Guidance Note
Moderating User Generated Content
Issued: 16 June 2011
Revised: 19 June 2014
Scope of this Guidance Note
This guidance note applies to the moderation of user generated content appearing
on ABC websites and on official ABC interactive services established on third-party
websites, such as ABC accounts on external social media sites (Facebook, YouTube
etc).
User generated content includes text (comments, posts), photos, images, video and
audio submitted for publication on ABC websites, official ABC presences on thirdparty sites or other interactive services.
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In the case of interactive services established by the ABC and specifically designed
for children under the age of 18, refer to the Guidance Note Children and Young
People: Managing their Participation Online.
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Mandatory referrals
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All user generated content (UGC) published on ABC platforms must be moderated –
either pre-moderated, post-moderated or reactively moderated.
Any proposal for post-moderation or reactive moderation of an interactive service
must be approved by an appropriately senior ABC person designated for the purpose
within the responsible division.
Any proposal to set up an ABC interactive service on a third-party site must be
approved by an appropriately senior ABC person designated for the purpose within
the responsible division and the division’s Social Media Representative.
Any threats of violence, self-harm or harm to other people or property or other
security issues must be referred to the ABC Security Manager (02 8333 1640 or
abc.security@abc.net.au) as well as upward referred to the relevant Editorial
Manager. In the event that a threat appears to be insincere or a hoax, the matter
must be referred as if it were genuine.
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Introduction
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The ABC hosts numerous online discussion spaces intended as “electronic town
squares”, where members of the public are invited to contribute and participate.
These spaces enable our audiences to engage with and debate ideas and issues,
and to share a diverse range of perspectives, experiences and imaginations. The
discussions are publicly visible and attract an audience much greater than the
numbers who directly contribute.
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As host, the ABC has a responsibility to ensure the integrity, amenity and safety of
these discussion spaces, and to ensure that they serve the interests of both
contributors and readers. We expect all online users to treat each other with respect
and courtesy.
In managing these spaces, the ABC should be as transparent as possible. Our
approach should be consistent across the online platform, taking into account
different audiences and topics.
This Guidance Note covers –
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What is Moderation?
a. Moderation
b. Types of moderation
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Who Moderates?
a. Role and responsibility of the moderator
b. Moderation Plan
c. Editorial responsibility and upward referral
d. Registration
e. Training
3.
How to Moderate?
a. Conditions of Use
b. House Rules
c. Moderation issues
d. Privacy and identification
e. Staff comments and contributions
f. Security
g. Complaints
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Moderating ABC Presences on Third-Party Sites
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1. What is Moderation?
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a. Moderation
Moderation is the review of user generated content and the decision to publish, edit
or delete the content or at times to engage with the online community.
Moderation is the ABC’s main means of managing the risk of inappropriate user
generated content being published by users. This risk varies according to a number
of factors such as legal risks – defamation, racial vilification, contempt of court or
breach of copyright – or editorial policy risks – publishing material likely to cause
harm or offence or material that could be perceived as advertising or commercial
promotion.
Managers of online communities associated with ABC programs and networks also
need to consider the potential risk of inappropriate content to the reputation of the
program, network and the ABC.
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b. Types of moderation
There are three approaches to moderation in use at the ABC –
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Pre-moderation
All posts are moderated before they appear online.
Pre-moderation enables the ABC to manage sites where the risk associated
with publishing inappropriate content is high. This might include some news
and current affairs sites, the discussion of sensitive or controversial topics, sites
targeted at children or sites inviting submission of users’ photos, video or audio.
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The House Rules on pre-moderated sites might indicate that posts submitted
overnight or on weekends may not appear online until the next working day.
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Post-moderation
All posts appear online immediately which enables users to have a free flowing
conversation unimpeded by the delays that occur when each post needs to be
approved.
All posts are moderated after they appear online.
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Post-moderation may be the most appropriate editorial choice where –
there is low risk that the topic might generate offensive or abusive content;
the risk of users posting inappropriate content is considered low; or
adequate moderation resources are available to ensure prompt and timely
review of all submissions.
The rhythm of review will reflect the nature of the content, the online audience
and the risk of inappropriate content remaining online for an extended period. In
some circumstances it may be appropriate to revert to pre-moderation
overnight or on weekends.
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Reactive moderation
All posts appear immediately online. Posts are only moderated after the
moderator receives an alert from a user. This form of moderation is often used
in conjunction with post-moderation.
Reactive moderation may be appropriate where a particular community has
demonstrated a high degree of responsibility and an ongoing ability to manage
themselves. It is more likely to suit topics which tend not to attract polarised or
extreme responses.
The decision about the appropriate moderation type is based on factors including
target audience, history of audience behaviour and management, nature of topics,
the availability of moderation resources, how long the ABC intends to continue to
publish the UGC, and the platform. The choice to pre-moderate is not available on
most third-party sites, including Facebook.
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Any proposal for post-moderation or reactive moderation of an interactive service
must be approved by an appropriate senior ABC person designated for the purpose
within the responsible division.
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Moderators should consider scheduling specific times through the day to
moderate posts.
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Wherever moderator alerts are enabled, editorial managers should ensure there is a
well managed system of accessing and dealing with the alerts as they are delivered
via email. The moderator must monitor the email account regularly and act on alerts
promptly. Good practice is to avoid lengthy delays. Such delays could have legal
implications. Editorial managers and moderators should devise a Moderation Plan for
monitoring and acting on alerts received after normal business hours.
Editorial managers and moderators should ensure that all moderator alerts are
dealt with as soon as possible.
2. Who Moderates?
a. Role and responsibility of the moderator
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The moderator is the person who manages the online community for a particular site
on behalf of the ABC. This may include:
creating the Moderation Plan;
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getting approval for the plan (if required by the division);
writing and posting the site’s House Rules in accordance with the Conditions of
Use;
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monitoring users’ behaviour on the site, including holding (or blocking or banning
users) if and when required;
being editorially responsible for deciding whether UGC is published, edited or
deleted according to the selected moderation type (pre-, post- or reactive) and
consistent with the Editorial Policies, the Conditions of Use and the House
Rules.
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The moderator’s role is to be objective, impartial, respectful and fair.
Moderators should strive to keep the interactive space safe for all users.
They should generally ensure participants do not publish inappropriate personal
information such as personal contact details. House Rules can be used to define this
for the particular site. (See Privacy and identification below.)
Moderators need to monitor the language and tone of contributions to keep the
space attractive to potential users. They need to ensure the language of published
posts and conversations does not become abusive, aggressive, bullying or
intimidating, or contain inappropriate personal attacks.
Moderators may act as online hosts posting opening welcome messages and closing
notes.
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Moderators may publish ‘moderator notices’ to stories and threads reminding users
of the ABC Conditions of Use, the site’s House Rules or specific moderation issues.
In their role as hosts moderators may enter the discussion and post replies to
audience questions on behalf of programs or sites – in which case they should
generally identify themself as the host. Moderators of successful community spaces
find a balance between active facilitation and participation, and allowing the audience
to drive a conversation. If moderators intend to take on the role of host as well as
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moderator they should seek advice from their editorial manager on distinguishing
these roles.
Moderators are not expected to routinely convey reasons for moderation, deletion or
editing to individual audience members. However they should consider keeping
records for occasions when moderation decisions are questioned by users or are the
subject of a formal complaint. It may be appropriate to maintain file notes on
significant incidents, or where an audience member has continued to ignore
published House Rules, Conditions of Use etc. These notes may include
screenshots.
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b. Moderation Plan
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Moderators should develop a Moderation Plan, preferably while planning the
interactive feature. This will indicate –
who is editorially responsible for the content published;
purpose of an interactive feature;
resourcing, including detail of moderating over different times of the day, week
and year;
expected lifespan of the user generated content;
moderators and panellists;
specific moderation approaches adopted for different times; and
include House Rules specific to the needs of the site.
If these strategies include post- or reactive moderation the plan can indicate
maximum likely delays in reviewing contributions or reviewing audience alerts.
Where post- or reactive moderation is to be used, prior approval must be obtained –
see Mandatory referrals above.
c. Editorial responsibility and upward referral
Editorial responsibility for the particular ABC site or ABC-managed spaces on thirdparty sites which includes the moderation of UGC must be clarified and documented.
If there is more than one moderator for a site, it is particularly important for the lines
of upward referral to be clear and for the editorial manager to be available for
referrals. It is also important for there to be clear communication between all
moderators and the editorial manager to ensure consistency in applying Editorial
Policies, Conditions of Use and site House Rules (see below).
When in doubt
If a moderator is unsure of the appropriate decision regarding a post submitted to a
pre-moderated discussion space, the post should not be published, and the
moderator should upwardly refer to their editorial manager. If the moderator is
uncertain about a post already published to a post-moderated space and if the
particular platform permits, they should remove it and seek advice as above.
A moderator may also seek advice from ABC Legal regarding specific posts.
However after considering this legal advice, the final decision about publishing the
post rests with the moderator. If there are security threats moderators must upward
refer to their editorial manager and to ABC Security immediately (see Security
below).
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d. Registration
Users may register a preferred username with the ABC. This requires them to use a
valid email address to receive an access password. It should be clear to users of
ABC interactive services where they can register to participate. A user should be
able to manage their registered online identity.
e. Training
All moderators should be trained in ABC moderating practices. This training should
include –
ABC Editorial Policies;
the Moderation Plan;
techniques to manage online communities;
an understanding of legal concepts including defamation, contempt, copyright,
racial vilification and privacy;
ABC complaints handling procedures.
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3. How to Moderate?
a. Conditions of Use
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Audience members contribute to all ABC interactive services under Conditions of
Use developed in consultation with ABC Legal. The ABC’s Conditions of Use may be
supplemented, but cannot be overridden, by local House Rules tailored to a
particular site or interactive service. The Conditions of Use and the House Rules
must be readily accessible to users.
b. House Rules
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House Rules explain to community members how user generated contributions to a
particular site are moderated, provide site specific rules for contributions and may
highlight any grounds on which the ABC may refuse to publish, or may edit or
remove, a contribution.
Typical House Rules might describe the scope of the discussion on the site, or the
type of content that audience members are invited to contribute. The House Rules
might also detail the local site’s approach to the editing of audience contributions, as
well as length or duration of contributions etc.
The House Rules can also simply re-state aspects of the Conditions of Use that may
require reinforcement such as reminders about the inappropriateness of abusive
behaviour or offensive language and the acceptable level of commercial references.
It can also remind users to be aware of privacy and security issues in interacting
online.
c. Moderation issues
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Accuracy
The ABC does not require content generated and submitted by individuals and
organisations to meet the Editorial Policies standard of accuracy. However, where
the ABC is satisfied that it is appropriate to do so, the ABC may decline to broadcast
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or publish, or may edit, remove, correct or clarify content generated by users that
contains a significant material error or is otherwise false, misleading or harmful.
Where UGC is to be incorporated into factual content, checks must be made to verify
the accuracy of any factual material contained or presented within UGC.
Critical / negative opinions
The ABC takes a robust approach to criticism of its own content. Critical comments
about ABC content, presenters or the issues canvassed in the program should be
published, provided they are not abusive or defamatory of the presenter or any other
program participant, and are consistent with the ABC’s Conditions of Use and the
site’s House Rules.
Impartiality
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Individuals and organisations who generate and submit content are not required to
be impartial. The ABC recognises that social and political activity, including robust
debate, is a necessary and desirable aspect of a healthy democratic community.
Public discussion spaces reflect the views of their users. From time to time one
particular side of the debate may dominate views expressed there. This simply
reflects the natural flow of comments received.
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The ABC reserves the right to reject contributions that have already been widely
canvassed in the discussions. It also reserves the right to reject contributions from
users who seek to dominate the discussion.
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Offensive posts
UGC will not be published if the ABC considers it to be abusive, offensive, bullying or
violating laws such as defamation, harassment, discrimination or racial vilification.
Such posts will be deleted from post-moderated and reactively moderated sites.
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Copyright
Moderators should delete or not publish a contribution they reasonably believe to be
an infringement of copyright.
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Commercial references
References to commercial brands in contributions may be acceptable if they are
editorially justified, or contextually relevant. An acceptable commercial reference may
include providing audiences with useful information in event diaries. UGC including
login or user names that promote a particular brand, product or service will be
deleted if the ABC determines the UGC is part of a marketing campaign.
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External links
External links included in audience contributions should be checked initially or at the
earliest opportunity, consistent with the moderation approach in use for the site, to
ensure they link to appropriate and relevant content, particularly links to commercial
products or services. Any links to illegal or offensive sites should be deleted. In
situations where the volume of posts makes it impractical to check every link,
moderators may remove the links in comments, or reject the comment, but such an
approach should be reflected in the house rules of the site.
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Off topic
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User generated messages are expected to add value to, or advance, the topic of
conversation at hand. Moderators should be wary of exchanges between individuals
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which descend into personal ‘slanging matches’, with each participant seeking the
last word. Off- topic contributions or comments can be deleted.
d. Privacy and identification
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Moderators must be careful not to reveal unnecessarily personal information about
themselves, their colleagues, or contributors to ABC online platforms such as
Message Boards. On third-party sites, revealing personal information of users may
be a feature of the site (e.g. Facebook).
Moderators should be familiar with the ABC’s Privacy Policy and relevant online
Privacy Statements.
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As part of their duties moderators may have access to the personal information of
users and contributors. This information can only be used for the purposes of
managing the user’s involvement in the particular community space. Moderators
must not use this personal information in any other way. They should not reveal this
information to anyone except where expressly authorised or required to do so by the
ABC or where required under law.
Some ABC sites may require that users do not use their real name. On other ABC
sites audience members are able to participate using either their real name or a
nickname or pseudonym. This decision is made by the relevant editorial manager
and requirements or restrictions would generally be indicated via the House Rules
and the Moderation Plan.
Current ABC practice is generally not to reveal the identity of the moderator for
privacy and security reasons. Records should be kept to enable editorial managers
to identify who was responsible for moderation at a particular time. However this
information should generally not be made publicly available.
e. Staff comments and contributions
Program staff and contributors may post responses to audience comments and
questions. It would be appropriate for them to be clearly identified as ABC staff
associated with the content under discussion. Alternatively it may be appropriate for
a moderator to post such a response on behalf of a contributor, program maker or
program. The same criteria outlined in the Conditions of Use apply to all these
contributions. Staff responding and participating in ABC community spaces on behalf
of ABC programs or websites would be expected to identify their connection with the
program.
ABC staff are welcome to participate on ABC community spaces as private users but
they should observe the principles developed to guide ABC staff in their use of social
media (see the Use of Social Media Policy at http://myabc/en/Working-at-theABC/~/media/Documents/Policies/EditorialPolicies/SocialMediaPOLpdf.ashx).
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f.
Security
Any threats of violence, self-harm or harm to other people or property or other
security issues must be referred to the ABC Security Manager (02 8333 1640 or
abc.security@abc.net.au) as well as upward referred to the relevant Editorial
Manager. In the event that a threat appears to be insincere or a hoax, the matter
must be referred as if it were genuine. Moderators on third-party sites should also
refer such threats to the ABC Security Manager.
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Moderators should keep dated and signed file notes of any serious security incident
associated with the moderation of ABC community spaces.
g. Complaints
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The ABC’s complaints handling system recognises that the changing media
environment provides audiences more options. They can engage with the ABC and
each other via the ABC’s forums, comment threads and using other interactive
spaces. Commenting online is potentially a quick and informal alternative to making
a formal complaint. ABC online spaces should be moderated in ways to facilitate this.
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Moderators must be familiar with the ABC’s complaints handling procedures and
know how to handle correctly any complaints or other direct audience contacts
regarding moderation.
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If a post or submission asserts a serious editorial breach, a moderator should
consider reviewing the incident and if necessary referring this on to the relevant
program area and informing the contributor how they may make a complaint to
Audience and Consumer Affairs.
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4. Moderating ABC Presences on Third-Party Sites
The ABC creates official presences on third-party sites, including social media to
engage with audiences online. Where such accounts are official ABC accounts, it
should be clear to users that they are interacting with a page, channel or other
presence that is maintained by the ABC. Branding is important. If you are creating or
have established an official ABC social media account you must follow the ABC
Branding Guidelines, which you can find on the Social Media Wiki.
There are also presences on third-party sites that use or reference ABC content that
are not official ABC accounts. These accounts may be managed wholly by coproduction partners, distributors, broadcast partners or fans, or a combination of
these groups. Aside from the power to protect its intellectual property rights, the
ABC has limited control over the establishment of these sites, and may have little or
no control over their management. Even so, it is important to exercise a duty of care
over our content and audiences, even if they are not being managed by staff.
Therefore the ABC should request these accounts clarify who has responsibility for
the sites wherever practicable. For example, information can be posted such as
‘[Name of production company] is responsible for the content of this site’. Such
information should include a web or email address where audiences can direct
comments or complaints if required.
There are also instances where an account might be managed by the ABC and a
combination of the above, in which case these accounts should be treated as official
ABC accounts. Thought should be given to who maintains the accounts if the ABC
no longer has the rights to the content, an arrangement most common in television.
Before the ABC uploads its content to a third-party site, or invites users to upload
content to a third-party site, the ABC must give consideration to the site’s terms and
conditions and whether there is a need to address legal and rights issues. ABC Legal
and the ABC’s Rights Management unit should be consulted as appropriate, and if it
relates to social media, your Divisional Social Media Representative.
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As social media and other forms of user interactivity are evolving, the ABC needs to
take a flexible approach to assessing when and how it intervenes. The approach
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adopted by the ABC in each case should be sensitive to the expectations, customs
and conventions of existing users of the third-party site, and to the ABC’s need to
maintain its own reputation as an innovator with integrity.
In considering how to handle particular circumstances it can be helpful to refer back
to the Principles in section 9 of the Editorial Policies, especially the reference to
editorial responsibility being proportionate to the level of control.
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Related material
ABC Conditions of Use (http://abc.net.au/conditions.htm)
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ABC Online Privacy Policy (http://www.abc.net.au/privacy.htm)
ABC Shop Online Privacy Policy (https://shop.abc.net.au/pages/privacy-policy)
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Examples of House Rules:
ABC News http://www.abc.net.au/news/help/house-rules/
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ABC3 http://www.abc.net.au/abc3/about/houserules.htm
ABC – about the ABC http://about.abc.net.au/house-rules/
Radio http://www.abc.net.au/radio/faq/house-rules.htm
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ABC Privacy Policy (http://myabc/en/Working-at-theABC/~/media/Documents/Policies/PrivacyPOLpdf.ashx)
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Protective Security Policy (http://myabc/en/Working-at-theABC/~/media/Documents/Policies/BusinessServices/ProtectiveSecurityPOLpdf.ashx)
IT security Policy
(http://myabc/Divisions/Technology/~/media/Documents/Policies/Technology/Techno
logySecurityPOLpdf.ashx)
Operating Official ABC Social media Accounts
http://about.abc.net.au/wp-content/uploads/2013/10/GNOfficialSocialMediaINS.pdf
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Status of Guidance Note
This Guidance Note, authorised by the Managing Director, is provided to assist
interpretation of the Editorial Policies to which the Guidance Note relates. The
Editorial Policies contain the standards enforceable under the ABC’s internal
management processes and under the ABC’s complaints handling procedures.
It is expected the advice contained in Guidance Notes will normally be followed. In a
given situation there may be good reasons to depart from the advice. This is
permissible so long as the standards of the Editorial Policies are met. In such
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situations, the matter should ordinarily be referred upwards. Any mandatory referrals
specified in Guidance Notes must be complied with.
Key Editorial Standards
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Excerpts of key editorial standards relevant to this Guidance Note are set out below.
Other editorial standards such as 1.2, 1.4, 2.1, 2.2, 4.3, 4.4, 4.5, 7.7 and 12.1 dealing
with ABC independence, accuracy, impartiality, harm and offence and commercial
references may also be relevant, depending on the specific circumstances applying
in each case.
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Public access and participation
9.1 Free broadcast time or publication space may be provided to enable individuals
or organisations to communicate directly with the ABC, the audience and each
other, provided that:
a the content is broadcast or published as a public service;
b the content is relevant and suitable in the context in which it appears;
c the ABC maintains editorial control; and
d ABC independence and integrity are maintained.
9.2 Opportunities to participate must be administered fairly and respectfully.
9.3 Do not knowingly mislead audiences about the nature of the content.
9.4 Clearly distinguish content generated and submitted to the ABC from content
produced, commissioned or acquired by the ABC.
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9.5 Do not accept money or other benefit in exchange for broadcasting or
publishing the content generated through public access and participation.
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