Regulating for rights – IFLA comments on the draft UNESCO Guidelines on Platform Regulation
08 March 2023
Following our participation in the UNESCO Internet4Trust conference, IFLA has now submitted comments on UNESCO’s draft Guidelines on Platform Regulation. In addition to welcoming the balance found in the document, we also propose improvements, including readier recognition of libraries’ role in a healthy internet.
Platforms have had a huge role in shaping the internet as we know it today, enabling new forms of communication and creativity. Yet at the same time, they have also accelerated some more negative phenomena, causing real harm.
As states rush to work out what approach to take to regulating them, UNESCO has stepped forwards to propose a draft set of guidelines, which have the potential to be an important reference point.
This is a welcome step, given that such regulation, if done badly, can have far reaching consequences. It is vital in particular to ensure that the value of freedom of expression and access to information remains at the heart of any law-making. The draft Guidelines do exactly this.
IFLA’s comments on the Draft Guidelines therefore strongly endorse this overall focus and thank UNESCO for its work in this space.
One element that is currently absent from the guidelines, however, is the role of libraries. Our institutions and profession bring valuable and relevant experience of how to promote these freedoms, given long work to collect and give access to diverse, and sometimes difficult, materials. Crucially, it will help to underline that laws should uphold the value of access to all types of information, not just media or government information.
More directly still, the Guidelines’ emphasis on the importance of promoting media and information literacy is weakened by the lack of a specific reference to libraries, which would be valuable in ensuring their inclusion in national policy efforts. Such activities can be supported by platforms directly, but also through effective taxation that ensures resources are available for libraries to do their work.
Another issue currently missing is the need to have a means of archiving content which may break rules, but which can represent vital evidence in, for example, prosecuting those guilty of human rights abuses.
Finally, IFLA’s comments underline that there should be a guarantee that the sort of regulation applied to major commercial platforms such as Facebook or YouTube should not apply to the non-profit repositories run or used by any libraries, and which are essential for open access, science and education.
Further support for balance
There are also useful steps that could be taken to enhance the value of the Guidelines. IFLA’s submission notes the importance of maximising possibilities for users to choose platforms, and so ensuring that new players can emerge.
Similarly, we highlight concerns about ‘must-carry’ provisions that would oblige platforms to display certain content – something that we would not accept in libraries. What will be important are clear processes for content moderation, and reporting on how they operate in practice, in a way that is accessible for all.
The same goes for activities around media and information literacy, which would very much benefit from stronger resourcing. However, this needs to be done in a way that does not lead to bias.
A further concern is about the risk of internet fragmentation created by divergent regulation of platforms. This is an area where the guidelines themselves may favour harmonisation, but it will be powerful to make this explicit.
You can access the full IFLA comments here, and we will continue to report on our engagement around the Guidelines through our news pages.