Release document for OIA 2022 23 0648.pdf

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While our expert teams pay attention to the nuance of our enforcement, we
also run databases of keywords associated with violent extremism and hate,
which disallow users from searching for particular terms. Similarly, we maintain
databases of signs, symbols and images related to violent extremism,
dangerous organisations and hateful ideologies to ensure content containing it
is disallowed, blocked from upload or removed. TikTok continuously reviews
entities that are know to participate in hateful behaviour, violent extremism ,  1982
and criminal activities. These identified groups are not able to join our platform
and action would be taken against any such accounts. Additionally, TikTok has
commercial partners that monitor and gather intelligence on violent extremist
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content and provide threat alerts on credible threats. We have access to
databases that include more than 7,000 archived audio/video files and 200,000
URLs published/shared by designated extremist groups. We use this
intelligence to improve our detection and proactive risk mitigation.

These are some of the ways that TikTok is already deploying technical solutions
and product changes that make our platform experience a safer one for users.
We will continue to innovate in this space, and look forward to working with
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the Coalition to identify opportunities to enhance protections.

We know there is no finish line when it comes to further improving safety on
TikTok and our transparency reports show that we removed 2,712,492 pieces
of content that violated our Community Guidelines relating to violent extremism
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in 2021.

2. Referring to the Call to Action, what commitments has TikTok
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already addressed or taken measures to address?

Through TikTok's publicly available Community Guidelines and Terms of
Service, our platform clearly articulates and enforces policies to support the Cal
to Action commitments.
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Violent extremism, dangerous organisations and hateful ideologies are explicitly
designated in our Community Guidelines as being prohibited on our platform.
And our Community Guidelines Enforcement Reports are regularly updated to
provide information on the types of content we remove, at what volume, and
what stage of moderation. Our most recent update is available here.

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As described in the answer above, we use a mixture of machine and human
moderation to detect, remove and take enforcement action as appropriate
when violative content is detected on TikTok. Specifically, TikTok has a clear
policy of removing violent extremism content. We reject any form of violent

content or content that seeks to glorify groups and/or individuals associated
with violent extremism from using our platform to advance their violent
extremism propaganda.

We will terminate accounts and may also ban users from coming back to our
platform if they have posted content that glorifies and promotes violence.

While we take decisive action against violative content and accounts, we also
ensure we notify our users of the actions taken and provide an avenue to  1982
appeal, consistent with transparent, best practice.

In late 2021, we provided an update on work we are doing regarding our
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recommendation system, to keep people's "For You Feed" fresh and to interrupt
repetitive patterns to foster diversity of content. Further details are available
here, and it builds on our previously provided overview of how our
recommendation system works, which is available here.

TikTok has a network of Transparency and Accountability Centres, that provide
outside experts an opportunity to directly view how our teams at TikTok go
about the day-to-day challenging, but critically important, work of moderating
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content on the platform, our privacy policies and other important practices. We
would be pleased to welcome representatives of the Christchurch Cal  an
opportunity to participate in a tour of our Transparency and Accountability
Centre.

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TikTok also works with industry experts, non-governmental organisations, and
industry associations throughout our safety policy and feature development
process to monitor emerging trends, identify blindspots or gaps in our
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knowledge, and generate innovative solutions for building the safest possible
platform for our community.

It's worth noting that TikTok currently participates in three of the Global
Internet Forum to Counter Terrorism's (GIFCT) working groups, in order to
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learn from and contribute to industry best practices. These working groups are:
Transparency, Crisis Response, and Positive Interventions and Strategic
Communications. TikTok continues to actively work toward gaining
membership in GIFCT and recently completed the GIFCT-Tech Against
Terrorism mentorship program.

3. How does TikTok intend to contribute to and participate in the
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Christchurch Call Community?

TikTok's top priority is safety for our community. We know there is no finish
line when it comes to keeping our users safe and we are committed to working

col aboratively with our industry peers to ensure we are playing a proactive and
meaningful role globally to support shared safety goals.

TikTok is committed to sharing information that will support the identification
and suppression of terrorist and violent extremist content. We do so already
through global and regional initiatives, including:
x  MHA-RSIS Webinar on "Countering Extremist Content: Promoting
Positive Narratives Online" - an engagement to combat extremism online  1982
with the Singapore Government's Home Affairs Ministry and a local
think-tank.
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  Collaboration with UNDP to empower content creators in APAC to build
a safe online space
Our intention is to continue this collaborative and open engagement through
the Christchurch Call community and we are open to more detailed discussions
around how we can most meaningfully support achieving the Christchurch Call's
objectives.

4. Could you please describe TikTok’s ownership structure? What is
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the nature of the relationship between ByteDance and Beijing
ByteDance Technology (noting the Chinese Government’s recent
acquisition of a 1% stake in the latter)? a. Does this investment allow
for a board seat in Beijing ByteDance Technology? How does this
relate to TikTok’s operations?

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TikTok Ltd is owned by Bytedance Ltd, a privately owned technology company
incorporated in the Cayman Islands, and the majority investors include
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Bytdance and TikTok founder, Yiming Zhang and large institutional investors
such as Sequoia Capital, General Atlantic, KKR and Softbank. We have a global
board of directors.

TikTok’s CEO is based in Singapore, and we have a diverse leadership team,
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many of which are based in the United States. The TikTok app is available in
more than 150 countries, but not in China.

The Chinese Government has not taken an ownership stake in TikTok.

The subsidiary referenced has no ownership, visibility, or input into TikTok’s
operations.
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There are no TikTok companies incorporated in China.

In summary, there is nothing about TikTok's ownership structure which would
limit our commitment to participate in the Christchurch Call.

5. What assurances can TikTok give about its data protections and the
independence of its content moderation processes?

New Zealand user data is stored in the US and Singapore. As indeed is the data
of all TikTok users, worldwide.

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We have strict access controls in place - including restrictions on who has
access to which data set, strong authentication measures, logging of access,
limited access period, and encryption of data. We employ thousands of safety
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professionals around the world to ensure we have 24/7 coverage of content on
TikTok.

Our moderation teams that review New Zealand content (for example) are
based in Europe and SE Asia and provide coverage on a 24/7 basis. This team
is supervised by dedicated experts in policy and enforcement who write the
content moderation guidelines and leads practice - they are based in our
regional Trust & Safety hubs in Singapore, Dublin, and California and include
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specialists who are familiar with our local culture and norms.

We moderate content according to our Community Guidelines and local laws,
our moderation teams are empowered to make decisions that suit the local
market.
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6. Noting ByteDance products in China, such as Douyin, are subject
to regulatory frameworks and privacy regimes there, to what extent
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is TikTok also subject to these and/or, as a subsidiary of ByteDance,
has the potential to be subject to these?

TikTok is not available in China and we are a global company. We have not and
will not share user data with the Chinese Government, and would not do so if
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asked.

Any legal requests by any Government for TikTok user data would be sent to
our Law Enforcement Response Team (LERT) and would follow a well
established international process. Such requests would need to go through the
relevant Mutual Legal Assistance Treaty (MLAT) process.

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As is made publicly available in our regularly published Transparency and
Accountability reports, the Chinese Government has not requested or asked for
TikTok user data. We have never given the Chinese Government TikTok user
data.

Our Trust and Safety Centres are located in Singapore, Ireland and the US; our
data storage facilities are in US and Singapore (which have achieved
international recognised security certifications), and we have strict controls on
who can access it.

We also have a dedicated US based Data Protection team focused on controls
implementation and monitoring of our protected sensitive data. and our Chief
Security Officer, Roland Cloutier, brings to TikTok over 30 years of experience  1982
in cyber security and law enforcement, including over a decade serving the
United States Air Force, Department of Defence and Department of Veterans
Affairs.
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We would welcome conveners of the Christchurch Call to participate in a
Transparency and Accountability Centre tour which will provide you an
opportunity to visit and see first-hand how teams at TikTok go about the
critically important work of securing our community's safety, data, and privacy.

7. How does TikTok approach the concept of a free, open and secure
internet? Does TikTok have policies and/oral public statement on how
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it respects and protects human rights and fundamental freedoms?

TikTok has progressed a range of partnerships and projects related to human
rights, including as a member of Business for Social Responsibility (BSR) and
TikTok has joined BSR's Human Rights Working Group. Together with BSR and
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Article 1 Advisors, we have held educational trainings for senior leadership on
the UN Guiding Principles on Business and Human Rights, and are committed
to respect human rights under the UNGP's Protect-Respect-Remedy framework.
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We have also publicly made a statement with respect to our approach to human
rights that is available on our website. It reads:

Technology is an essential gateway to the exercise of human rights. TikTok
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touches more than 1 billion people across the globe, who represent a variety
of ethnicities, orientations, backgrounds and life experiences. As a global
entertainment company, TikTok has a responsibility to ensure that our
community is treated.

Responsibility for upholding human rights is shared: while governments have
the responsibility to protect human rights, TikTok and other businesses have a
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responsibility to respect those human rights. Respecting human rights is
essential for TikTok to build and sustain trust among our employees, creators,
advertisers, and others who engage with our company.

Our philosophy is informed by the International Bill of Human Rights (which
includes the Universal Declaration of Human Rights and the International
Labour Organisation’s Declaration on Fundamental Principles and Rights at
Work) and the United Nations Guiding Principles on Business and Human
Rights. As part of our commitment, we will strive to respect human rights
throughout our business and will comply with applicable laws and regulations
intended to promote human rights where we conduct business globally. We will
continuously evaluate our operations to identify, assess, and address salient
human rights risks; engage key stakeholders; and prioritise key areas where  1982
we have the greatest opportunity to have a positive impact.

8. What is TikTok doing to improve transparency of the platform?
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As articulated in our answer to Question 2 above, at TikTok we recognise that
accountability and transparency are essential to facilitating trust, and we are
committed to being transparent in how we operate, moderate and recommend
content, and secure our platform. In early 2020 TikTok launched its first
Transparency Report. As part of that work, we provide regular updates on
reports received across different violation types, the frequency of those reports,
and how much of that content we act on for violating our Community
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Guidelines. We also disclose the percentages of content we take action on
proactively, through automation and detection models that enqueue content
for human moderation.

As mentioned, TikTok has also opened Transparency and Accountability
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Centres for experts and policymakers to see first-hand how we are working to
build a safe and secure platform for our growing and diverse community. Due
to physical constraints around the ongoing COVID-19 pandemic, opening the
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centre has meant evolving our original plans to offer a virtual experience until
we can welcome guests to the full tour at our physical locations.

Moving forward, we endeavour to lead the industry in transparency including
through robust transparency reporting as well as additional experiences at the
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Transparency and Accountability Centres, including opportunities for qualified
experts to review our algorithm.

We are also very upfront about our platform's policies, including our Terms of
Service and our Community Guidelines. Everyone who uses TikTok is bound by
our Terms of Service, and our Community Guidelines apply universally. We take
a firm stance on behaviours and content which are not in keeping with our
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policies, and we will not hesitate to take action against accounts that might
seek to undermine the safety of our community.

When users make reports about particular content, we notify them of the
outcome of that report. For TikTok users whose content has been removed or
account has terminated, we notify them with information on why the action
was taken, and they will be allowed to submit an appeal should they feel the
removal decision was unjustified.

9. How does TikTok moderate live content for TVEC?

At TikTok, we use a number of measures to identify and moderate TVEC,  1982
including through automated detection.

Specifically, we have multiple models that detect content that overlaps with
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Violent Extremism (VE) signals, for example (but not limited to), we have
model(s) that detects blood in the frame and another that detects sensitive
military or police clothing. If our models are hit with a positive match, it will be
automatically sent to the moderation queue where human moderators will
assess the content for possible violations.

We also have a dedicated high risk detection database, which scans through
high risk content (such as footage from previous Violent Extremism attacks)
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that will automatically detects and remove this content.

Regarding our moderation practices, our moderators are trained on integrated
policies including being able to detect violent extremist signals and enforce
against them.
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We also have a number of dedicated teams that help moderate live content for
TVEC including:
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x  a dedicated Emergency Response Team that work with law-enforcement
to tackle the use of VE actors on the platform;
x  an Incident Management Team that handles major VE events from an
operational perspective and collaborates closely with our policy team;
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x  a Risk Analysis Team that proactively detects possible threats to the
platform for teams to prepare against.
Our global policy team has global and regional experts focusing on violent
extremism, hateful organisations and ideologies, including policy experts
dedicated to livestreams.

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Our Trust and Safety teams pay special attention to livestreams, taking into
consideration the unique nature of this feature, including but not limited to the
simultaneity between creation and consumption of content, the interaction
between viewers and hosts, existing or past strikes against user accounts. Our

policies and safety strategies are continuously reviewed and updated: they are
influenced and shaped by real-life events and feedback from experts. As violent
extremist events occur around the world, we work to proactively draft policies
that are able to scale and adapt to novel concepts.

10. How does TikTok prevent recommending TVEC or harmful
content? How does TikTok assess and moderate algorithmic
recommendation processes?

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As previously described, we use a mix of technology and human moderation to
enforce our Community Guidelines (which includes controlling TVEC or harmful
content), which is also informed by in-app user reporting (and non-users via
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website), where users have an option to easily report potentially violative
content.

All content uploaded to TikTok passes through technology that works to identify
potential policy violations. Our safety team takes additional precautions to
review videos as they rise in popularity to reduce the likelihood of content that
may not be appropriate for a general audience entering our recommendation
system.
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With regard to our recommendation system, we present users with a stream of
videos on our ‘For You’ feed curated to their interests, but also works to
intersperse recommendations that might fall outside people’s expressed
preferences, offering an opportunity to discover new categories of content.
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Our recommendation system on TikTok is designed with safety as a key
consideration. Reviewed content found to depict things like graphic medical
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procedures or legal consumption of regulated goods, for example - which may
be shocking if surfaced as a recommended video to a general audience that
hasn’t opted in to such content - may not be eligible for recommendation. Users
can also report a video that seems out of line with our guidelines. All these
actions contribute to future recommendations on the For You feed.
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Content along the lines of TVEC or harmful content in general will not be eligible
for recommendation under any circumstances and wil  be taken down from the
platform as they violate our Community Guidelines.

Ultimately, the For You feed is powered by user’s feedback: the system is
designed to continuously improve, correct, and learn from user’s engagement
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with the platform to produce personalised recommendations that we hope
inspire creativity and bring joy with every refresh of their For You feed.

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