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This letter was sent to Ms. Sissons on 3 January 2022. We are now publishing the letter with additional signatories, updated as of 19 January 2022.

Miranda Sissons
Director of Human Rights
Facebook Inc. (Meta)

Release of the Human Rights Impact Assessment of Facebook in India

Dear Ms. Sissons,

In 2020, Facebook (now Meta) commissioned the law firm Foley Hoag to conduct a Human Rights Impact Assessment (HRIA) to evaluate its role in spreading hate speech and incitement to violence on its services in India, the company’s largest market. A year and a half later, the HRIA has not yet been released. Furthermore, the Wall Street Journal recently reported that Facebook’s Human Rights team has taken steps that can be perceived as an effort to narrow the scope of, and perhaps stifle, the independent HRIA it commissioned. In response, a Facebook spokesperson said “we look forward” to the report being completed, while Foley Hoag said their work “still is ongoing.”

The Wall Street Journal report is worrying for a number of reasons. As the whistleblower Frances Haugen’s reports have made clear, there is an epidemic of hate speech and disinformation on Facebook’s platforms in India, particularly targeting Muslims and other minority groups. Much of this content flagrantly violates community standards, yet it has not been taken down – partly because Facebook has not allocated nearly enough resources to tackling the problem. At the same time, the Wall Street Journal has published troubling reports of a pattern of favoritism by FB India toward the ruling BJP party in India, as well as ties between a former FB India staff and the party.

Given these circumstances and indications that the company has not adequately respected the rights of minorities online in India, it is vitally important that an HRIA probing Facebook’s human rights impacts in India be thorough, extensive, and entirely independent. Any indication or perception that this is not the case is deeply concerning. We understand that Facebook has narrowed the draft report’s scope and demanded more data and made technical objections. This has created the impression that the HRIA is not independent or that Facebook does not wish for certain information to be included.

As human rights and digital rights organizations, we are troubled by reporting that the Human Rights team at Facebook may be involved in shaping the HRIA in any way.

The current perception is that Facebook is not committed to respecting rights in this case. The India HRIA is an important element of Facebook’s human rights due diligence and, at a minimum, should be made public, in line with the company’s responsibility to respect human rights. The UN Guiding Principles on Business and Human Rights are clear that transparency is a key aspect of human rights due diligence and that in order to account for how they address human rights impacts, companies should “be prepared to communicate this externally, particularly when concerns are raised by or on behalf of affected stakeholders.”*
Facebook should demonstrate that it is committed to an independent, thorough, and ultimately public HRIA on India, to gain and retain the trust of the human rights and digital rights communities, as well as the billions of users of Facebook’s services in India, and to counter the perception that Facebook is resistant to such measures.

Members of civil society have shared their time and insight with the lawyers of Foley Hoag. We urge the company to release a public, unredacted, and complete India Human Rights Impact Assessment without delay.


Access Now
Accountable Tech
Amnesty International
Article 21
Association for Progressive Communications (APC)
Citizens for Justice and Peace
Defend Democracy
Electronic Frontier Foundation
Foundation the London Story
Global Witness
Hate Speech Beda
Human Rights Watch
India Civil Watch International
Internet Freedom Foundation
Real Facebook Oversight Board
The Signals Network

* UN Guiding Principles on Business and Human Rights, Principle 21.