Content Moderation Policy (TS-POL-001)
1. Objective
This policy establishes requirements for content moderation activities to ensure user-generated content on the video streaming platform complies with community guidelines, legal requirements, and regulatory obligations. The framework maintains user safety, platform integrity, and compliance with the EU Digital Services Act and other applicable regulations while fostering a healthy environment for creative expression and community engagement across our global platform.
2. Scope
This policy applies to all user-generated content on the video streaming platform including videos, comments, live streams, user profiles, and metadata. Coverage encompasses all content moderation activities, automated systems, human review processes, and appeals procedures across all geographic regions where [Company Name] operates, ensuring consistent global standards while respecting local legal requirements.
3. Policy
3.1 Content Moderation Framework
The Company must maintain multi-layered content review using AI-powered detection and human moderation and implement a risk-based moderation approach prioritizing harmful content and vulnerable users. The Company must provide transparent content policies and community guidelines accessible to all users and conduct regular review and updates of moderation policies based on emerging threats and regulatory requirements. The Company must ensure integration with platform recommendation and discovery algorithms and maintain compliance with Digital Services Act transparency and accountability requirements.
3.2 Automated Content Detection
AI-powered content moderation systems must train machine learning models on diverse datasets to minimize bias across demographics and conduct regular bias testing and fairness assessments across protected characteristics. The Company must implement continuous model improvement based on human reviewer feedback and accuracy metrics and provide explainable AI capabilities to provide reasoning for automated decisions. The Company must maintain performance monitoring with accuracy, precision, and recall metrics by content category and establish escalation procedures for edge cases and novel content types requiring human review.
3.3 Human Content Review
Human moderators must receive comprehensive training on community guidelines, legal requirements, and cultural sensitivity and have access to mental health support and counseling services for moderators exposed to harmful content. The Company must conduct regular calibration sessions to ensure consistency across moderation decisions and implement quality assurance programs with random sampling and accuracy measurement. The Company must establish clear escalation procedures for complex or sensitive content decisions and maintain documentation requirements for moderation decisions and reasoning.
3.4 Content Categories and Actions
Content moderation must address specific categories of harmful or prohibited content:
Prohibited Content (Immediate Removal):
- Illegal content including child exploitation, terrorism, and copyright infringement
- Graphic violence and threats against individuals or groups
- Non-consensual intimate imagery and harassment
- Spam, malware, and deceptive practices
- Hate speech and discriminatory content targeting protected characteristics
Restricted Content (Limited Distribution):
- Age-inappropriate content requiring age verification or restricted access
- Potentially misleading information requiring fact-checking labels
- Content violating intellectual property rights pending review
- Borderline content that approaches but doesn’t violate community guidelines
Enforcement Actions:
- Content removal with user notification and appeal rights
- Content demonetization and reduced distribution
- Account warnings, suspensions, and permanent bans
- Shadow banning and reduced visibility for repeat offenders
- Geographic content blocking for region-specific legal requirements
3.5 Appeals and Due Process
Users must have clear appeals procedures accessible within 24 hours of moderation action and receive human review of all appeals with response within 7 days for standard appeals. The Company must provide expedited appeals process for time-sensitive content (news, public interest) and maintain an independent review board for high-impact content decisions. The Company must publish transparency reporting on appeals volume, outcome rates, and processing times and provide user communication explaining moderation decisions and appeal rights.
3.6 Transparency and Accountability
Content moderation practices must publish public transparency reports quarterly with detailed moderation metrics and maintain community guidelines easily accessible and translated into local languages. The Company must conduct regular stakeholder engagement including user feedback and expert consultation and perform external audits of content moderation practices and bias assessments. The Company must provide researcher access programs for academic study of content moderation effectiveness and ensure compliance with DSA requirements for algorithmic transparency and risk assessments.
3.7 Special Protections
The Company must provide additional protections for users under 18 with specialized moderation workflows and implement crisis intervention procedures for content indicating self-harm or suicide risk. The Company must ensure expedited review for content related to public health emergencies and maintain cultural and linguistic expertise for content in diverse languages and regions. The Company must coordinate with law enforcement for criminal content while protecting user privacy and provide whistleblower protection for moderators reporting policy violations or safety concerns.
3.8 Cross-Border and Legal Compliance
Content moderation must implement geographic content blocking for country-specific legal requirements and ensure compliance with local content laws while maintaining consistent global standards. The Company must establish legal review processes for government takedown requests and maintain documentation and reporting of content removals for regulatory compliance. The Company must coordinate with legal teams for complex jurisdictional issues and provide regular legal training for moderation teams on evolving regulatory requirements.
4. Standards Compliance
| Policy Section | Standard/Framework | Control Reference |
|---|---|---|
| 3.1, 3.6 | EU Digital Services Act | Art. 15, 24 |
| 3.1 | PCI DSS v4.0 | Req. 12.1 |
| 3.2 | EU Digital Services Act | Art. 27 |
| 3.2 | PCI DSS v4.0 | Req. 12.10.7 |
| 3.3 | ISO/IEC 27001:2022 | A.7.2.2 |
| 3.3 | PCI DSS v4.0 | Req. 7.1, 8.1 |
| 3.5 | EU Digital Services Act | Art. 20 |
| 3.5 | PCI DSS v4.0 | Req. 12.2 |
| 3.6 | EU Digital Services Act | Art. 24, 42 |
| 3.6 | PCI DSS v4.0 | Req. 12.10.1 |
| 3.7 | COPPA | § 312.2 |
| 3.7 | PCI DSS v4.0 | Req. 3.3.1 |
| 3.8 | GDPR | Art. 3, 44-49 |
| 3.8 | PCI DSS v4.0 | Req. 4.1 |
5. Definitions
Content Moderation: The practice of monitoring and applying predetermined rules and guidelines to user-generated content.
Community Guidelines: Platform-specific rules that define acceptable behavior and content for users.
Digital Services Act (DSA): EU regulation requiring transparency and accountability in content moderation for large online platforms.
Algorithmic Bias: Systematic and unfair discrimination in automated decision-making systems affecting certain groups.
Shadow Banning: Reducing content visibility without explicitly notifying the user of the action.
Explainable AI: AI systems designed to provide understandable explanations for their decisions and recommendations.
Transparency Report: Public document disclosing content moderation activities, metrics, and policy enforcement statistics.
6. Responsibilities
| Role | Responsibility |
|---|---|
| [Trust & Safety Department/Team Name] | Develop and implement content moderation policies, oversee moderation operations, and ensure compliance with community guidelines and legal requirements. |
| Content Moderators | Review user-generated content according to guidelines, make consistent moderation decisions, and escalate complex cases appropriately. |
| AI/ML Teams | Develop and maintain automated content detection systems, conduct bias testing, and improve model accuracy and fairness. |
| [Legal Department/Team Name] | Provide guidance on content moderation legal requirements, review government requests, and ensure compliance with regional laws and regulations. |
| Policy Team | Develop community guidelines, coordinate policy updates, and engage with stakeholders on content moderation standards. |
| User Appeals Team | Process user appeals fairly and consistently, provide clear communication, and identify policy improvement opportunities. |