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Have you read the Internet for Trust Participation Guidelines?Have you read the full draft 2.0 Guidelines on Regulating Digital Platforms?Did you participate in the Internet for Trust Conference?How did you participate in the event?Specific Channel Question/FormFeedback in Original Language (if not English)
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AppendixN/AReferences on terminology: the phrase “on digital platforms” lists social media networks, search
engines, app stores and content-sharing platforms. It is suggested to add in messaging systems (to
encompass eg. WhatsApp, Fb messager, Telegram, etc.) which are also used as vectors for hate
speech and disinformation, even though they do not algorithmically amplify or rank content and are
more difficult to moderate than more open platforms.		Emailed CommentsGroup 3. Civil Society and MediaN/AN/AN/AN/AEmailedN/A
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Document titleN/A[DEL: Guidelines] [ADD: guiding principles] for regulating digital platforms:
A multistakeholder approach to safeguarding freedom of expression and access to information
Emailed CommentsN/AN/AN/AN/AEmailedN/A
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General comments on the drafting processN/AWe understand that UNESCO is managing requirements and requests across a diversity of
stakeholders and we thank you for continuing to ensure that independent regulators, who will in
many cases implement the digital regulations you are discussing, are a key stakeholder around the
table.
We appreciate that, given the multi-stakeholder consultation, you are receiving sometimes
conflicting feedback from different groups, making it difficult to decide where to land in the
guidelines. It is for this reason that we propose a more concise and high-level set of guidelines as
described above, focused on the key components of regulatory design, which would facilitate
consensus. Removing some of the details around content moderation, platform activities and
specific assessments would help expedite agreement amongst the diverse stakeholder groups
involved in the consultation of these guidelines. This would not close the door on UNESCO developing further specific guidance and advice on specific issues (e.g. human rights and gender-responsive risk assessments, considerations for human rights respecting content moderation, specific arrangements required for independent regulatory systems, etc.) developed in partnership
with experts and specific stakeholder groups, including to reflect evolving evidence in the area of
digital regulation, and collating existing best practices (e.g. around regulatory independence).
Finally, we would ask UNESCO to conduct further consultations on the guidelines and the initiatives
related to the guidelines, like the proposed network of regulatory networks. We think it would be
incredibly helpful to streamline the subsequent rounds of consultation if UNESCO were to provide an
explanation for the amendments it makes in draft 3.0, including where relevant by reference to
feedback received from different constituencies. It might also be useful and help advance this
process if UNESCO were to enable a dialogue (e.g. through workshops or roundtables) between
interested parties over the next draft, rather than simply continue to generate new written versions
of the guidelines.		Emailed CommentsGroup 1. Public Sector (member states, executive, legislative, and judicial branches of government, regulatory bodies, state entities)N/AN/AN/AN/AEmailedN/A
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General comments on the drafting processN/A- The document must not constitute a binding document or one that sets procedural precedents regarding the way in which the problem should be addressed by the States, in the understanding that the document was not adopted as the result of an intergovernmental negotiation and that it probably has not been given. within the States the processes of studies and debates necessary for the adoption of a more complete position regarding the way in which the problem should be addressed so that it does not imply an impairment of the right to freedom of expression and other fundamental human rights.
- Regarding the problem of disinformation on the Internet within the framework of the Human Rights Council, in March 2022, Resolution 49/21 "The role of States in the fight against the negative effects of disinformation on the enjoyment of and the effectiveness of human rights" states "that disinformation can negatively affect the enjoyment and effectiveness of all human rights and that States play an essential role in the fight against disinformation" (OP1 A/HRC/RES/ 49/21).
Likewise, said Resolution expresses its concern "over the growing and profound negative impact that the deliberate creation and dissemination of false or manipulated information with the intention of deceiving and confusing the public has on the enjoyment and effectiveness of human rights, either to cause harm or for personal, political or financial gain". However, neither in the document nor in its precedent, Resolution 76/227 "Counter disinformation to promote and protect human rights and fundamental freedoms" of the General Assembly of the United Nations refers to "the criminal effects of the disinformation".
Both Resolutions, in particular the one adopted within the framework of the Human Rights Council, call on States to ensure that their responses to the spread of disinformation are in line with international human rights law and that their efforts to counter disinformation promote, protect, and respect the right of individuals to freedom of expression and the freedom to seek, receive, and disseminate information, as well as other human rights; as well as urge States to adopt multidimensional and collective responses that conform to international human rights law.
The centrality of the focus on the person and human rights, respect for the plurality of sources of information and respect for freedom of expression, the role of the state in terms of digital transformation to promote and guarantee human rights, universalize access to connectivity, guarantee inclusion, protect vulnerable and hypervulnerable groups, combat misinformation and seek multi-stakeholder and multi-level participation in technological developments and solutions, among other aspects.
All developments of new technologies or regulatory approaches must have the person as the center ("human-centred"); Digitization/digital transformation must be respectful of people's human rights, both as workers and as consumers and users. Digitization/digital transformation must strengthen consumers and protect them from possible abuses, especially hypervulnerable consumers"; Specifically regarding regulation of platforms, it is emphasized: Promote the right to freely receive truthful information, combat misinformation and promote free Choice of services and digital content The digitization process must be developed in a sustainable and agile manner, with the participation of all stakeholders, promoting multi-stakeholder and multi-level public-private partnerships, State protection.		Overall SurveyGroup 1. Public Sector (member states, executive, legislative, and judicial branches of government, regulatory bodies, state entities)ArgentinaYesYesYesIn person: I was in Paris for the event at UNESCO.Overall Survey- El documento no debe constituir un documento vinculante o que siente precedentes procedimentales acerca del modo en que el problema deba ser abordado por los Estados, en el entendido que el documento no fue adoptado como fruto de una negociación intergubernamental y que probablemente no se ha dado al interior de los Estados los procesos de estudios y debates necesarios para la adopción de una posición más acabada respecto del modo en que se debe abordar el problema para que no implique un menoscabo del derecho a la libertad de expresión y otros derechos humanos fundamentales.
- En relación al problema de la desinformación en internet en el marco del Consejo de Derechos Humanos, en marzo de 2022, se adoptó la Resolución 49/21 "El papel de los Estados en la lucha contra los efectos negativo de la desinformación en el disfrute y la efectividad de los derechos humanos" se afirma "que la desinformación puede afectar negativamente al disfrute y la efectividad de todos los derechos humanos y que los Estados desempeñan un papel esencial en la lucha contra la desinformación" (OP1 A/HRC/RES/49/21).
Asimismo, dicha Resolución manifiesta su preocupación "por el creciente y profundo impacto negativo que tienen sobre el disfrute y la efectividad de los derechos humanos la creación y difusión deliberadas de información falsa o manipulada con la intención de engañar y confundir al público, ya sea para causar daño o para obtener beneficios personales, políticos o financieros". No obstante, en el documento ni en su antecedente, la Resolución 76/227 "Contrarrestar la desinformación para promover y proteger los derechos humanos y las libertades fundamentales " de la Asamblea General de las Naciones Unidas se hace referencia a "los efectos criminales de la desinformación".
Ambas Resoluciones, en particular la adoptada en el marco del Consejo de Derechos Humanos, exhortan a los Estados a que se aseguren de que sus respuestas a la propagación de desinformación se ajustan al derecho internacional de los derechos humanos y que sus esfuerzos por contrarrestar la desinformación promueven, protegen y respetan el derecho de las personas a la libertad de expresión y a la libertad de buscar, recibir y difundir informaciones, así como otros derechos humanos; así como instan a los Estados a que adopten respuestas multidimensionales y colectivas que se ajusten al derecho internacional de los derechos humanos.
Debe subrayarse la centralidad del enfoque en la persona y los derechos humanos, el respeto por la pluralidad de fuentes de información y el respeto a la libertad de expresión, el rol del estado en materia de transformación digital para promover y garantizar los derechos humanos, universalizar el acceso a la conectividad, garantizar la inclusión, proteger a los grupos vulnerables e hipervulnerables, combatir la desinformación y procurar la participación multiactor y multinivel en los desarrollos tecnológicos y en las soluciones, entre otros aspectos.
Todos los desarrollos de las nuevas tecnologías o los abordajes regulatorios deben tener a la persona como centro ("human-centred"); la digitalización/transformación digital debe ser respetuosa de los derechos humanos de las personas, tanto en su faceta de trabajadores como en la de consumidores y usuarios. Una digitalización/transformación digital debe fortalecer a las y los consumidores y protegerles de posibles abusos, especialmente a los consumidores hipervulnerables"; Específicamente sobre regulación de plataformas, se enfatiza: Promover el derecho a recibir libremente información veraz, combatir la desinformación y promover la libre elección de servicios y contenidos digitales. el proceso de digitalización debe desarrollarse de forma sostenible y ágil, con la participación de todos los actores, promoviendo alianzas público- privadas multiactor y multinivel; tutela del Estado.
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General comments on the drafting processN/AWe suggest that the draft can be made available for a longer period of time, which will allow a more accurate analysis of the recommendations, and the presentation of possible changes.Overall SurveyGroup 3. Civil Society and MediaBrazilYesYesNoOverall SurveyN/A
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General comments on the drafting processN/AWith regards to the process, we maintain our stance that tight deadlines, shorter times to study non-English versions, and limited participation in open debates regarding the contents of the documents themselves, do not constitute a constructive manner to address the need for broad, inclusive, transparent, participatory discussion. This extends to the need for recognition of regional consultations as a valuable way to collect input from different contexts.
We strongly believe that this process should not be subject to hard deadlines, and beyond that, it should not be subject to a specific type of output, before the full discussion has been finalised. In our understanding, UNESCO has to ensure meaningful transparency regarding the whole process, publicising the documents, making public the inputs by different stakeholders, and opening documentation for public and regional consultations.
Overall SurveyGroup 3. Civil Society and MediaChileYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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General comments on the drafting processN/AWe thank UNESCO for launching a consultation process for draft 2.0 and subsequent drafts. This process could be more effective if UNESCO publishes a clearer work plan, in which it makes public the consultation dates to follow as well as the different forms of participation. In addition, future consultations would benefit from adopting a multilingual and multigeographical approach.Overall SurveyGroup 3. Civil Society and MediaColombiaYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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General comments on the drafting processN/AThe drafting process should expand its capacity for dialogue with all the actors involved so that the very way in which it is done can contribute to the necessary changes in mentality in order to make the internet a true space for harmonious coexistence through its guarantees of respect, peace, education and enriching exchange.Overall SurveyGroup 4. Academia and Technical CommunityCubaYesYesYesOnline: I watched the event on livestream.Overall SurveyEl proceso de redacción deberá ampliar su capacidad de diálogo con todos los actores implicados de manera que la propia forma de hacerse pueda contribuir a los necesarios cambios de mentalidad en el hacer de internet un verdadero espacio de convivencia armónica por sus garantías de respeto, paz, educación e intercambio enriquecedor.
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General comments on the drafting processN/AAs an Institution with experience and expertise on human rights and business and technology, we would appreciate further involvement in the process of developing these guidelines then what we have seen so far. Please see link to our work on technology and human rights here: https://www.humanrights.dk/technologyOverall SurveyGroup 1. Public Sector (member states, executive, legislative, and judicial branches of government, regulatory bodies, state entities)DenmarkYesYesYesOnline: I watched the event on livestream.Overall SurveyN/A
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General comments on the drafting processN/ABesides the current process it would be very useful also to have a sort of a summary guidelines on one page!Overall SurveyGroup 3. Civil Society and MediaDenmarkYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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General comments on the drafting processN/AI think this process is valuable and UNESCO has the legitimacy to lead it, but I would encourage you to take a step back, work on a less ambitious timeline, and hold more comprehensive, local public consultations to gather a wider array of input. In addition, and this is a small point, please provide the questions for these online surveys as a PDF or ideally as a Word document, so we can draft our responses and paste them into the survey as it does not auto-save.Overall SurveyGroup 3. Civil Society and MediaGermanyYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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General comments on the drafting processN/A2.The drafting has to keep in mind that,the Societies and organisations have been used for transfer or money siphon activity with the scope of unabridged power in their hands.Overall SurveyGroup 4. Academia and Technical CommunityIndiaYesYesYesOnline: I watched the event on livestream.Overall SurveyN/A
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General comments on the drafting processN/ACivil society is the root of Democracy. India has seen invaders destruction of society culture and heritage. We are both the pioneers and the suffering persons.Overall SurveyGroup 4. Academia and Technical CommunityIndiaYesYesYesOnline: I watched the event on livestream.Overall SurveyN/A
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General comments on the drafting processN/ARegions and languages ,moderation resources , automated processes . content & digital platforms transparencyOverall SurveyGroup 3. Civil Society and MediaIndiaYesYesYesOnline: I watched the event on livestream.Overall SurveyN/A
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General comments on the drafting processN/AEach section is well written and identified.Overall SurveyGroup 4. Academia and Technical CommunityMexicoYesYesYesOnline: I watched the event on livestream.Overall SurveyEstá bien redactado e identificado cada apartado.
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General comments on the drafting processN/AWe need more time and more spaces to discuss seriously the regulatory framework.Overall SurveyGroup 3. Civil Society and MediaMexicoYesYesYesOnline: I watched the event on livestream.Overall SurveyN/A
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General comments on the drafting processN/AWe welcome the opportunity to comment, and hope that future drafts can be shared among a wider community, including in particular that associated with the Internet Governance Forum, in order to ensure the full range of views can feed in - a number of people we consulted around the guidelines who are strongly implicated in the IGF had not been aware of this work, which is a shame, given the importance of this initiativeOverall SurveyGroup 3. Civil Society and MediaNetherlandsYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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General comments on the drafting processN/ATherefore, we would like to submit that the UNESCO and other stakeholders must consider these ground realities while proposing and finalizing these guidelines.Overall SurveyGroup 3. Civil Society and MediaPakistanYesYesYesOnline: I watched the event on livestream.Overall SurveyN/A
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General comments on the drafting processN/AAll written comments should be made available on a public databaseOverall SurveyGroup 4. Academia and Technical CommunitySouth AfricaYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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General comments on the drafting processN/AAccountability
Transparency
Rule of Law
Domestic Affairs
Negotiations 		Overall SurveyGroup 1. Public Sector (member states, executive, legislative, and judicial branches of government, regulatory bodies, state entities)United Kingdom of Great Britain and Northern IslandsYesYesYesOnline: I watched the event on livestream.Overall SurveyN/A
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General comments on the drafting processN/AIt would be better for feedback forms like this one to allow contributors to upload documents, or at least to format their comments on each paragraph with line breaks and links.Overall SurveyGroup 4. Academia and Technical CommunityUnited Kingdom of Great Britain and Northern IslandsYesYesNoOverall SurveyN/A
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General comments on the drafting processN/ASpecific sessions with stakeholders to address detailed sections of the guidelines could be useful to address the inconsistencies and the often vague/broad languageOverall SurveyGroup 4. Academia and Technical CommunityUnited Kingdom of Great Britain and Northern IslandsYesYesYesOnline: I watched the event on livestream.Overall SurveyN/A
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General comments on the drafting processN/AWe understand that UNESCO is managing requirements and requests across a diversity of stakeholders and we thank you for continuing to ensure that independent regulators, who will in many cases implement the digital regulations you are discussing, are a key stakeholder around the table.

We appreciate that, given the multi-stakeholder consultation, you are receiving sometimes conflicting feedback from different groups, making it difficult to decide where to land in the guidelines. It is for this reason that we propose a more concise and high-level set of guidelines as described above, focused on the key components of regulatory design, which would facilitate consensus. Removing some of the details around content moderation, platform activities and specific assessments would help expedite agreement amongst the diverse stakeholder groups involved in the consultation of these guidelines. This would not close the door on UNESCO developing further specific guidance and advice on specific issues (e.g. human rights and gender-responsive risk assessments, considerations for human rights respecting content moderation, specific arrangements required for independent regulatory systems, etc.) developed in partnership with experts and specific stakeholder groups, including to reflect evolving evidence in the area of digital regulation, and collating existing best practices (e.g. around regulatory independence).

Finally, we would ask UNESCO to conduct further consultations on the guidelines and the initiatives related to the guidelines, like the proposed network of regulatory networks. We think it would be incredibly helpful to streamline the subsequent rounds of consultation if UNESCO were to provide an explanation for the amendments it makes in draft 3.0, including where relevant by reference to feedback received from different constituencies. It might also be useful and help advance this process if UNESCO were to enable a dialogue (e.g. through workshops or roundtables) between interested parties over the next draft, rather than simply continue to generate new written versions of the guidelines.


Note: Although we believe much of the detail in draft 2.0 should be moved to separate guidance documents, to be developed separately, we are nonetheless providing paragraph-specific feedback on the content of draft 2.0. We have commented both on paragraphs we recommend to be retained and on those that we have recommended removing.
Overall SurveyGroup 1. Public Sector (member states, executive, legislative, and judicial branches of government, regulatory bodies, state entities)United Kingdom of Great Britain and Northern IslandsYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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General comments on the drafting processN/AThe commenters recommend an advance notice of the full consultation schedule, through to the expected completion date, and an opportunity to comment on that schedule, as well as an indication of which specific topics will be of interest for UNESCO at each consultation opportunity. This will allow civil society commenters to appropriately deploy limited resources.
In addition, it would be useful if the online commenting platform supported rich text for formatting and linking. 		Overall SurveyGroup 4. Academia and Technical CommunityUnited States of AmericaYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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General comments on the drafting processN/A- A multistakeholder approach is essential going forward to ensure inclusion of all voices with expertise and a stake in platform regulation.
- Greater coordination across different actors and initiatives will also be key to avoid duplicating efforts. This is particularly important across the UN as we see different processes taking place.
- We should find new ways of working together, to seek to understand shared challenges and act together on our joint responsibility to build together. This means working across the public-private sector divide and ensuring that the most marginalized and disadvantaged voices are heard. Embracing meaningful multistakeholder engagement – for which there is robust international best practices and guidance – is an important lesson for this UNESCO initiative and for many others.
- Approaching this and other UN processes, namely the Global Digital Compact, can not only preserve, but fortify, the best things about the Internet — that is, the concept of Internet Freedom and the resilience of an open, interoperable, reliable, and secure Internet. And, it should prompt us to reconsider and recommit to areas where we can all do better, for example in ensuring multilateral efforts that embrace meaningful multistakeholder engagement on digital governance issues.
- The greatest value to the broader UN process could be in taking a principles-based approach, around which meaningful consultation and thus coordination could take place in the coming year. 		Overall SurveyGroup 2. Private Sector (companies, industry representatives)YesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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General comments on the drafting processN/AI am pleased to hear there will be thematic consultations around the next draft. The International Science Council would be prepared to convene a meeting of representatives from its 250 member institutions to allow organised science to offer perspectives in view of the points raised in 12 above.

It is noticeable that some of the most empirically vulnerable groups have not been represented in substantive discussions on the guidelines. (A number of studies indicate that as a professional class, scientists now face a level of online harassment and censorship comparable to journalists.) 		Overall SurveyGroup 4. Academia and Technical CommunityYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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General comments on the drafting processN/AWider consultation with grass roots organisations and individuals.Overall SurveyGroup 3. Civil Society and MediaYesYesNoOverall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AThe title needs to be amended. In this regard, adding: "ensuring public interest and protecting users against harmful content" as incorporated in the below is requested.
“Guidelines for regulating digital platforms: "ensuring public interest and protecting users against harmful content" while safeguarding freedom of expression and access to information”		Emailed CommentsGroup 1. Public Sector (member states, executive, legislative, and judicial branches of government, regulatory bodies, state entities)Iran, Islamic Republic ofN/AN/AN/AN/AEmailedN/A
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General comments on the overall draft 2.0 GuidelinesN/AThere are some terms in the guidelines which need more precision and clarification. For instance, there is a big difference between freedom of opinion (which should be absolute) and freedom of expression (which should be limited). This means that you can have any opinion that you like but when you want to express this opinion, you need to be limited as its expression might be peaceful or not. There thus needs to be clarification in the guidelines. Emailed CommentsGroup 1. Public Sector (member states, executive, legislative, and judicial branches of government, regulatory bodies, state entities)LibyaN/AN/AN/AN/AOutcomes of the electoral workshop_08.03.2085N/A
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General comments on the overall draft 2.0 GuidelinesN/AReading through the draft, I felt supply-side narratives heavily influenced it because there are few demand-side narratives and terminologies.Emailed CommentsGroup 4. Academia and Technical CommunityN/AN/AN/AN/AEmailedN/A
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General comments on the overall draft 2.0 GuidelinesN/AThe opportunity to comment on V.2 is appreciated, and it is hoped that the points above are taken in
the spirit they are intended, namely as a constructive contribution to a very important endeavour.		Emailed CommentsGroup 3. Civil Society and MediaN/AN/AN/AN/AEmailedN/A
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General comments on the overall draft 2.0 GuidelinesN/AThe scope of the guidelines, where they address online platforms, should be clarified. The guidelines note that it is up to regulators to decide how the breadth of the rules corresponds to the size of the regulated platforms, but the fact that the two should be proportionate to one another is a major principle of platform regulation that should be included in the guidance.Emailed CommentsGroup 1. Public Sector (member states, executive, legislative, and judicial branches of government, regulatory bodies, state entities)N/AN/AN/AN/AEmailedN/A
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General comments on the overall draft 2.0 GuidelinesN/ATo support the reframing of the guidelines, these could open by restating that the free flow of ideas across borders is mutually reinforcing our global democracies, and that no regulatory initiative should jeopardise this. Equally, the guidelines should state explicitly that freedom of expression needs to be fully respected offline if any national regulatory initiative on platforms is to improve it online. All of the requirements for a functioning democracy should subsequently be restated. References to existing rule of law programmes and further progress that is required in the relevant areas (e.g. independent judiciary) could be inserted here as well. Turning to online platforms, the guidelines should note that these services have a role to play to facilitate this free flow of information and ideas, and to keep citizens safe, in all countries in which they operate. This role includes a need to resist illegitimate government interference. Note that with this access to cross-border online information, the primary response to the risks associated with that same access lies with local societies, not with local platform regulation. As a reminder, the EU’s Digital Services Act in this context sees 27 Member States coming together to ban themselves from imposing general monitoring obligations on platforms.
After this first introductory section, which could be called ‘reinforcing global democracies’, the guidelines could move to a subsequent section entitled ‘a whole-of-society response’, which should cover all actors other than global online platforms, and which would focus on digital skills education, fact-checkers, independent media and all other primary tools to promote freedom of expression and safety. In a third section, the guidelines could then address ‘the responsibilities of global online platforms’, looking specifically at how large online platforms have a role to play in facilitating this global effort to improving the status quo.
A final section would then address ‘global regulatory frameworks for online platforms’, where the emphasis would lie on regulation as a process-focused tool, to be coordinated at a global level, to ensure large, global platforms take their responsibility. This final section would restate that the starting point is that regulation is conditioned upon democratic standards being respected in the first place, and that any such initiative should not address online platforms in isolation, but should identify all actors in the societal response to illegal content and societal risks, and subjecting all actors to transparency so as to give agency over online content moderation to society at large, never to any one actor – be they platforms, governments, regulators, fact-checkers, etc.		Emailed CommentsGroup 1. Public Sector (member states, executive, legislative, and judicial branches of government, regulatory bodies, state entities)N/AN/AN/AN/AEmailedN/A
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General comments on the overall draft 2.0 GuidelinesN/AVersion 2 improves much on Version 1, in terms of conceptualization and condensing issues into
clear principles. Creating international benchmarks by which stakeholders can assess regulatory
arrangements at regional or national levels, is a very valuable exercise. As always, however, the
elaborating of principles is one thing, but if they do not anticipate the challenges of real situations,
the chances of them having impact are limited.
On the ground, much current regulation is state-led, rather than representing a multi-stakeholder
movement. This situation correlates with many rules are being drawn up and implemented in ways
that threaten to harness platforms as part of the state apparatus – which is not always friendly to
freedom of expression. Regulators are weak and also lack independence. (There is also a crying need
for prioritization and modularity in focusing regulatory arrangements on particular issues (eg.
elections), rather than trying to cover the entire waterfront of issues. Such modularity could be
discussed as a helpful approach to “eating the elephant” in the Guidelines).
Commendably, the Guidelines in version 2 do underline the importance of independence in
regulatory arrangements. However, taking account of realities, it is very hard to envisage changes
here – meaning that this part of the Guidelines will lag, and even undercut the other parts. If key
decisions are made by compromised regulators in isolation, then legitimate expression on the
platforms could be a casualty.
Thus the Guidelines could do well to encourage a perspective that presents governmental
involvement in regulation as one (significant) element, but also as one that optimally works alongside

that of other actors in regulation. This would signal the many advantages of having a bigger co-
ordinated picture for regulation, even in cases where regulators are problematic in various respects.

Without this, the risk is to encourage replacing platform power with governmental power. In very
many cases, these may fail to promote information as a public good but instead end up limiting
legitimate expression like criticism of authorities. Proposing that corporate and state powers take
account of civil society interests, through institutionalised multistakeholder modalities, is a way
forward. It can help protect free expression while systemically countering content that harms human
rights and works against information as a public good.
The making of content-related rules by authorities (including regulators), and within this frame by
companies themselves, can benefit enormously from meaningful civil society participation. Similarly,
the massive work of implementation, monitoring, oversight and review of these rules can also be
enriched in the same way. UNESCO has an opportunity in the Guidelines to really highlight the
centrality of multistakeholder arrangements in regulatory measures. This would do a lot to aid the
insights and arguments of actors working for positive change of the status quo in platform
governance that aligns with protection of freedom of expression. In summary, the value of
multistakeholder governance as a sine qua non could be better and more consistently presented.
Some points elaborating this argument in relation to specific sections of the Guidelines follow below.		Emailed CommentsGroup 3. Civil Society and MediaN/AN/AN/AN/AEmailedN/A
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General comments on the overall draft 2.0 GuidelinesN/AWe are grateful to UNESCO for taking on board a great deal of our initial feedback in this revised
version of the guidelines and for hosting us and others at the Internet for Trust conference.
This second draft of the guidelines has rightly focused on systems and processes, but new additions
have unhelpfully widened that focus. In order to serve as a useful point of reference for any country
seeking to introduce platform regulation, the guidelines should be more concise, starting with a
clear stated purpose/goal (serving as such a point of reference) and a brief explanation of each of
the core components that any digital regulation regime should have. We believe these core
components are:
• regulatory independence
• the concept of platform responsibility (as manifested through obligations to carry out risk
assessments and develop risk mitigation plans)
• systems and processes-based regulation – notably this includes, but is not limited to,
systems for content moderation, as pointed out by Christopher Wylie at the conference
• supported by robust transparency obligations (and by extension, information-gathering
powers for regulators).
We heard from many stakeholders at the UNESCO Internet for Trust Conference that the guidelines
as they currently stand mention a large number of specific issues related to digital regulation, like
content moderation and user empowerment tools, but then do not adequately provide sufficient
nuance and explanations in each case. We agree with this commentary and in fact would go further
– we think that the more detail and prescription, the less likely it is that these guidelines will
ultimately achieve consensus and, importantly, be able to serve as a useful point of reference for the
development of digital regulation globally. Rather, we believe a more concise set of guidelines
focused on the key components of digital regulation and at the level of regulatory principle, are key
to building consensus across the diversity of stakeholders and being useful to the key constituencies.

2
Topics that are in this way removed from the guidelines could nonetheless be used to develop
further specific implementation guidance for stakeholder groups engaging in digital regulation.
On this basis, we would suggest that draft 3.0 follow the following structure and focus on the
following content:
1. Purpose: It should be made clear upfront that the guidelines are intended to provide a
recommended path to rights-respecting digital regulation. To that end, they provide a
foundational toolkit for legislators, regulators and platforms. We would, however,
discourage the express reference to particular forms of online harmful content (whether
illegal, like CSAM, or legal, like disinformation), as ideally the guidelines – given their
grounding in systems and processes - should be relevant to any digital regulation regime,
whatever its focus. (Paragraphs to be included in this section: 8-12, 16-17)
2. Core components
a. Shared responsibility/duty of care: The foundation of a digital regulation regime
should be recognition of the shared responsibility between the platforms and the
independent regulators. In the UK, this has been translated as a concept of a duty of
care on platforms. (Paragraph 21, 31, 13)
i. Independent regulatory systems, with information gathering and
enforcement powers (Paragraphs 37-39, 44-45)
ii. Governments and regulators (Paragraphs 24-27)
iii. Industry (Paragraphs 50, 28b-28e)
iv. Civil society and researchers (Paragraphs 32-34)
v. Intergovernmental organisations (Paragraph 30)
b. Systems and processes: Regulation should focus on the systems and processes used
by platforms (i.e. the choices made by platforms in the design and operation of their
services, including their algorithms) (Paragraph 18-20)
i. Transparency obligations (and supporting information-gathering powers) are
the primary regulatory tool for platform accountability (Paragraphs 67-69)
To note, other organisations like the OECD and GNI have already published
detailed and in-depth consulted best practice transparency frameworks. We
would suggest focusing on general principles of transparency in this section,
given the existing work done in this space.
ii. Risk assessments are the primary means by which platforms are required to
take responsibility for their choices and the uses made of their services, as
noted above. They should be carried out regularly by platforms, in relation
to all risk areas identified by the relevant national regulations, including
around the impact of the services/their design, including content curation,
on human rights. There is currently no general paragraph including risk
assessment. We suggest the following language be added:
“Risk assessments related to all areas of risk identified by national
regulations should be conducted on a regular basis by platforms. These risk
assessments should be an anchor for decision-making within a platform,
informing how platforms approach the design and operation of their
services, and the mitigations they deploy to address residual risk. Moreover,
responsibilities for risk management should be clearly specified and owned

3
at the most senior levels, and risk management activities should regularly
report to senior decision-makers. Finally, risk assessment activities should be
highlighted in transparency reporting to regulators and the public, and
independently scrutinised where possible.”
iii. User empowerment tools are likely to play a key part in keeping users safe
online, and platforms should ensure these tools are clearly available and
easily usable (Paragraphs 75-77, 82-84, 86, 89-91)
iv. Researcher access to data is an important component of digital regulation in
order to supplement (sometimes limited) regulatory resources, helping to
mitigate information asymmetries between platforms and regulators, in
order to help hold the platforms accountable (Paragraphs 72-74)
v. Media literacy and equipping users to better understand what’s on offer and
to make informed choices, is increasingly important, and regulation should
focus on the demand side, not only on the supply side (Paragraphs 77, 79-
81).
We also think the paragraphs on media literacy should make reference to
UNESCO’s work on media literacy, the work of the UNESCO MIL Alliance and
the detailed guidance already developed by UNESCO to shape national
media and information literacy strategies and policies.

As mentioned above, we suggest that other content currently contained in the guidelines could be
used and refined to create separate implementation guidance, targeted at specific audiences,
including:
• Risk Assessments: specific guidance on human rights and gender-responsive risk
assessments (Paragraphs 92-98), and emergencies, conflict and crisis assessments (104-105)
• A human-rights approach to content moderation (Paragraphs 28a, 52-54, 56-63, 65-66, 70-
71). The Council of Europe have already published guidance on content moderation that
could be useful for this exercise.
• Specific arrangements required for independent regulatory systems (Paragraphs 41-43, 47-
49)
Emailed CommentsGroup 1. Public Sector (member states, executive, legislative, and judicial branches of government, regulatory bodies, state entities)N/AN/AN/AN/AEmailedN/A
38
General comments on the overall draft 2.0 GuidelinesN/A
12 years ago we conducted research with in-depth interviews with children about their interactive cultural consumption. We analyze common sense and debtrto dd business models of the tranas of video games and networks

We send you by mail the last 2. 2021 and 2022 and the recomfbdaciknes. We would like to show in images in Paris how the plots of video games and networks aimed at children and the new business models work.
Overall SurveyGroup 1. Public Sector (member states, executive, legislative, and judicial branches of government, regulatory bodies, state entities)ArgentinaYesYesOverall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AThe document focuses on the topic of "content moderation and curation", which refers to algorithms and platforms that manage content created by human users. This issue has been crucial in the second decade of the 21st century.
However, the document risks becoming outdated quickly since the looming challenge is that of "content generation": algorithms and platforms that generate new content, bypassing human users. The issue of "content generation" is only mentioned in section 98.d related to gendered disinformation, but it should have greater relevance throughout the entire document.		Overall SurveyGroup 2. Private Sector (companies, industry representatives)ArgentinaYesYesNoOverall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/A• We thank UNESCO for its efforts in providing a second draft of the Guidelines, which we believe contains many improvements from the initial version. We particularly welcome the inclusion of human rights safeguards, mentioning the importance of language and context for content moderation as well as the inclusion of civil society in promoting media literacy.

• Additionally, we are grateful for UNESCO hosting the Internet for Trust conference, which provided a platform for multi-stakeholder engagement and better understanding of many of the issues raised in the Guidelines.

• We take note that Draft 2.0 no longer includes provisions for access to a platform representative in the countries where platforms operate. Given the attention which Draft 2.0 gives to local context in regulating content this seems counterintuitive.

• We welcome that the Guidelines in para 10 recognize that differences in size, scope and of financial model of platforms require different regulatory processes. However, the Guidelines should also include recommendations on what this means for regulating various platforms.

• What could be added to the introduction is a general context for the relevance of the topic: why is freedom of expression and access of information a concern today? What are some of the phenomena/problems and concerns/public discussions the Guidelines respond to?

• For us it is still somewhat unclear who should be included in the regulatory system. We understand that some discretion is needed to allow to accommodate to a range of different regulatory systems. However, we would like to see further clarification on the potential role of platforms and civil society within the regulatory framework, as well on its mandate (national, regional or international).
Overall SurveyGroup 1. Public Sector (member states, executive, legislative, and judicial branches of government, regulatory bodies, state entities)AustriaYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AIn general, the guidelines propose adequate measures to enable citizens to better exercise their rights on online platforms. The emphasis on co-regulation in the Guidelines also allows for a better redistribution of normative and decision-making power in the digital sphere, which currently remains in the hands of a limited number of private actors. However, the lack of a platform-based approach in the Guidelines risks causing over-regulation of small players, and may even prevent the development of new content platforms in the future.Overall SurveyGroup 4. Academia and Technical CommunityBelgiumYesYesNoOverall SurveyDe manière générale, les lignes directrices proposent des mesures adéquates afin de permettre aux citoyens de mieux exercer leurs droits sur les plateformes en ligne. La mise en avant de la co-régulation dans les lignes directrices permet également de mieux redistribuer le pouvoir normatif et décisionnel dans la sphère numérique qui reste actuellement dans les mains d'un nombre limité d'acteurs privés. Cependant, l'absence d'approche basée sur l'importance des plateformes dans les lignes directrices risque de causer une régulation excessive pour des acteurs de petites tailles, voir pourrait empêcher le développement de nouvelles plateformes de contenus à l'avenir.
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General comments on the overall draft 2.0 GuidelinesN/AWe welcome that UNESCO’s commitment to extensive stakeholder consultations, which is also reflected in its significant revisions of its previous draft in response to the comments it received. In addition to the comments we submitted during the UNESCO Global Conference “Internet for Trust” in Paris in February, we would like to propose the following remarks and amendment proposals to Draft 2.0 of the Guidelines for regulating digital platforms: A multistakeholder approach to safeguarding freedom of expression and access to information (hereinafter, “Guidelines”).Overall SurveyGroup 3. Civil Society and MediaBelgiumYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AThe document is very well structured, dividing responsibilities and obligations according to the stakeholders involved in the process. A more accurate analysis would be necessary to issue an opinion on the text presented. Time was limited to carry out this analysis. We would like to participate directly or follow the development of the final document preparation activities.Overall SurveyGroup 3. Civil Society and MediaBrazilYesYesNoOverall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AIt is our view that there is substantial improvement in Draft 2.0. Although we still maintain our critical view with regards to the need for this document as encouragement for platform regulation, we recognise the effort carried out by UNESCO to collect input from different stakeholders and allow those input to influence the draft, including through the global conference in February 2023. It is our expectation that such efforts to collect an increasing array of views from different stakeholders and internet users from all around the world can continue, so those inputs will be part of future drafts.
We maintain our concerns about this process as a potential pathway for States to act as empowered or emboldened to carry out digital platform regulation in a manner that risks going against human rights. The continued framing of this effort as one to guide platform regulation risks becoming an incentive to introduce new regulatory efforts that may impair freedom of expression and access to information, rather than enhancing them. Separately, we maintain our scepticism with regards to the need to provide specific guidance on the independent regulatory system, as well as specific guidance around sensitive issues such as situations of heightened risks, as in the case of elections. Some of these subjects are difficult enough to deserve more focused discussion, separately from broader ideas on platform regulation. Moreover, the language in several points still requires some detailed revision.
Because of the substantive discussions that each point of the shared documents requires, it is important that feedback is not only part of future versions of the document (or its sections), but also that inputs by different stakeholders are made public. Transparency in the discussion itself is a value that highlights the relevance of this subject matter, and publicising contributions opens up opportunities to identify convergence between different stakeholders and different groups. In order to allow for meaningful participation in this process, UNESCO should be very transparent about the opportunities for future consultation, avenues for engaging, and guidance for meaningful contributions.
Overall SurveyGroup 3. Civil Society and MediaChileYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/A1. The importance of concepts and definitions that meet the legality criteria. Any regulatory effort requires great rigor when addressing the concepts of the issues that will be subject to regulation. The scope of concepts such as “content that is illegal”, “content that risks significant harm to democracy and the enjoyment of human rights” (#8) is still worrying. Although the guide refers to the fact that these concepts must be delimited under the rules of international law, the risk remains that concepts that are still under debate will enter and could lead to censorship. The guide speaks of “illegal content” (see, for example, # 58) and “content that may impair democracy and the enjoyment of human rights” (# 59). The question is, what scope does this last concept have, does it only cover misinformation or other concepts?

In another section of the guide, concepts such as “disinformation”(#27,e), “inspectoral, investigate or other compliance functions” (# 41), “systems and processes” (# 18). The question remains, what is the scope of these concepts?

Likewise, it remains to define what moderation and/or content curation is. This is a transversal concept in the guide, but its scope is not clear.

2. The subjects of regulation and the existence of general parameters for all, without clarifying how to consider the particularities of each platform. Undoubtedly, it reflects a greater effort to clarify and delimit the subjects of regulation -digital platforms-. But, the recognition of the variety of subjects also generates doubts regarding the liability rules of the platforms raised in the guide and whether they are applicable to all of them. In particular, the presence of “messaging apps” and “search engines” raises doubts. Especially the former, since they are covered by privacy standards that can collide with transparency charges, which deserves a specific analysis.

3. The Regulatory System proposal does not seem to be based on previous experiences with surveillance entities; that demonstrate the existence of financial, independence and usefulness challenges.

4. Obsolescence of regulatory parameters. The regulation of technology entails a regulatory challenge that must be considered and that is that technology advances rapidly and constantly. Thus, it is relevant to think about how to address and include parameters that make the charges for the parties enforceable regardless of the technology used.

5. The co-regulation may be insufficient, since it would reflect the idea that the system would eliminate errors, when surely a percentage of them will be maintained without this being specially considered in the guide. The guide indicates that the guideline approach to regulation is, among other approaches, a co-regulation system (#21). The two subjects involved are the State (which has the duty to generate a legal framework for the creation and enforceability of the rules) and an internal government of the companies (which creates the rules and manages them to guarantee compliance). In other words, the guide/guideline focuses on thinking about and proposing a preventive and transparent system, but it ignores that even with the greatest efforts there will be a percentage of errors in the work of content moderation. The guide seems to address this last aspect from a transparent perspective, but there is no mention of specific organizational and state responses.
6. The risk that such broad transparency -although relevant- could generate a surveillance system on the part of the platforms. Some parameters seem to call for surveillance of "illegal" content, but that will necessarily lead to surveillance of the general content that circulates on the platforms.		Overall SurveyGroup 3. Civil Society and MediaColombiaYesYesYesIn person: I was in Paris for the event at UNESCO.Overall Survey1. La importancia de los conceptos y definiciones que cumplan con el criterio de legalidad. Todo esfuerzo de regulación requiere de gran rigurosidad al abordar los conceptos de los asuntos que serán objeto de reglamentación. Aún preocupa el alcance de los conceptos como “content that is illegal”, “content that risks significant harm to democracy and the enjoyment of human rights” (#8). Aunque en la guía se hace referencia a que estos conceptos deben acotarse bajo las reglas de derecho internacional, se mantiene el riesgo de que entren conceptos que aún son objeto de debate y, podría conllevar a censura. En la guía se habla de “contenidos ilegales” (véase, por ejemplo, # 58) y de “contenido que puede significar una afectación a la democracia y al disfrute de derechos humanos” (# 59). La pregunta es, ¿qué alcance tiene este último concepto, esto cobija solo desinformación u otros conceptos?.

En otro apartado de la guía, conceptos como “disinformation”(#27,e), “inspectorial, investigate or other compliance functions” (# 41), “systems and processes” (# 18). Se mantiene la pregunta, ¿cuál es el alcance de estos conceptos?

Así mismo, falta definir qué es moderación y/o curación de contenidos. Esto, pues es un concepto transversal en la guía, pero no es claro su alcance.

2. Los sujetos de regulación y la existencia de unos parámetros generales para todos, sin aclarar cómo considerar las particularidades de cada plataforma. Sin lugar a dudas se refleja un mayor esfuerzo para aclarar y acotar los sujetos de regulación -las plataformas digitales-. Pero, el reconocimiento a la variedad de sujetos genera, también, dudas respecto a las reglas de responsabilidad de las plataformas planteadas en la guía y sí las mismas son aplicables para todas estas. En especial, genera duda la presencia de las “messaging apps” y “search engines”. Sobre todo las primeras, pues están cobijadas por estándares de privacidad que pueden chocar con las cargas de transparencia, lo cual amerita un análisis concreto.

3. La propuesta del Sistema regulador no parece estar basada en las experiencias previas con entes de vigilancia; que demuestran la existencia de retos financieros, de independencia y utilidad.

4. Obsolescencia de los parámetros regulatorios. La regulación de la tecnología conlleva un reto regulatorio que debe ser considerado y es que la tecnología avanza de forma rápida y constante. Así pues, es relevante pensar cómo abordar e incluir parámetros que hagan que las cargas para las partes sean exigibles independiente de la tecnología empleada.

5. La co-regulación puede ser insuficiente, pues reflejaría la idea de que el sistema eliminaría los errores, cuando seguramente se mantendrá un porcentaje de los mismos sin que esto sea especialmente considerado en la guía. En la guía se indica que la forma que el abordaje de la directriz a la regulación es, entre otros enfoques, un sistema de corregulación (# 21). Los dos sujetos involucrados son el Estado (que tiene el deber de generar un marco legal para la creación y exigibilidad de las reglas) y, un gobierno interno de las empresas (que cree las reglas y las administre para garantizar el cumplimiento). Es decir, la guía/directriz se enfoca en pensar y proponer un sistema preventivo y transparente, pero ignora que aún con los mayores esfuerzos existirá un porcentaje de errores en la labor de moderación de contenidos. La guía parece abordar este último aspecto desde la transparencia, pero no se hablan de respuestas organizacionales y estatales concretas.
6.El riesgo de que una transparencia tan amplia -aunque relevante- llegue a generar un sistema de vigilancia por parte de las plataformas. Algunos parámetros parecen apremiar a una vigilancia de contenidos “ilegales”, pero que necesariamente llevará a vigilar el contenido general que circula en las plataformas.

46
General comments on the overall draft 2.0 GuidelinesN/AIt is an important initiative that urgently needs to be deployed in view of the need to better articulate a digital space designed and dreamed of for the benefit, growth and consolidation of human, cultural and social relations, the process of instruction and multicultural literacy through; that, however, is moving rapidly towards the opposite, that is, disrespect for human beings, their vulnerabilities, differences, the most basic rights, such as the authentic expression of their desires and needs, learning new and enriching knowledge, sharing good practices, demand information that is necessary for coexistence and development, respect for their privacy in terms of data and images, not be the object of hate attacks, incitement to individual, collective and social violence.
The document includes a set of guidelines that, however, must have more precisely declared principles that are mandatory for all the actors that today come together in this space and that is diverse by nature (state, business, academic, social). and scope (global, cross-border and national), as well as objectives (commercial, educational, recreational, political, among others).
These principles must be based on everything stipulated by International Law and the United Nations Charter, but with respect for the sovereignty of States in the digital space that implies non-intervention in their internal affairs, nor in their identities. , autochthonous cultures and religions, nor invite the political and social instability that fragments, and worse still leads to violence more counts. Family values, cultural, religious and linguistic diversity must be protected; the protection of personal data, privacy, access to information you will see, timely and accurate, as well as contributing to peaceful coexistence.
The regulation proposals must be for all the actors of the digital ecosystem with the specificities that each one has. Thus, cross-border platforms have to have very well established duties, just like the States and Civil Society that represents citizens. It is indisputable that the platforms today have supranational scope that even due to their economic and development interests affect National States, especially from the South, which become more consumers than producers, more suppliers of raw materials and cheap labor, as well as capital. human being of high cognitive value, becoming increasingly decapitalized and not at all capable of achieving sustainable development that makes them stronger. It also occurs with the management that these platforms make of the data, the information flows and their organizational forms in favor of economic, structural and political interference that make them vulnerable to the aforementioned National States.
The regulations will have to be beneficial for citizens, their peoples, their economic, cultural, social and political organizational forms, otherwise at this point, where not only the freedom of expression of journalists and citizens is at stake, but also a new way of coexistence and global relations, inequality will continue to be the historical mark that we will leave as it prevailed in a world that is increasingly polarized and destroyed.		Overall SurveyGroup 4. Academia and Technical CommunityCubaYesYesYesOnline: I watched the event on livestream.Overall SurveyEs una importante iniciativa que urge desplegar ante la necesidad de articular mejor un espacio digital pensado y soñado para el beneficio, crecimiento y consolidación de las relaciones humanas, culturales y sociales, proceso de instrucción y alfabetización multicultural mediante; que sin embargo, camina aceleradamente hacia todo lo contrario, o sea el irrespeto por los seres humanos, sus vulnerabilidades, diferencias, derechos más elementales cómo el de la expresión auténtica de sus deseos y necesidades, el aprender nuevos y enriquecedores saberes, compartir las buenas prácticas, exigir informaciones que le son necesarias para la convivencia y el desarrollo, el respeto por su privacidad en cuanto datos e imágenes, no ser objeto de ataques de odio, incitacion a la violencia individual, colectiva y social.
El documento recoge un conjunto de directrices que, sin embargo, deben tener principios declarados con mayor precisión que sean de obligatorio cumplimiento por todos los actores que hoy confluyen en ese espacio y que resulta diverso por su naturaleza (estatal, empresarial, académica, social) y alcance (global, transfronterizo y nacional), así como objetivos (comerciales, educativos, lúdicos, políticos, entre otros).
Esos principios deben basarse en todo lo estipulado por el Derecho Internacional y la carta de las Naciones Unidas pero con apego al respeto a la soberanía de los Estados en el espacio digital que implique la no intervención en los asuntos internos de estos, ni en sus identidades, culturas y religiones autóctonas, ni invite la desestabilidad política y social que fragmenta, y peor aún conduce a la violencia más cuenta. Se deben proteger los valores familiares, la diversidad cultural, religiosa y lingüística; la protección de los datos personales, la privacidad, el acceso a información verás, oportuna y precisa, así como contribuir a la convivencia pacífica.
Las propuestas de regulación deben ser para todos los actores del ecosistema digital con las especificidades que cada cual posee. Así las plataformas transfronterizas tienen que tener deberes muy bien establecidos., al igual que los Estados y la Sociedad Civil que representa a la ciudadanía. Es indiscutible que las plataformas hoy tienen alcances supranacionales que incluso por sus intereses económicos y de desarrollo afectan a Estados Nacionales, sobre todo del Sur que se tornan más consumidores que productores, más provedores de materias primas y mano de obra barata, así como de capital humano de alto valor cognoscitivo, descapitalizandose cada vez más y para nada capaces de lograr desarrollos sostenibles que los hagan más fuertes. Asimismo ocurre con el manejo que estás plataformas hacen de los datos, los flujos informativos y sus formas organizativas a favor de ingerencias económicas, estructurales y políticas que los hacen vulnerables a los mencionados Estados Nacionales.
Las regulaciones tendrán que ser beneficiosas para los ciudadanos, sus pueblos, sus formas organizativas económicas, culturales, sociales y políticas de lo contrario en este punto, dónde no solo está en juego la libertad de expresión de periodistas y ciudadanos, sino una forma nueva de convivencia y relacionamiento global seguirá siendo la inequidad la marca histórica que dejaremos como vencía en un mundo cada vez más polarizado y destruido.
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General comments on the overall draft 2.0 GuidelinesN/AWe welcome the guidelines that mostly stem from the EU Digital Services Act. However, we would like to endorse the comments submitted by the European Commission, especially in the part “General comments”. The guidelines basically focus only on one aspect of the whole-of-the-society approach and cover the provisions of the platform regulation. Therefore, we would like the other aspects covered as well.

Overall SurveyGroup 1. Public Sector (member states, executive, legislative, and judicial branches of government, regulatory bodies, state entities)CzechiaYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AMost of the guidelines are addressing the challenges. However it is important to underline the need for human rights and ethical literacy for tech staff, to include authors' rights among rights to be respected, to reach out in all languages and regarding AI to have a focus on declaration, bylines and rights of the content used by AI to develop new content.Overall SurveyGroup 3. Civil Society and MediaDenmarkYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AIn general, the guidelines are a good improvement over earlier drafts, but there is a lack of definitions over key terms -- and definitions matter! The category of content that you speak about, which "risks significant harm to democracy", well there is SO much embedded into this sentence. What is "significant harm"? What is "democracy"? Let's not make any assumptions here and please spell out what you mean precisely. And, how do these guidelines align with the Secretary-General's Global Digital Compact?Overall SurveyGroup 3. Civil Society and MediaGermanyYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AFocus on creating & enabling environment for users , Different legal or regulatory frameworks for human sensitive contentOverall SurveyGroup 3. Civil Society and MediaIndiaYesYesYesOnline: I watched the event on livestream.Overall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/ALet me readOverall SurveyGroup 4. Academia and Technical CommunityIndiaYesYesYesOnline: I watched the event on livestream.Overall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AThe " Necessity of societies and technology related continuing educational organizations also needs to be in conformity in providing all genuine related issues of finance, and regulations. Democratic setup.to mach modern standards. Equal work.And sticking to volunteer activities as per international standards with out any financial obligations. These institutions have to disclose their turnover, staff,works,and commitments to their national laws in their open web sites.Overall SurveyGroup 4. Academia and Technical CommunityIndiaYesYesYesOnline: I watched the event on livestream.Overall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AThe Second Draft of the UNESCO Guidelines is a considerable improvement from the earlier draft in terms of recognizing the impact of platform content moderation and curation functions on (i) freedom of speech and access to information, (ii) regional and cultural differences affecting platform regulation, (iii) a stronger reference to the UN Guiding Principles on Business and Human Rights to hold platforms accountable, and (iv) emphasis on due process including judicial review echoing the three part-test on legitimate restrictions laid out in Article 19 of ICCPR.
We appreciate the Guidelines for recognizing and incorporating the following:
(a) Detailing the criteria for composition and scope of powers of independent regulators.
(b) Requiring human rights compliance and transparency in respect of both content moderation and content curation functions performed by digital platforms.
(c) Special attention to the employment status and conditions of work of human moderators as a factor affecting the quality of content moderation efforts.
(d) Significance of digital platforms conducting periodic human rights due diligence of their operations
(e) Specific attention to gendered disinformation and online gender-based violence.

However, we believe that the Guidelines are still not sufficiently attendant to
a) Challenges of platform regulation - especially in the Global South
b) Architecture of corporate impunity that platforms benefit from and
c) Need to address communication governance through a supra-liberal framework.

The Guidelines’ lack of differentiation between different types of digital platforms in terms of their functionality, user-base, and size will hinder effective and proportionate response to the distinct regulatory challenges for securing freedom of expression and information as a public good. We recommend that the Guidelines provide greater clarity on the role and mode of engagement of inter-governmental organizations and the role of civil society, media organizations, academia, and other constituencies. This is necessary to ensure that policy processes are democratic, inclusive and accountable. We reiterate our earlier recommendation to push for interoperability and data portability in order to minimize internet fragmentation and promote diversity of information and view-points. Finally, we suggest that the Guidelines tighten its language in several places to ensure that terms are not left to subjective interpretation, which could defeat the purpose of developing a common framework for pinning accountability on the platforms and the government.

Our detailed comments to Draft 2.0 of the Guidelines can be read here: https://itforchange.net/response-from-itfc-to-draft-20-unesco-guidelines-for-regulating-digital-platforms
Overall SurveyGroup 3. Civil Society and MediaIndiaYesYesYesOnline: I watched the event on livestream.Overall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/ALooking forward to user-friendly access and reporting for civic writers and independent journalists. Indifference is silently killing freedom of expression; cancel culture exists within the internet algorithm, web administrators, anonymity (hiding behind mega institutions) and email correspondences.Overall SurveyGroup 3. Civil Society and MediaIndonesiaYesYesOverall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AThe document has good stand but you need also to consider culture aspect values when you are adopting digitalizationOverall SurveyGroup 2. Private Sector (companies, industry representatives)MalawiYesYesOverall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AIn general, the document makes it possible to identify the actors, their positions and responsibilities. More emphasis could be placed on terminological references with a larger number of documents that allow the current state of the discussion to be known.Overall SurveyGroup 4. Academia and Technical CommunityMexicoYesYesYesOnline: I watched the event on livestream.Overall SurveyEn general el documento permite identificar a los actores, posicionamientos y responsabilidades de cada uno. Podría enfatizarse más las referencias terminológicas con un número más amplio de documentos que permitan conocer el estado actual de la discusión
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General comments on the overall draft 2.0 GuidelinesN/AThere are important points that must be changed, as we explain in our document of commentaries to the Draft.Overall SurveyGroup 3. Civil Society and MediaMexicoYesYesYesOnline: I watched the event on livestream.Overall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/A1) Overall, we strongly welcome the initiative taken by UNESCO to produce these guidelines. We recognise the need to ensure adequate regulation of platforms, given their huge and structuring role in people’s experience of the internet, and so to realise their ability to enjoy their right of access to information.
2) In particular, at a time where the loudest voices often focus more on imposing restrictions, it is hugely important that UNESCO is underlining that any regulation needs to take as a starting point the importance of upholding the rights of freedom of expression and access to information, and the application of rules around reasonableness and proportionality when restricting this.
3) In line with the overall mission of libraries, we would encourage an approach to access to information that recognises the importance of press freedom and open government, but does not limit itself to these, given that the range of information necessary to support development is far wider.
4) Similarly, the Guidelines should also be clear about their scope, given that they do not necessarily cover all aspects of the work of platforms. It should be clear, for example, that rules around privacy and data protection should apply, as should an obligation on platforms to pay their taxes. The latter is particularly important, given that it is tax revenue that allows public sector entities, such as libraries, to operate and so contribute to the healthier information ecosystem that is a key underlying goal of the Guidelines as a whole.
5) It should be a principle running across the guidelines that any actions taken should not serve to undermine the possibility for new platforms to emerge which may work in ways that are more in line with the goals of the Guidelines in the first place.
6) It would be helpful to ensure that, even if not included in the text itself, that the Guidelines are ‘tested’ against different scenarios. As became clear in the Internet4Trust conference, perceptions of where the greatest threat to freedom of expression and access to information lie. How do they operate in the face of platforms that encourage extremism and spread misinformation? What about in the face of a repressive and intolerant government?
7) A further broad point is that the Guidelines should also be clear that efforts made to address the risk that platforms exacerbate problems should not take away from those to address the underlying problems.
8) At the same time, there clearly does need to be careful consideration of the importance of anonymity and the protection of users’ personal data.
9) A further point to consider is the degree to which platforms themselves should be allowed to make decisions in order to retain relevance to a particular community, in line with their own freedoms. Specialised platforms may provide an essential space for groups at risk of marginalisation, or with particular needs and interests, to come together. It may not be reasonable to oblige them to carry any material that isn’t illegal, insofar as this reduces the value of the platform for the members involved (who can of course also seek information elsewhere).
10) Linked to the above, we would finally note that there are dangers in ‘must-carry’ or ‘must-promote’ provisions. Such steps can risk favouring particular sources of information over others, and can be likened to violations of net neutrality principles.
Overall SurveyGroup 3. Civil Society and MediaNetherlandsYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AIndigenous nations, frantically making efforts should not be restricted by owners of online outlets. Online media's Shouldn't be used negatively as a political tool. Like was seen during the contest of Trump, where he had to even be schemed out by Frontline nonlinear media's just to forward his rival.
The peace and reduction of conflicts can be robust when we realize that online information is key to freedom of speech. This policy should not in any be made to suit the interest of globalists and Illuminati.
The work if it can add my observations to it will be beneficial to small, big and mighty.		Overall SurveyGroup 4. Academia and Technical CommunityNigeriaYesYesOverall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AMedia Challenges are rapidly evolving and to better answer them, these guidelines must be written alongside the youth and content moderators who are at the frontline of this constantly evolving space.
I suggest that future events like this Conference invite Youth and Moderators as separate stakeholder groups, instead of inviting some of them as panelists.
Internet communities vary between generations and language communities. These guidelines will have to be written taking into account this diversity of experiences and realities.		Overall SurveyGroup 3. Civil Society and MediaPeruYesYesOverall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AVersion 2 improves much on Version 1, in terms of conceptualization and condensing issues into clear principles. Creating international benchmarks by which stakeholders can assess regulatory arrangements at regional or national levels, is a very valuable exercise. As always, however, the elaborating of principles is one thing, but if they do not anticipate the challenges of real situations, the chances of them having impact are limited.
On the ground, much current regulation is state-led, rather than representing a multi-stakeholder movement. This situation correlates with many rules are being drawn up and implemented in ways that threaten to harness platforms as part of the state apparatus – which is not always friendly to freedom of expression. Regulators are weak and also lack independence. (There is also a crying need for prioritization and modularity in focusing regulatory arrangements on particular issues (eg. elections), rather than trying to cover the entire waterfront of issues. Such modularity could be discussed as a helpful approach to “eating the elephant” in the Guidelines).
Commendably, the Guidelines in version 2 do underline the importance of independence in regulatory arrangements. However, taking account of realities, it is very hard to envisage changes here – meaning that this part of the Guidelines will lag, and even undercut the other parts. If key decisions are made by compromised regulators in isolation, then legitimate expression on the platforms could be a casualty.
Thus the Guidelines could do well to encourage a perspective that presents governmental involvement in regulation as one (significant) element, but also as one that optimally works alongside that of other actors in regulation. This would signal the many advantages of having a bigger co-ordinated picture for regulation, even in cases where regulators are problematic in various respects.
Without this, the risk is to encourage replacing platform power with governmental power. In very many cases, these may fail to promote information as a public good but instead end up limiting legitimate expression like criticism of authorities. Proposing that corporate and state powers take account of civil society interests, through institutionalised multistakeholder modalities, is a way forward. It can help protect free expression while systemically countering content that harms human rights and works against information as a public good.
The making of content-related rules by authorities (including regulators), and within this frame by companies themselves, can benefit enormously from meaningful civil society participation. Similarly, the massive work of implementation, monitoring, oversight and review of these rules can also be enriched in the same way. UNESCO has an opportunity in the Guidelines to really highlight the centrality of multistakeholder arrangements in regulatory measures. This would do a lot to aid the insights and arguments of actors working for positive change of the status quo in platform governance that aligns with protection of freedom of expression. In summary, the value of multistakeholder governance as a sine qua non could be better and more consistently presented.
Overall SurveyGroup 4. Academia and Technical CommunitySouth AfricaYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/A1 - Risk assessments by the platforms under regulatory supervision should come before everything else as is described in the UNGPs and the UK and EU online safety regimes. All actions then flow from this risk assessment. the risk assessment also captures proportionality and the heterogenous nature of platforms - those that have only low risk activities need then take no action.
2 - We are concerned that UNESCO use of 'content moderation and curation' enthuse guidelines is a little too narrow. Carnegie and Professor Woods have written several guidelines on social media regulation - Prof Woods derived a simple conceptual model of how to frame/analyse the options available to platforms when undertaking risk management which we feel would help inform UNESCO thinking This four stage information flow model, reflects the role of the platforms in creating and influencing the flow of content from their users, comprises the following: • access to the service and content creation; • discovery and navigation; • user response tools; and • platform response. Using this model allows easier consideration of options for action and you might wish to consider this in the next draft of your document. Our Model Code which has some similarities to the UNESCO approach can be found at https://www.carnegieuktrust.org.uk/publications/model-code-a-reference-model-for-regulatory-or-self-regulatory-approaches-to-harm-reduction-on-social-media/ 		Overall SurveyGroup 3. Civil Society and MediaUnited Kingdom of Great Britain and Northern IslandsYesYesOverall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AClarification for legislation and policies, however more of in depth information of Equity and Solutions based Action with required investment.Overall SurveyGroup 1. Public Sector (member states, executive, legislative, and judicial branches of government, regulatory bodies, state entities)United Kingdom of Great Britain and Northern IslandsYesYesYesOnline: I watched the event on livestream.Overall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AThe guidelines represent a good effort in reiterating the importance of putting human rights at the centre of the regulation of internet platforms. However, there are several inconsistencies across the documents that should be addressed to make the guidelines effective and useful from a human rights perspectives. More international human rights law language should be used, not just simply in theory but with specific reference to instruments (UDHR, ICCPR, ICESCR) relevant for this discussion. Moreover, it should be clarified what, if any, could be the role of regional human rights bodies or national human rights institutions as they could constitute an extremely important addition to the regulatory framework for internet platforms [I'm currently working and researching on this aspect and I'm happy to elaborate further if needed and interested].

In addition to the specific comments on the paragraphs, there is a general inconsistency in terms of depth and details of the guidelines as they mix very general and vague expressions/definitions with very specific and detailed examples. A more consistent and harmonised approach would be welcomed. 		Overall SurveyGroup 4. Academia and Technical CommunityUnited Kingdom of Great Britain and Northern IslandsYesYesYesOnline: I watched the event on livestream.Overall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AWe are grateful to UNESCO for taking on board a great deal of our initial feedback in this revised version of the guidelines and for hosting us and others at the Internet for Trust conference.

This second draft of the guidelines has rightly focused on systems and processes, but new additions have unhelpfully widened that focus. In order to serve as a useful point of reference for any country seeking to introduce platform regulation, the guidelines should be more concise, starting with a clear stated purpose/goal (serving as such a point of reference) and a brief explanation of each of the core components that any digital regulation regime should have. We believe these core components are:

• regulatory independence
• the concept of platform responsibility (as manifested through obligations to carry out risk assessments and develop risk mitigation plans)
• systems and processes-based regulation – notably this includes, but is not limited to, systems for content moderation, as pointed out by Christopher Wylie at the conference
• supported by robust transparency obligations (and by extension, information-gathering powers for regulators).

We heard from many stakeholders at the UNESCO Internet for Trust Conference that the guidelines as they currently stand mention a large number of specific issues related to digital regulation, like content moderation and user empowerment tools, but then do not adequately provide sufficient nuance and explanations in each case. We agree with this commentary and in fact would go further – we think that the more detail and prescription, the less likely it is that these guidelines will ultimately achieve consensus and, importantly, be able to serve as a useful point of reference for the development of digital regulation globally. Rather, we believe a more concise set of guidelines focused on the key components of digital regulation and at the level of regulatory principle, are key to building consensus across the diversity of stakeholders and being useful to the key constituencies. Topics that are in this way removed from the guidelines could nonetheless be used to develop further specific implementation guidance for stakeholder groups engaging in digital regulation.

On this basis, we would suggest that draft 3.0 follow the following structure (further specific details on our suggestions have been provided in writing separately, due to space constraints in this form):

1. Purpose: It should be made clear upfront that the guidelines are intended to provide a recommended path to rights-respecting digital regulation. To that end, they provide a foundational toolkit for legislators, regulators and platforms. (Paras to be included in this section: 8-12, 16-17)

2. Core components

a. Shared responsibility/duty of care: (Paras 21, 31, 13)
i. Independent regulatory systems, with information gathering and enforcement powers (Paragraphs 37-39, 44-45)
ii. Governments and regulators (Paras 24-27)
iii. Industry (Paras 50, 28b-28e)
iv. Civil society and researchers (Paras 32-34)
v. Intergovernmental organisations (Para 30)

b. Systems and processes: Regulation should focus on the systems and processes used by platforms (Paragraph 18-20)
i. Transparency obligations (Paras 67-69)
ii. Risk assessments (language proposed separately)
iii. User empowerment tools (Paras 75-77, 82-84, 86, 89-91)
iv. Researcher access to data (Paras 72-74)
v. Media literacy (Paras 77, 79-81)

We suggest that other content currently contained in the guidelines could be used and refined to create separate implementation guidance, targeted at specific audiences, including:

• Risk Assessments: (Paras 92-98, 104-105)
• A human-rights approach to content moderation (Paras 28a, 52-54, 56-63, 65-66, 70-71)
• Specific arrangements required for independent regulatory systems (Paras 41-43, 47-49)

Further details have been provided in writing to you, due to space constraints in this form. 		Overall SurveyGroup 1. Public Sector (member states, executive, legislative, and judicial branches of government, regulatory bodies, state entities)United Kingdom of Great Britain and Northern IslandsYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AWe support the inclusion of specifically naming gender-based violence. We beleive that a gender-based approach to all aspects of tech regulation is essential and would therefore advice that a Violence Against Women and Girls/ Gendered Based-Violice Code of Practice for Tech companies be included within these Guidelines. Such a model Code of Practice has been drawn up within the UK legislative context (which can be found here: https://drive.google.com/file/d/1cMIginaMEN2kULCL2eftH2B7oGVK9FZh/view)

This guidance was created due to the high prevalence of Violence Against Women and Girls (VAWG)
perpetrated in the digital sphere. This includes technology-facilitated abuse (activities carried out with the
use of technology and communication equipment, including hardware and software) enabling abusers
to stalk, harass, surveil, and control victims. It is prepared with regard to the Online Safety Bill and the
obligations placed on regulated providers, as set out in the Bill, to prevent harm against adult and child
users. This is a ‘living’ document that will continue to evolve as the Online Safety Bill progresses through
Parliament. It has been prepared by Carnegie UK, The End Violence Against Women Coaltion, Glitch,
NSPCC, Refuge, 5Rights and academics Lorna Woods and Clare McGlynn.

While there is some cross over between the draft Guildelines and the drafted VAWG Code of Practice, the full list of areas that tech companies should be considering in relation to gender-based violence outlined within our document are as follows:

1) Responsibility, risk assessment, mitigation and remediation
2) Safety by Design
3) Access to the online service, terms of service and content creation
4) Discovery and navigation
5) User Response, User Tools
6) Moderation
7) Transparency
8) Victim support and remediation
9) Safety Testing
10) Supply Chain Issues
11) Enforcement of criminal law
12) Education and Training
13) Vigilance over Time

This list offers are more detailed guide for tech companies to comprehensively combat gender-based violence on their platforms. Glitch suggests that the section beginning paragraph 97 on page 23 include a Code of Practice that covers areas such as the 13 areas listed above.		Overall SurveyGroup 3. Civil Society and MediaUnited Kingdom of Great Britain and Northern IslandsYesYesNoOverall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/Ato foucuse how to improve and develoment artifcahl intellegenceOverall SurveyGroup 4. Academia and Technical CommunityYemenYesYesOverall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AAlthough the guidelines repeatedly make reference to a multi-stakeholder framework and the need to be systemic, there is no reference to organised science or the scientific community. This is a critical community, even in the context of Freedom of Expression norms because public health and the impact of material wellbeing provide important caveats for exercising freedom of expression. There needs therefore to be a paragraph, such as paragraph 20 that focuses on the practical implications of engaging the science community.
Such a paragraph might address: i) the need for support to scientific literacy; ii) the need to engage credible spokespersons on the global scientific consensus in crises such as 'infodemics' (along the model of 'Trusted Flaggers' in the EU's DSA ); iii) a legislative framework for access to and protection of data from digital platforms to support quality research to inform the regulatory decisions around the impact of policy and technology used by these platforms.		Overall SurveyGroup 4. Academia and Technical CommunityYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AI believe the Guidelines provide a useful too for regulating social media and use of the internet. However, challenges reamin wherein what is legal in one jurisdiction is illegal in another, given most social media platforms have global access. For example, with regard to Principle 1, lgbtq+ rights are prohibited in many African Union and Middle Eastern states. Human rights defenders in countries where consensual same sex relations between adults are illegal, must be ensured protection where their access to universal human rights, including digital platforms promoting lgbt rights as human rights, are threatened by homophobic domestic jurisprudence.

In my humble opinion, the Guidelines should therefore emphasize the importance of transposing universal human rights into domestic legislation in many states where equity and equality of access to fundamental rights, including the right to life itself, remain elusive objectives to be achieved . 		Overall SurveyGroup 3. Civil Society and MediaYesYesNoOverall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AOverall, the guidelines are aimed at mitigation rather than prevention – one way to remedy this will be to demand that new tech integrates human rights principles at the level of design and coding. In this respect, the current consultation has clearly left out this body of stakeholders. Engineers who actually design and write codes should form an integral part of the category “industry stakeholders”, which currently seems to consist of only of policy and market representatives. UNESCO needs stronger involvement of engineers and coders to get their input into the guidelines writing process.
(Note that this is our 2nd submission and focused mainly on this issue. A more complete list of comments was submitted earlier.)		Overall SurveyGroup 3. Civil Society and MediaYesYesOverall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AThe primary comment I want to make and one that I also made in-person at the event as a speaker on one of the panels is that I think the guidelines don't go far enough in making meaningfully public data from the platforms available to a wide enough audience. There are obviously some important transparency requirements in the guidelines and one I support but they tend to focus much more aggregated reports and data access mechanisms that are limited to approved groups of researchers.

As several prominent speakers mentioned and certainly as UNESCO has advocated in other settings, if we want to build a healthy internet that protects human rights and advances the ideals of democracy, then we need a bottoms-up approach to helping govern those spaces that engages with as much of civil society as possible. But that's only possible if there is some meaningful, real-time data accessibility that is available to more than just academics and as they currently stand, the guidelines don't go nearly far enough in advancing that core concept. If UNESCO is interested in advancing the idea that information is a public good, then I think there are more steps needed to encourage and promote the free flow of privacy-protecting data out of the platforms and into civil society, including the news industry. 		Overall SurveyGroup 3. Civil Society and MediaYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AUNESCO's mandate includes safeguarding and setting long-term priorities for creating better educational, social and cultural values for us and our future generations. The draft declaration that is under discussion is bereft of language of urgency and recognition of destruction, and instead takes a technical approach. It ignores the ambition to deliver an information system to our future generations where spreading life-threatening rumours and genocidal hate speech are not just an issue of regulation, but a moral and ethical wrong. It ignores a whole young generation which is at this point growing on regular dosage of radicalisation on the internet. The declaration appears to be a watered down initiative of countries and companies, rather than an ambitious agenda-setting.

Our concerns are:
1) The introductory paragraphs emphasise human rights and democracy, yet the content does not reflect this. These guidelines seem to be more concerned about government censorship of content and the wellbeing and ease of companies to comply.
2) There is little practical recognition of the absolute devastation caused by the prevalence of harmful content by non-state actors.
3) Platform regulation is framed as something purely technical. Language in the document like “this guidance is principle-based”, with the “regulator setting the overall goal” forgets that regulatory systems are bureaucratic and not a democratic representation of either our current or future social morality.
4) UNESCO wants to build resilience at the receiving end (the user) instead of putting the onus on the perpetrating party (hate speakers and platforms) against the spread of hate, life-threatening rumours, and politically motivated disinformation.
5) Platforms are left to co-regulate, but are merely required to disclose what they “would do” or what theoretical systems are in place. These guidelines must call on platforms to respond - not just demonstrate how they would respond.


We would like a declaration which adheres to moral, ethical and one world language which proscribes future agendas that are bold and ambitious. As guidelines, they need to be as ambitious as possible. Then, further technical documents can refine the tools to realise these. 		Overall SurveyGroup 3. Civil Society and MediaYesYesOverall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AWe are grateful for the opportunity to comment on UNESCOs draft 2.0 Guidelines. Internet regulation is one of the defining issues of our time and central to how people exercise their freedom of expression online. We have long supported smart, innovative and systems-based regulation for social media platforms such as ourselves, in line with human rights norms and principles. Below we outline our key comments on the Guidelines to ensure a holistic approach to Internet regulation that is not open to abuse by authoritarian governments.

- The guidelines should defer to and align with existing regulatory systems and human rights legal frameworks, instead of constituting an attempt to create new ones.
- The language of the guidelines should be tightened and revised, as many terms remain vague and thus leave room for uncertainty and potential abuse by governments.
- The guidelines should advocate for a whole-of-society approach to the guidelines, with the onus not falling solely on platforms - as echoed by civil society, freedom of expression entities, and industry stakeholders at the UNESCO “Internet for Trust” conference.
- We are aligned with the concerns of human rights groups, such as Access Now and ARTICLE 19, that indicate the concept of ‘harm to democracy’ is overly broad and should be removed.
- We would support regulatory measures aligned with a global international standard that push for greater transparency. This would reduce regulatory burdens (for companies, governments and regulators), develop trust and improve stability in regulatory structures, and help prevent potential abuses of freedom of expression through government actions.
- Differences in political systems, structures, and regulatory capacities of governments, as well as differences in platforms, should be taken into account.
- All would benefit from greater clarity in communication of the objectives of these guidelines - as guidance, not recommendations nor policy - and within what parameters they would be adopted/applied.		Overall SurveyGroup 2. Private Sector (companies, industry representatives)YesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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General comments on the overall draft 2.0 GuidelinesN/AWe welcome that draft 2.0 of the Guidelines contains substantial improvements that integrate the feedback provided by GPD and other organisations on previous iterations. We acknowledge the efforts undertaken by the UNESCO team to work through different perspectives and reflect them in their revisions.
The present structure provides a more progressive analysis of the different elements to take into consideration when developing, implementing or revising regulatory processes. It more clearly sets out existing international human rights law and standards and the responsibilities of various stakeholders to ensure an “enabling environment for freedom of expression and the right to information”. We are particularly pleased to see a more detailed subsection on the states’ duties to respect, protect and fulfil human rights, including the obligation to provide the right to an effective remedy for violations and clarification that states should refrain from imposing a general monitoring obligation on platforms.
We also welcome the new structure and content for the responsibilities of companies to respect human rights, including the identified principles. We are particularly pleased that human rights due diligence has been elevated as one of the five principles. Previous drafts only touched upon this topic in a rather superficial manner, whereas due diligence is now better integrated within the document and aligned with the UNGPs and other relevant frameworks at the national and regional levels. We find it helpful that a number of issues (such as elections integrity, gendered disinformation and violence and crisis situations) are included under this principle to underscore there a number of specific situations that entail enhanced risks, rather than addressing them as separate sections of guidelines.
Moreover, draft 2.0 removes a number of problematic concepts such as “enhance the availability of accurate and reliable information in the public sphere” and “potentially harmful content”, which lacked of clarity in their scope and could be interpreted by governments as providing permission to prohibit broad categories of legal content online, or even be weaponized for censorship and control in non-democratic contexts.
On the other hand, we believe there is still room for continuing improvement with respect to several of the aforementioned areas and a need for UNESCO to provide more granular guidance, as well as a few additional areas of concern.
We recommend better integration of sources of best practice to ensure that the guidance builds on and expands upon existing work. The initiative would benefit from coordinating with existing bodies and initiatives that are already committed to developing standards for the regulation of online content from a human rights perspective. In particular, UNESCO should seek to coordinate more closely with institutional partners at the United Nations, such as the OHCHR, in order to leverage complementary efforts such as those under the B-Tech Project. We further recommend that UNESCO leverage the existing expertise and outputs of relevant Special Procedures of the Human Rights Council.
As was highlighted by UNESCO representatives during the global conference, the UNESCO holds a special mandate to defend and promote freedom of expression. Given so, there is a need to ensure that the language and the structural approach of the guidelines enjoy sufficient clarity to avoid being misused by regulatory attempts that do not align with relevant standards on the promotion and protection of freedom of expression.		Overall SurveyGroup 3. Civil Society and MediaYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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Section 1N/AIn the “introduction” section, it may be useful to provide global context to explain why the Guidance
is needed and the complexity of the environment, given that platforms operate internationally while
government jurisdiction is national.		Emailed CommentsGroup 1. Public Sector (member states, executive, legislative, and judicial branches of government, regulatory bodies, state entities)CanadaN/AN/AN/AN/AEmailedN/A
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Section 1N/A(New paragraph) As outcomes of the WSIS are primary and consensus based documents on internet related public policy issues, the Draft Guidelines should be built upon the WSIS documents, including the Declaration of Principles (2003) and Tunis Agenda (2005), in particular P.35a Tunis Agenda that emphasizes Policy authority for Internet-related public policy issues is the sovereign right of States. They have rights and responsibilities for international Internet-related public policy issues and p.58 of the Declaration of Principles the use of ICTs and content creation should respect human rights and fundamental freedoms of others, including personal privacy, and the right to freedom of thought, conscience, and religion in conformity with relevant international instruments.Emailed CommentsGroup 1. Public Sector (member states, executive, legislative, and judicial branches of government, regulatory bodies, state entities)Iran, Islamic Republic ofN/AN/AN/AN/AEmailedN/A
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Section 1N/AIn paragraphs 1, 2, and 7.2, the terms "regulate," "co-regulate," and "self-regulate" have been used without defining the actors involved in the processes. It would be good to elaborate on these. Emailed CommentsGroup 4. Academia and Technical CommunityN/AN/AN/AN/AEmailedN/A
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Section 1Paragraph 1Consider shortening.
Para 1. should mention the goal of these Guidelines. Now, the goal only appears in para 107.
Emailed CommentsN/AN/AN/AN/AEmailedN/A
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Section 1Paragraph 1In November 1945, UNESCO was created with the mission of “contributing to peace and security by promoting collaboration among nations through education, science and culture in order to further universal respect for justice, for the rule of law and for the human rights and fundamental freedoms which are affirmed for the peoples of the world.”2 UNESCO’s global mandate, which includes the promotion of “the free flow of ideas by word and image”, has guided the Organization’s work for nearly 80 years—as a laboratory of ideas, a clearing house, a standard-setter, a catalyst and motor for international cooperation, and a capacity-builder. This history has shaped our mandate within the United Nations system [ADD: as one of the entities] to protect and promote freedom of expression, access to information, and safety of journalists.Emailed CommentsN/AN/AN/AN/AEmailedN/A
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Section 1Paragraph 1


We have produced digital content on these rights and childhoods for 12 years at Pakapaka channel public tv		Overall SurveyGroup 1. Public Sector (member states, executive, legislative, and judicial branches of government, regulatory bodies, state entities)ArgentinaYesYesOverall SurveyN/A
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Section 1Paragraph 1suggesting to include here the words "creativity" and "Inspiration", along the line the Higher education crafts the graduate capabilities. "as a laboratory of ideas, a clearing house, a standard-setter, a catalyst and motor for international cooperation, and a capacity-builder, fostering creativity by inspiring the people.Overall SurveyGroup 4. Academia and Technical CommunityAustraliaYesYesOverall SurveyN/A
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Section 1Paragraph 1While this mandate can ensure the status of UNESCO as a promoter of rights, it is important to also recognise that the range of affected human rights requires an openness to the expertise of not only different stakeholders, but the expertise of a broad range of UN institutions and experts who share mandates concerning human rights that can be fostered or affected by the use of digital platforms.Overall SurveyGroup 3. Civil Society and MediaChileYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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Section 1Paragraph 1Supported global +Social Good for United Nations system by technology , innovation & Social networks for global challenges aligned with global human rightsOverall SurveyGroup 3. Civil Society and MediaIndiaYesYesYesOnline: I watched the event on livestream.Overall SurveyN/A
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Section 1Paragraph 1The idea and attitude are misused by most societies.Overall SurveyGroup 4. Academia and Technical CommunityIndiaYesYesYesOnline: I watched the event on livestream.Overall SurveyN/A
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Section 1Paragraph 1True an essential feOverall SurveyGroup 4. Academia and Technical CommunityIndiaYesYesYesOnline: I watched the event on livestream.Overall SurveyN/A
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Section 1Paragraph 1Hope for user-friendly, fast responding access and reporting, before journalists become statistics in memoriam. With the internet, it is possible to target individuals directly for better and for worse.Overall SurveyGroup 3. Civil Society and MediaIndonesiaYesYesOverall SurveyN/A
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Section 1Paragraph 1But some values has been amended without a knowledge of the mass people.Therefore is better to keep on observe the first vision on this developmentOverall SurveyGroup 2. Private Sector (companies, industry representatives)MalawiYesYesOverall SurveyN/A
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Section 1Paragraph 1In the final sentence, we could recommend making clear that access to information refers to access to information OF ALL TYPES. Too often, this is understood as only referring to government information, whereas in reality, it is broader, for example including open access and open science.
Overall SurveyGroup 3. Civil Society and MediaNetherlandsYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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Section 1Paragraph 1Well in your efforts you have failed to cover and protect the aspirations of emerging nations that are frantically seeking for referendum, eg. Biafra, ambassonia etc, and in most African countries, your presence seems to be remote, we need to see your catalystic influence in oppressed parts of Indigenous nations, assisting in making their voice reach the world, and draw attention to such Indigenous nations.Overall SurveyGroup 4. Academia and Technical CommunityNigeriaYesYesOverall SurveyN/A
90
Section 1Paragraph 1Consider shortening.
Para 1. should mention the goal of these Guidelines. Now, the goal only appears in para 107.
Overall SurveyGroup 1. Public Sector (member states, executive, legislative, and judicial branches of government, regulatory bodies, state entities)SwitzerlandYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
91
Section 1Paragraph 1Human Rights Act 10 and 11. Legislation of UN Human Rights Council and International United Nations charter youth inputs of Demands.Overall SurveyGroup 1. Public Sector (member states, executive, legislative, and judicial branches of government, regulatory bodies, state entities)United Kingdom of Great Britain and Northern IslandsYesYesYesOnline: I watched the event on livestream.Overall SurveyN/A
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Section 1Paragraph 1we should to change regulation and chareecters of UNOverall SurveyGroup 4. Academia and Technical CommunityYemenYesYesOverall SurveyN/A
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Section 1Paragraph 1A multistakeholder approach requires meaningful regional representation and consultation, which were unfortunately limited as part of the elaboration of these guidelines. Since the start of the process, we have not observed sufficient publicly available information or guidelines on UNESCOʼs stakeholder engagement and consultation with the global community. To date, it remains unclear which and how many stakeholders UNESCO has engaged with during this process, who contributed to the first draft of the Guidance (e.g. civil society, private companies, academia, and States), the number of participants, their respective countries or regions, languages considered and the comments they provided. Without more transparency and inclusiveness in this process, the content and outcomes of these Guidelines are at risk of reflecting the views of only a few stakeholders.Overall SurveyGroup 3. Civil Society and MediaYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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Section 1Paragraph 1It is worth noting that this history has not been without controversy and reflecting on the importance of working in a transparent and inclusive manner to avoid the potential for misunderstandings and unintended consequences.Overall SurveyGroup 3. Civil Society and MediaYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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Section 1Paragraph 1We recommend that these paragraphs explicitly note that the content of the guidelines is a reflection of that trajectory described here in order to avoid regulatory proposals that can result harmful for freedom of expression. We suggest adding the phrase: “According to this trajectory, UNESCO's ongoing work and commitment is to ensure that digital platform regulation protects and promotes freedom of expression”.Overall SurveyGroup 3. Civil Society and MediaYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A
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Section 1Paragraph 2“Over the past decade” > if the guidelines are to be relevant in the future, any timely reference should be avoided.Emailed CommentsGroup 1. Public Sector (member states, executive, legislative, and judicial branches of government, regulatory bodies, state entities)N/AN/AN/AN/AEmailedN/A
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Section 1Paragraph 2Building upon relevant principles, conventions, and declarations over the past decade, the UNESCO Secretariat is now developing, through multistakeholder consultations and a global dialogue, [ADD:Guiding principles] [DEL:Guidelines] for regulating digital platforms: a multistakeholder approach to safeguarding freedom of expression and access to information (the Guidelines).Emailed CommentsN/AN/AN/AN/AEmailedN/A
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Section 1Paragraph 2Paragraph 2, second line. The text mentions “regulating content,” which I think in this initial paragraph may be controversial. Despite the goodwill and human rights approach that lies behind such an idea, I suggest the text should have a more careful approach to it. Otherwise, those who fear that any regulation may hide obscure intentions to silence freedom of expression will reject it. In the same manner, those who are longing to reduce such freedoms will distort its meaning. I suggest modifying the text to "establish regulatory parameters on content moderation" instead of “regulating content.”Emailed CommentsGroup 4. Academia and Technical CommunityN/AN/AN/AN/AEmailedN/A
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Section 1Paragraph 2big problem is bussiness model about data extravism and consequences on human rightsOverall SurveyGroup 1. Public Sector (member states, executive, legislative, and judicial branches of government, regulatory bodies, state entities)ArgentinaYesYesOverall SurveyN/A
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Section 1Paragraph 2It is important to note that the framing of this document can be very different if the purpose is to regulate digital platforms, an effort intrinsically linked to the power of the State, than if it is to safeguard freedom of expression, which can happen through other means. If the previously expressed mandate of UNESCO is linked to freedom of expression and access to information, we understand that safeguards are the better focus of this document, rather than regulation as a highly complex action by states.
Overall SurveyGroup 3. Civil Society and MediaChileYesYesYesIn person: I was in Paris for the event at UNESCO.Overall SurveyN/A