Coalition For Women In Journalism (CFWIJ)

Corporate Europe Observatory (CEO)

Cyber Rights Organization

CyberPeace Institute

Defend Democracy

Delfi Lithuania

Democracy Reporting International gGmbH

digiQ

Digital Action

Donegal Intercultural Platform

Doras

Ekō

Epicenter.works

European Federation of Public Services Unions (EPSU)

Eticas

EU DisinfoLab

European Digital Rights (EDRi)

Federación de Consumidores y Usuarios (CECU)

Global Witness

Gong

HateAid

Institute for Strategic Dialogue (ISD)

Irish Council for Civil Liberties

Kempelen Institute of Intelligent Technologies

LGBT Ireland

NEVER AGAIN' Association

Panoptykon Foundation

Pavee Point Traveller and Roma Centre

SUPERRR Lab

The Daphne Caruana Galizia Foundation

The London Story

The Rowan Trust

Transparency International EU

Uplift

Waag Futurelab

Women In Journalism Institute - Canada

#jesuisla

#ShePersisted

Endorsed by the following global organisations;

Accountable Tech

ANDA - Agência de Notícias de Direitos Animais

Consortium of Ethiopian Human Rights Organizations (CEHRO)

Fair Vote UK

Full Fact

Global Action Plan

Legal Resources Centre

Open Britain

Rede Nacional de Combate à Desinformação-RNCD BRASIL

Tech4Peach

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