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The ICO is calling for views to support the development of guidance that will provide clarity on how data protection law applies to online content moderation processes.

Content moderation is the process of analysing content generated by users of online platforms to assess whether it meets certain standards or whether it is appropriate for a given context. This content can often include personal data and the analysis may trigger subsequent action to be taken, such as removal of the content, escalation to human moderator or application of a content warning. We have a role to ensure that personal data is processed in compliance with data protection law during content moderation.

This work is the first step in meeting commitments set out in our November 2022 Joint Statement with Ofcom to provide certainty for organisations in scope of the future UK online safety regime

Our guidance, in parallel with our ongoing collaborative work with Ofcom, will support organisations to meet both their data protection and online safety responsibilities. It will also support other organisations developing and deploying content moderation in a non-online safety context.

As part of our call for views we want to understand more about:

  • How content moderation solutions use people’s personal data, and how the solutions are being used or developed more generally.
  • Where clarification is needed on the application of UK GDPR, DPA 2018 and PECR to content moderation.
  • What challenges organisations are facing relating to data protection when they deploy content moderation processes.

We recognise that content moderation is a developing area and new approaches are continuing to emerge. We are launching this call for views to develop our knowledge and to ensure that the guidance we provide about meeting data protection expectations is meaningful to organisations.

Responding to the call for views

We want to hear from organisations and individuals with expertise, experience or an interest in the use of content moderation technology.

Please complete the call for views through our online survey, available through the link below. Alternatively you can download the Word document and email your response to [email protected].

You don’t need to answer every question - some of the questions may not be relevant to you or your organisation, so please skip these as necessary.

This call for views will remain open until 9 June 2023.

If you have any general queries about the call for views or would like further information, please email us at [email protected].

Privacy statement

For this consultation, we may publish a summary of the responses but will not publish the actual responses received from organisations or individuals. If we publish a summary of the responses, information and views will not be attributed to individual respondents.

Should we receive an FOI request for your response we will need to consider whether we make it available. However, at this point, we would always seek to consult with you for your views on the disclosure of this information before any decision is made.

For more information about what we do with personal data please see our privacy notice.

Please note that we are using the platform Snap Surveys to gather this information. Any data collected by Snap Surveys for ICO is stored on UK servers. You can read their Privacy Policy here.