Content Moderation Best Practices
The following are the industry best practices recommended for any Reflected customers that allow adult content to be uploaded by users (UGC Customers):
Only users who have verified their age and identity should be permitted to upload adult content on customers’ sites. UGC Customers must ensure that all uploaders are over the age of 18 and must use industry-standard age and identity verification services.
Downloading of amateur adult content should be prohibited and the feature not enabled on the customer’s platform. Any adult content downloads should only be permitted from verified content partner studio accounts.
UGC Customers should have a dedicated human content moderation team that is trained to identify and take down illegal and abusive material. The content moderation team should be proactive and not only responsive to complaints. The size and composition of the team should be consistent with the size of the site and the customer’s resources.
UGC Customers should develop and implement a list of banned / flagged words (“Banned Words List”) which trigger deletion or review by the content moderation team. The Banned Words List must be consistent with industry standards for identifying illegal or abusive content, and regularly updated.
UGC Customers should engage in ongoing moderation of their customers’ search terms in an effort to identify phrases designed to bypass existing safeguards.
UGC Customers should label their sites in such a way that will allow the sites to be identified and blocked by standard parental control filters.
UGC Customers should use reasonable efforts to integrate automated filters designed to detect illegal and abusive content, such as:
UGC Customers should implement a reporting form or feature that allows users and third parties to report illegal or abusive content to the site for expedited review and removal if appropriate.
UGC Customers should implement a program designed to allow trusted third parties to identify and immediately disable access to illegal content pending review by the customer. Examples of trusted third-parties include: Cyber Civil Rights Initiative (United States of America), National Center for Missing & Exploited Children (United States of America), Internet Watch Foundation (United Kingdom), Stopline (Austria), Child Focus (Belgium), Safenet (Bulgaria), Te Protejo Hotline - I Protect You Hotline (Colombia), CZ.NIC - Stop Online (Czech Republic ), Point de Contact (France), Eco-Association of the Internet Industry (Germany), Safeline (Greece), Save the Children (Iceland), Latvian Internet Association (Latvia), Meldpunt Kinderporno - Child Pornography Reporting Point (Netherlands), Centre for Safer Internet Slovenia (Slovenia), FPB Hotline - Film and Publication Board (South Africa), ECPAT (Sweden), ECPAT (Taiwan).
UGC Customers should agree to comply with any legal obligations to report apparent underage content to appropriate agencies such as the National Center for Missing and Exploited Children (NCMEC).
UGC Customers should publish, on no less than an annual basis, a transparency report identifying their content moderation and removal efforts.
