User Moderation Appeals Procedure (TS-PROC-002)

1. Purpose

The purpose of this procedure is to describe the process for handling user appeals of content moderation decisions to ensure fair, transparent, and timely review of moderation actions while maintaining platform safety and compliance with regulatory requirements including the EU Digital Services Act.

2. Scope

This procedure applies to all user appeals of content moderation decisions including content removal, account restrictions, demonetization, and distribution limitations. It covers appeals submitted through platform interfaces, email, and other communication channels across all geographic regions.

3. Overview

This procedure provides users with a fair opportunity to challenge moderation decisions through independent review by trained appeals specialists who were not involved in the original decision. The process emphasizes transparency, consistency, and timely resolution while maintaining platform safety standards.

4. Procedure

Step Who What
1 User Submit appeal through platform interface or designated channels within 30 days of moderation action, providing additional context or evidence as needed.
2 Appeals System Automatically acknowledge appeal receipt within 24 hours, assign unique case number, and provide estimated response timeline to user.
3 Appeals Triage Review appeal for completeness, categorize by complexity and urgency, and assign to appropriate appeals specialist based on expertise and workload.
4 Appeals Specialist Conduct independent review of original content, moderation decision, community guidelines, and any additional evidence provided by user.
5 Appeals Specialist Consult with subject matter experts for complex cases involving cultural context, legal requirements, or technical platform features.
6 Appeals Specialist Make appeals decision (uphold, reverse, or modify original decision) based on policy compliance and provide detailed reasoning for decision.
7 Senior Appeals Reviewer Review high-impact appeals or cases involving policy interpretation before final decision communication to ensure consistency and accuracy.
8 Appeals Specialist Communicate decision to user within 7 days (2 days for expedited appeals) with clear explanation of reasoning and any further appeal options.
9 Content Management Implement appeals decision including content restoration, account reinstatement, or adjustment of enforcement actions as appropriate.
10 User Communication Provide follow-up communication confirming implementation of appeals decision and any additional guidance for future content creation.
11 Quality Assurance Monitor appeals decision quality through random sampling, accuracy assessment, and consistency measurement across appeals specialists.
12 Data Analysis Track appeals metrics including volume, decision rates, processing times, and user satisfaction for process improvement and transparency reporting.

5. Standards Compliance

Procedure Step(s) Standard/Framework Control Reference
1-2 EU Digital Services Act Art. 20
1-2 PCI DSS v4.0 Req. 7.1.1
4-6 ISO/IEC 27001:2022 A.7.2.2
4-6 PCI DSS v4.0 Req. 8.1, 8.2
7-8 EU Digital Services Act Art. 20
7-8 PCI DSS v4.0 Req. 12.10.1
11-12 EU Digital Services Act Art. 24
11-12 PCI DSS v4.0 Req. 10.6, 12.2

6. Artifact(s)

A complete appeals case record containing original moderation decision, user appeal submission, independent review analysis, appeals decision with reasoning, implementation confirmation, and quality assurance evaluation stored in the appeals management system with appropriate privacy protections.

7. Definitions

Appeals Specialist: Trained reviewer responsible for conducting independent assessment of moderation appeals who was not involved in the original decision.

Independent Review: Appeals assessment conducted by personnel separate from the original moderation team to ensure objectivity.

Expedited Appeals: Fast-track review process for time-sensitive content including breaking news, public interest, or rapidly spreading content.

High-Impact Appeals: Appeals involving significant user accounts, viral content, or potential policy precedent requiring senior review.

Appeals Triage: Initial assessment and categorization of appeals to determine priority, complexity, and appropriate reviewer assignment.

Reverse Decision: Appeals outcome that overturns the original moderation action and restores content or account status.

7.1 Out-of-Court Dispute Settlement

In compliance with DSA Article 21, users who have exhausted the internal appeals process and remain dissatisfied with the appeals decision have the right to select a certified, independent out-of-court dispute settlement body to resolve disputes regarding content moderation decisions. [Company Name] commits to engage with any such selected dispute settlement body in good faith and will cooperate with the dispute resolution process. Information about available certified dispute settlement bodies and the process for initiating out-of-court dispute settlement will be provided to users upon completion of the internal appeals process.

8. Responsibilities

Role Responsibility
Appeals Specialists Conduct fair and independent review of moderation appeals, make consistent policy-based decisions, and communicate clearly with users about outcomes.
Appeals Triage Team Efficiently categorize and prioritize appeals, assign cases appropriately, and ensure timely processing of all appeal submissions.
Senior Appeals Reviewers Review complex appeals decisions, ensure consistency across appeals team, and provide guidance on policy interpretation and precedent.
Subject Matter Experts Provide specialized expertise on cultural, legal, or technical aspects of content for complex appeals requiring additional context.
Quality Assurance Team Monitor appeals decision quality, provide feedback and training, and identify opportunities for process improvement and policy clarification.
User Communications Provide clear and empathetic communication with users throughout appeals process and ensure understanding of decisions and next steps.

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