Transparency Reporting Procedure (LEG-PROC-002)

1. Purpose

The purpose of this procedure is to describe the systematic process for collecting data and publishing transparency reports in compliance with DSA Articles 15, 24, and 42, ensuring accurate and comprehensive reporting of content moderation activities, user appeals, and platform governance measures.

2. Scope

This procedure applies to all data collection and transparency reporting activities for the video streaming platform including content moderation metrics, appeals processing statistics, regulatory orders, and automated system performance data. It covers all geographic regions and user-generated content categories.

3. Overview

This procedure ensures systematic collection, validation, and publication of transparency data through coordinated efforts across Legal, Trust & Safety, and Data Analytics teams. The process prioritizes accuracy, completeness, and regulatory compliance while providing meaningful insights to users, regulators, and the public about platform governance.

4. Procedure

Step Who What
1 Data Analytics Team Extract quarterly content moderation metrics including total number of moderation actions categorized by type of illegal content and policy violations (terrorism, child sexual abuse, hate speech, copyright infringement, etc.).
2 Data Analytics Team Collect appeals data including total number of appeals received, categorized by original moderation action type, and outcomes (decision upheld, reversed, or modified) with percentage breakdowns.
3 Data Analytics Team Calculate median processing times for content moderation notices, user appeals, and regulatory orders from receipt to final resolution across all categories.
4 [Legal Department/Team Name] Compile data on orders received from EU member state authorities including number of requests, type of content involved, geographic scope, and compliance actions taken.
5 [Trust & Safety Department/Team Name] Document automated moderation system performance including accuracy rates, false positive rates, error margins, and human review percentages for different content categories.
6 Data Analytics Team Validate all collected metrics for accuracy, completeness, and consistency using standardized data quality checks and cross-reference verification procedures.
7 [Legal Department/Team Name] Review compiled data for regulatory compliance, legal accuracy, and alignment with DSA transparency reporting requirements including confidentiality considerations.
8 [Trust & Safety Department/Team Name] Provide context and explanations for significant changes in moderation metrics, policy updates, or system improvements that affected reported data.
9 Data Analytics Team Prepare comprehensive transparency report draft with clear data presentations, methodology explanations, and comparative analysis with previous reporting periods.
10 [Legal Department/Team Name] Conduct final legal review of transparency report for compliance with DSA requirements, accuracy of legal interpretations, and protection of sensitive information.
11 Executive Leadership Review and approve final transparency report for publication, ensuring alignment with corporate transparency commitments and regulatory obligations.
12 [Legal Department/Team Name] Publish transparency report on company website and submit to relevant regulatory authorities within required DSA timeframes, ensuring public accessibility and regulatory notification.

5. Standards Compliance

Procedure Step(s) Standard/Framework Control Reference
1-3 EU Digital Services Act Art. 15
1-3 PCI DSS v4.0 Req. 12.1
4 EU Digital Services Act Art. 24
4 PCI DSS v4.0 Req. 10.6
5 EU Digital Services Act Art. 42
5 PCI DSS v4.0 Req. 12.10.1
9-12 EU Digital Services Act Art. 15
9-12 PCI DSS v4.0 Req. 12.2

6. Artifact(s)

A comprehensive transparency report containing validated metrics on content moderation actions, appeals outcomes, processing times, regulatory orders, and automated system performance with detailed methodology explanations stored in the compliance reporting system and published for public access with appropriate data retention and privacy protections.

7. Definitions

Content Moderation Actions: All enforcement actions taken against user content including removal, restriction, labeling, demonetization, and distribution limitations.

Illegal Content Categories: Content classifications defined by applicable laws including terrorism, child sexual abuse material, hate speech, copyright infringement, and other prohibited content types.

Automated Moderation Systems: AI and machine learning tools used for content analysis, risk assessment, and preliminary moderation decisions before human review.

Processing Time: Duration from initial receipt of notice, appeal, or order to final resolution and user communication.

Accuracy Rate: Percentage of automated moderation decisions that align with subsequent human review determinations.

False Positive Rate: Percentage of content incorrectly identified as violating policies by automated systems.

8. Responsibilities

Role Responsibility
Data Analytics Team Extract, validate, and analyze transparency metrics from platform systems, ensure data accuracy and completeness, and prepare statistical presentations for reporting.
[Legal Department/Team Name] Compile regulatory order data, review report for legal compliance, coordinate with authorities, and manage publication process within required timeframes.
[Trust & Safety Department/Team Name] Provide moderation policy context, automated system performance data, and explanatory analysis for significant metric changes or policy updates.
Executive Leadership Review transparency report for strategic alignment, approve publication, and ensure organizational commitment to transparency and regulatory compliance.
Compliance Team Monitor DSA reporting requirements, coordinate cross-functional reporting efforts, and ensure adherence to regulatory timelines and standards.
Communications Team Support public communication about transparency report publication and coordinate with stakeholders regarding report availability and key findings.

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