Moderating User Generated Content
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- Ferdinand Todd
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1 Status of Guidance Note Guidance Note Moderating User Generated Content Issued: June 0 This Guidance Note, authorised by the Managing Director, is provided to assist interpretation of the Editorial Policies to which the Guidance Note relates. The Editorial Policies contain the standards enforceable under the ABC s internal management processes and under the ABC s complaints handling procedures. It is expected the advice contained in Guidance Notes will normally be followed. In a given situation there may be good reasons to depart from the advice. This is permissible so long as the standards of the Editorial Policies are met. In such situations, the matter should ordinarily be referred upwards. Any mandatory referrals specified in Guidance Notes must be complied with. Key Editorial Standards Excerpts of key editorial standards relevant to this Guidance Note are set out below. Other editorial standards such as.,.,.,.,.,.,.,. and. dealing with ABC independence, accuracy, impartiality, harm and offence and commercial references may also be relevant, depending on the specific circumstances applying in each case. Public access and participation. Free broadcast time or publication space may be provided to enable individuals or organisations to communicate directly with the ABC, the audience and each other, provided that: a the content is broadcast or published as a public service; b the content is relevant and suitable in the context in which it appears; c the ABC maintains editorial control; and d ABC independence and integrity are maintained.. Opportunities to participate must be administered fairly and respectfully.. Do not knowingly mislead audiences about the nature of the content.. Clearly distinguish content generated and submitted to the ABC from content produced, commissioned or acquired by the ABC.. Do not accept money or other benefit in exchange for broadcasting or publishing the content generated through public access and participation. Mandatory referrals All user generated content (UGC) published on ABC platforms must be moderated either pre-moderated, post-moderated or reactively moderated. Any proposal for post-moderation or reactive moderation of an interactive service must be approved by an appropriately senior ABC person designated for the purpose within the responsible division.
2 Any proposal to set up an ABC interactive service on a third-party site must be approved by an appropriately senior ABC person designated for the purpose within the responsible division and the division s Social Media Representative. Any threats of violence, self-harm or harm to other people or property or other security issues must be referred to the ABC Security Manager (0 0 or abc.security@abc.net.au) as well as upward referred to the relevant Editorial Manager. In the event that a threat appears to be insincere or a hoax, the matter must be referred as if it were genuine. Scope of this Guidance Note This guidance note applies to the moderation of user generated content appearing on ABC websites and on official ABC interactive services established on third-party websites, such as ABC accounts on external social media sites (Facebook, YouTube etc). User generated content includes text (comments, posts), photos, images, video and audio submitted for publication on ABC websites, official ABC presences on thirdparty sites or other interactive services. In the case of interactive services established by the ABC and specifically designed for children under the age of, refer to the Guidance Note Children and Young People: Managing their Participation Online. Introduction The ABC expects and welcomes contributions that stimulate debate and discussion or that reflect the diverse range of perspectives, experiences and imaginations of its audiences. While encouraging vigorous debate and critique, we expect all online users to treat each other with respect and courtesy. The ABC should be as transparent about the moderation process as possible. Our approach should be consistent across the online platform, taking into account different audiences and topics. This Guidance Note covers. What is Moderation? a. Moderation b. Types of moderation. Who Moderates? a. Role and responsibility of the moderator b. Moderation Plan c. Editorial responsibility and upward referral d. Registration e. Training. How to Moderate? a. Conditions of Use b. House Rules c. Moderation issues d. Privacy and identification e. Staff comments and contributions ABC Editorial Policies
3 f. Security g. Complaints. Moderating ABC Presences on Third-Party Sites. What is Moderation? a. Moderation Moderation is the review of user generated content and the decision to publish, edit or delete the content or at times to engage with the online community. Moderation is the ABC s main means of managing the risk of inappropriate user generated content being published by users. This risk varies according to a number of factors such as legal risks defamation, racial vilification, contempt of court or breach of copyright or editorial policy risks publishing material likely to cause harm or offence or material that could be perceived as advertising or commercial promotion. Managers of online communities associated with ABC programs and networks also need to consider the potential risk of inappropriate content to the reputation of the program, network and the ABC. b. Types of moderation There are three approaches to moderation in use at the ABC Pre-moderation All posts are moderated before they appear online. Pre-moderation enables the ABC to manage sites where the risk associated with publishing inappropriate content is high. This might include some news and current affairs sites, the discussion of sensitive or controversial topics, sites targeted at children or sites inviting submission of users photos, video or audio. The House Rules on pre-moderated sites might indicate that posts submitted overnight or on weekends may not appear online until the next working day. Post-moderation All posts appear online immediately which enables users to have a free flowing conversation unimpeded by the delays that occur when each post needs to be approved. All posts are moderated after they appear online. Post-moderation may be the most appropriate editorial choice where there is low risk that the topic might generate offensive or abusive content; the risk of users posting inappropriate content is considered low; or adequate moderation resources are available to ensure prompt and timely review of all submissions. ABC Editorial Policies
4 The rhythm of review will reflect the nature of the content, the online audience and the risk of inappropriate content remaining online for an extended period. In some circumstances it may be appropriate to revert to pre-moderation overnight or on weekends. Reactive moderation All posts appear immediately online. Posts are only moderated after the moderator receives an alert from a user. This form of moderation is often used in conjunction with post-moderation. Reactive moderation may be appropriate where a particular community has demonstrated a high degree of responsibility and an ongoing ability to manage themselves. It is more likely to suit topics which tend not to attract polarised or extreme responses. The decision about the appropriate moderation type is based on factors including target audience, history of audience behaviour and management, nature of topics, the availability of moderation resources, how long the ABC intends to continue to publish the UGC, and the platform. The choice to pre-moderate is not available on most third-party sites, including Facebook. Any proposal for post-moderation or reactive moderation of an interactive service must be approved by an appropriate senior ABC person designated for the purpose within the responsible division. Moderators should consider scheduling specific times through the day to moderate posts. Wherever moderator alerts are enabled, editorial managers should ensure there is a well managed system of accessing and dealing with the alerts as they are delivered via . The moderator must monitor the account regularly and act on alerts promptly. Good practice is to avoid lengthy delays. Such delays could have legal implications. Editorial managers and moderators should devise a Moderation Plan for monitoring and acting on alerts received after normal business hours. Editorial managers and moderators should ensure that all moderator alerts are dealt with as soon as possible.. Who Moderates? a. Role and responsibility of the moderator The moderator is the person who manages the online community for a particular site on behalf of the ABC. This may include: creating the Moderation Plan; getting approval for the plan (if required by the division); writing and posting the site s House Rules in accordance with the Conditions of Use; monitoring users behaviour on the site, including holding (or blocking or banning users) if and when required; ABC Editorial Policies
5 being editorially responsible for deciding whether UGC is published, edited or deleted according to the selected moderation type (pre-, post- or reactive) and consistent with the Editorial Policies, the Conditions of Use and the House Rules. The moderator s role is to be objective, impartial, respectful and fair. Moderators should strive to keep the interactive space safe for all users. They should generally ensure participants do not publish inappropriate personal information such as personal contact details. House Rules can be used to define this for the particular site. (See Privacy and identification below.) Moderators need to monitor the language and tone of contributions to keep the space attractive to potential users. They need to ensure the language of published posts and conversations does not become abusive, aggressive, bullying or intimidating. Moderators may act as online hosts posting opening welcome messages and closing notes. Moderators may publish moderator notices to stories and threads reminding users of the ABC Conditions of Use, the site s House Rules or specific moderation issues. In their role as hosts moderators may enter the discussion and post replies to audience questions on behalf of programs or sites in which case they should generally identify themself as the host. Moderators of successful community spaces find a balance between active facilitation and participation, and allowing the audience to drive a conversation. If moderators intend to take on the role of host as well as moderator they should seek advice from their editorial manager on distinguishing these roles. Moderators are not expected to routinely convey reasons for moderation, deletion or editing to individual audience members. However they should consider keeping records for occasions when moderation decisions are questioned by users or are the subject of a formal complaint. It may be appropriate to maintain file notes on significant incidents, or where an audience member has continued to ignore published House Rules, Conditions of Use etc. These notes may include screenshots. b. Moderation Plan Moderators should develop a Moderation Plan, preferably while planning the interactive feature. This will indicate who is editorially responsible for the content published; purpose of an interactive feature; resourcing, including detail of moderating over different times of the day, week and year; expected lifespan of the user generated content; moderators and panellists; specific moderation approaches adopted for different times; and include House Rules specific to the needs of the site. If these strategies include post- or reactive moderation the plan can indicate maximum likely delays in reviewing contributions or reviewing audience alerts. ABC Editorial Policies
6 Where post- or reactive moderation is to be used, prior approval must be obtained see Mandatory referrals above. c. Editorial responsibility and upward referral Editorial responsibility for the particular ABC site or ABC-managed spaces on thirdparty sites which includes the moderation of UGC must be clarified and documented. If there is more than one moderator for a site, it is particularly important for the lines of upward referral to be clear and for the editorial manager to be available for referrals. It is also important for there to be clear communication between all moderators and the editorial manager to ensure consistency in applying Editorial Policies, Conditions of Use and site House Rules (see below). If a moderator is unsure of the appropriate decision regarding a post submitted to a pre-moderated discussion space, the post should not be published, and the moderator should upwardly refer to their editorial manager. If the moderator is uncertain about a post already published to a post-moderated space and if the particular platform permits, they should remove it and seek advice as above. A moderator may also seek advice from ABC Legal regarding specific posts. However after considering this legal advice, the final decision about publishing the post rests with the moderator. If there are security threats moderators must upward refer to their editorial manager and to ABC Security immediately (see Security below). d. Registration Users may register a preferred username with the ABC. This requires them to use a valid address to receive an access password. It should be clear to users of ABC interactive services where they can register to participate. A user should be able to manage their registered online identity. e. Training All moderators should be trained in ABC moderating practices. This training should include ABC Editorial Policies; the Moderation Plan; techniques to manage online communities; an understanding of legal concepts including defamation, contempt, copyright, racial vilification and privacy; ABC complaints handling procedures.. How to Moderate? a. Conditions of Use Audience members contribute to all ABC interactive services under Conditions of Use developed in consultation with ABC Legal. The ABC s Conditions of Use may be supplemented, but cannot be overridden, by local House Rules tailored to a particular site or interactive service. The Conditions of Use and the House Rules must be readily accessible to users. ABC Editorial Policies
7 b. House Rules House Rules explain to community members how user generated contributions to a particular site are moderated, provide site specific rules for contributions and may highlight any grounds on which the ABC may refuse to publish, or may edit or remove, a contribution. Typical House Rules might describe the scope of the discussion on the site, or the type of content that audience members are invited to contribute. The House Rules might also detail the local site s approach to the editing of audience contributions, as well as length or duration of contributions etc. The House Rules can also simply re-state aspects of the Conditions of Use that may require reinforcement such as reminders about the inappropriateness of abusive behaviour or offensive language and the acceptable level of commercial references. It can also remind users to be aware of privacy and security issues in interacting online. c. Moderation issues Accuracy The ABC does not require content generated and submitted by individuals and organisations to meet the Editorial Policies standard of accuracy. However, where the ABC is satisfied that it is appropriate to do so, the ABC may decline to broadcast or publish, or may edit, remove, correct or clarify content generated by users that contains a significant material error or is otherwise false, misleading or harmful. Where UGC is to be incorporated into factual content, checks must be made to verify the accuracy of any factual material contained or presented within UGC. Critical / negative opinions The ABC takes a robust approach to criticism of its own content. Critical comments about ABC content, presenters or the issues canvassed in the program should be published. Posts that are abusive or defamatory of the presenter or any other program participant should be edited or not posted, consistent with the ABC s Conditions of Use and the site s House Rules. Impartiality Individuals and organisations who generate and submit content are not required to be impartial. The ABC recognises that social and political activity, including robust debate, is a necessary and desirable aspect of a healthy democratic community. Public discussion spaces reflect the views of their users. From time to time one particular side of the debate may dominate views expressed there. This simply reflects the natural flow of comments received. The ABC reserves the right to reject contributions that have already been widely canvassed in the discussions. It also reserves the right to reject contributions from users who seek to dominate the discussion. Offensive posts UGC will not be published if the ABC considers it to be abusive, offensive, bullying or violating laws such as defamation, harassment, discrimination or racial vilification. Such posts will be deleted from post-moderated and reactively moderated sites. ABC Editorial Policies
8 Copyright Moderators should delete or not publish a contribution they reasonably believe to be an infringement of copyright. Commercial references References to commercial brands in contributions may be acceptable if they are editorially justified, or contextually relevant. An acceptable commercial reference may include providing audiences with useful information in event diaries. UGC including login or user names that promote a particular brand, product or service will be deleted if the ABC determines the UGC is part of a marketing campaign. External links External links included in audience contributions should be checked initially or at the earliest opportunity, consistent with the moderation approach in use for the site, to ensure they link to appropriate and relevant content, particularly links to commercial products or services. Any links to illegal or offensive sites should be deleted. Off topic If a topic or range of topics has been clearly identified on the website, such as via the House Rules, off-topic contributions or comments can be deleted. d. Privacy and identification Moderators must be careful not to reveal unnecessarily personal information about themselves, their colleagues, or contributors to ABC online platforms such as Message Boards. On third-party sites, revealing personal information of users may be a feature of the site (e.g. Facebook). Moderators should be familiar with the ABC s Privacy Policy and relevant online Privacy Statements. As part of their duties moderators may have access to the personal information of users and contributors. This information can only be used for the purposes of managing the user s involvement in the particular community space. Moderators must not use this personal information in any other way. They should not reveal this information to anyone except where expressly authorised or required to do so by the ABC or where required under law. Some ABC sites may require that users do not use their real name. On other ABC sites audience members are able to participate using either their real name or a nickname or pseudonym. This decision is made by the relevant editorial manager and requirements or restrictions would generally be indicated via the House Rules and the Moderation Plan. Current ABC practice is generally not to reveal the identity of the moderator for privacy and security reasons. Records should be kept to enable editorial managers to identify who was responsible for moderation at a particular time. However this information should generally not be made publicly available. e. Staff comments and contributions Program staff and contributors may post responses to audience comments and questions. It would be appropriate for them to be clearly identified as ABC staff ABC Editorial Policies
9 associated with the content under discussion. Alternatively it may be appropriate for a moderator to post such a response on behalf of a contributor, program maker or program. The same criteria outlined in the Conditions of Use apply to all these contributions. Staff responding and participating in ABC community spaces on behalf of ABC programs or websites would be expected to identify their connection with the program. ABC staff are welcome to participate on ABC community spaces as private users but they should observe the principles developed to guide ABC staff in their use of social media (see the Use of Social Media Policy at ABC/~/media/Documents/Policies/EditorialPolicies/SocialMediaPOLpdf.ashx). f. Security Any threats of violence, self-harm or harm to other people or property or other security issues must be referred to the ABC Security Manager (0 0 or abc.security@abc.net.au) as well as upward referred to the relevant Editorial Manager. In the event that a threat appears to be insincere or a hoax, the matter must be referred as if it were genuine. Moderators on third-party sites should also refer such threats to the ABC Security Manager. Moderators should keep dated and signed file notes of any serious security incident associated with the moderation of ABC community spaces. g. Complaints Part of the rationale to the reforms to the ABC s complaints handling system is a recognition that the changing media environment provides audiences more options. They can engage with organisations such as the ABC, and can engage with each other via the ABC s forums. Commenting online is potentially a quick and informal alternative to making a formal complaint. ABC online spaces should be moderated in ways to facilitate the reforms.. Moderators must be familiar with the ABC s complaints handling procedures and know how to handle correctly any complaints or other direct audience contacts regarding moderation. If a post or submission asserts a serious editorial breach, a moderator should consider reviewing the incident and if necessary referring this on to the relevant program area and informing the contributor how they may make a complaint to Audience and Consumer Affairs.. Moderating ABC Presences on Third-Party Sites The ABC creates official presences on third-party sites, including social networking sites to engage with audiences online. Such pages or accounts or channels on YouTube, Facebook and Twitter and other third-party platforms are directly associated with ABC content and managed by ABC staff. It should be clear to users of the third-party site that they are interacting with a page, channel or other presence that is officially maintained by the ABC. There are also presences on third-party sites that are directly related to ABC content which are not official ABC presences and may be managed by co-production partners, distributors, other broadcasters or fans. Whilst there might be some risk of ABC Editorial Policies
10 reputational damage occurring through the perception that these sites are controlled by the ABC, the ABC does not usually restrict the establishment of these sites, and may have little or no control over their management. The ABC will request these sites clarify who has responsibility for the sites. For example information can be posted such as [Name of production company] is responsible for the content of this site. Such information should include a web or address where audiences can direct comments or complaints if required. Before the ABC uploads its content to a third-party site, or invites users to upload their content to a third-party site, the ABC must give consideration to the site s terms and conditions and whether there is a need to address legal and rights issues. ABC Legal and the ABC s Rights Management unit should be consulted as appropriate. In some circumstances, the ABC may need additionally to intervene and manage UGC submitted to the ABC s profile page, channel or other presence established on the third-party site. As social networking sites and other forms of user interactivity are evolving, the ABC needs to take a flexible approach to assessing when and how it intervenes. The approach adopted by the ABC in each case should be sensitive to the expectations, customs and conventions of existing users of the third-party site, and to the ABC s need to maintain its own reputation as an innovator with integrity. In considering how to handle particular circumstances it can be helpful to refer back to the Principles in section of the Editorial Policies, especially the reference to editorial responsibility being proportionate to the level of control. Related material ABC Conditions of Use ( ABC Online Privacy Policy ( ABC Shop Online Privacy Policy ( ABC Privacy Policy ( ABC/~/media/Documents/Policies/PrivacyPOLpdf.ashx) Protective Security Policy ( ABC/~/media/Documents/Policies/BusinessServices/ProtectiveSecurityPOLpdf.ashx) IT security Policy ( ABC/~/media/Documents/Policies/Technology/IT/ITSecurityPOLpdf.ashx) Use of Social Media Policy ( ABC/~/media/Documents/Policies/EditorialPolicies/SocialMediaPOLpdf.ashx) 0 ABC Editorial Policies
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