- - Adapting terms of service (TOS) and community guidelines to prohibit certain content, activity and shape norms of behaviour. In general, companies have a zerotolerance policy for terrorist content and activity on their platforms and have committed to ensuring the safety of their users. In light of the challenges in determining who terrorist actors actually are, some companies use international, regional or national sanctions lists to guide their decision-making on this issue.4 Developing guidance and systems (human and automated) for content flagging, referral and content/ account removal and for remedial action. Establishing guidance and systems for responding to law enforcement and government content/ account removal or data access requests. Establishing transparency measures for government requests. Establishing, training and sustaining content policy and legal teams. Cooperating with government or regional internet referral units (IRUs), when required. Developing tools and mechanisms (both human and automated) to counter the narratives of terrorist and violent extremist groups and their followers, carried out in conjunction with government agencies and/ or civil society and community organizations. The technology sector sometimes refers to the importance of failing fast – learning from real world experience and adapting in near real-time. There will clearly be situations where errors are made, especially given the complexity of implementing policy in this area, and the sheer scale of data involved on a daily basis. In the same way, there will be takedown requests that are impractical, inappropriate, or politically partisan. Undoubtedly, some practices - notably restricting content, account removal, providing access to user data, or engaging in online social engineering practices - continue to raise important normative, ethical and legal questions and, in some instances, implicate the legitimacy, transparency and accountability of those same private actors that are key to building and consolidating trust online. Hard data in the battle against terrorist use of the internet are elusive. Hence, measuring overall impact of private sector (and often also public sector) efforts to counter-terrorism efforts remains challenging since the evidentiary basis linking such actions to broader prevention strategies remains weak. This is also the case with online counter-speech or counter-narrative efforts.5 4 For instance, Microsoft recently announced that it “will consider terrorist content to be material posted by or in support of organizations included on the Consolidated United Nations Security Council Sanctions List that depicts graphic violence, encourages violent action, endorses a terrorist organization or its acts, or encourages people to join such groups”. See ‘Microsoft’s approach to terrorist content online’. http://blogs.microsoft.com/on-the-issues/2016/05/20/microsofts-approach-terrorist-contentonline/#sm.00008cf0g1gyufreset139jj0nsg1. For the UN SC Consolidated Sanctions List, see: https://www.un.org/sc/suborg/en/sanctions/un-sc-consolidated-list 5 See, for example, the work of the Global Forum for Media Development on this subject. Available at: http://gfmd.info/en/site/news/957/GFMD-Workshop-“Mediadev-CVE--counter-propaganda-Where-is-the-problem”-Brussels- Press-Club26-April-2016.htm. See also: Radsch, C (2016), Media Development and Countering Violent Extremism: An Uneasy Relationship, a Need for Dialogue. Cima/ NED publication. http://www.cima.ned.org/wp-content/uploads/2016/10/CIMA-CVE-Paper_web-150ppi.pdf; Ferguson, Kate (2016) Countering violent extremism through media and communication strategies: A review of the evidence http://www.paccsresearch.org.uk/wp-content/uploads/2016/03/Countering-Violent-Extremism-Through-Media-and-CommunicationStrategies-.pdf; SDI (2016) Impact of Counter Narratives Online, ISD http://www.strategicdialogue.org/wpcontent/uploads/2016/08/Impact-of-Counter-Narratives_ONLINE.pdf 6