欧盟
2023 年 7 月 1 日 – 2023 年 12 月 31 日

发布时间:

2024 年 4 月 25 日

更新时间:

2024 年 4 月 25 日

欢迎访问我们的欧盟 (EU) 透明度页面,我们在此发布《数字服务法案》(DSA)、《视听媒体服务指令》(AVMSD) 和《荷兰媒体法案》(DMA) 所要求的欧盟特定信息。请注意,这些透明度报告的最新版本可以在 en-US 区域中找到。

法定代表人 

Snap Group Limited 已指定 Snap B.V. 作为其 DSA 法定代表人。 您可以在我们的支持网站[此处]或以下位置,通过 dsa-enquiries@snapchat.com 联系 DSA 代表,通过 vsp-enquiries@snapchat.com 联系 AVMSD 和 DMA 的代表:

Snap B.V.
Keizersgracht 165, 1016 DP
Amsterdam, The Netherlands

如果您是执法机构,请遵循 此处概述的步骤。联系我们时,请使用荷兰语或英语交流。

监管机构

关于 DSA,我们受欧盟委员会和荷兰消费者和市场管理局 (ACM) 监管。关于 AVMSD 和 DMA,我们受荷兰媒体管理局 (CvdM) 监管。

DSA 透明度报告

DSA 第 15、24 和 42 条要求 Snap 发布报告,其中应包含有关 Snap 对 Snapchat 服务(视为“在线平台”)(即 Spotlight、 为您推荐、公众号、地图、特效镜头和广告)的内容审核的规定信息。自 2023 年 10 月 25 日起,该报告必须每 6 个月发布一次。

Snap 每年发布两次透明度报告,深入介绍 Snap 的安全工作以及我们平台上所举报内容的性质和数量。 我们 2023 年下半年(7 月 1 日至 12 月 31 日)的最新报告可点击 此处查看。 《数字服务法案》的特定指标可在此页面上找到。

平均月度活跃接收用户 
(DSA 第 24.2 和 42.3 条)

截止 2023 年 12 月 31 日,我们的 Snapchat 应用程序在欧盟的平均月度活跃接收用户达 9090 万。这意味着,在过去 6 个月中,平均有 9090 万欧盟注册用户在指定月份内至少打开过一次 Snapchat 应用程序。

This figure breaks down by Member State as follows:

These figures were calculated to meet current DSA rules and should only be relied on for DSA purposes. We have changed how we calculate this figure over time, including in response to changing internal policy, regulator guidance and technology, and figures are not intended to be compared between periods. This may also differ from the calculations used for other active user figures we publish for other purposes.


Member States Authority Requests
(DSA Article 15.1(a))

Takedown Requests 

During this period, we have received 0 takedown requests from EU member states pursuant to DSA Article 9. 

Information Requests 

During this period, we have received the following information requests from EU member states:

The median turnaround time to inform authorities of receipt of Information Requests is 0 minutes — we provide an automated response confirming receipt. The median turnaround time to give effect to Information Requests is ~10 days. This metric reflects the time period from when Snap receives an IR to when Snap believes the request is fully resolved. In some cases, the length of this process depends in part on the speed with which law enforcement responds to any requests for clarification from Snap necessary to process their request.

Content Moderation 


All content on Snapchat must adhere to our Community Guidelines and Terms of Service, as well as supporting terms, guidelines and explainers. Proactive detection mechanisms and reports of illegal or violating content or accounts prompt a review, at which point, our tooling systems process the request, gather relevant metadata, and route the relevant content to our moderation team via a structured user interface that is designed to facilitate effective and efficient review operations. When our moderation teams determine, either through human review or automated means, that a user has violated our Terms, we may remove the offending content or account, terminate or limit the visibility of the relevant account, and/or notify law enforcement as explained in our Snapchat Moderation, Enforcement, and Appeals Explainer.  Users whose accounts are locked by our safety team for Community Guidelines violations can submit a locked account appeal, and users can appeal certain content enforcements.

Content and Account Notices (DSA Article 15.1(b))

Snap has put into place mechanisms to allow users and non-users to notify Snap of content and accounts violating our Community Guidelines and Terms of Service on the platform, including those they consider illegal pursuant to DSA Article 16.  These reporting mechanisms are available in the app itself (i.e. directly from the piece of content) and on our website.

During the relevant period, we received the following content and account notices in the EU:

In H2’23, we handled 664,896 notices solely via automated means. All of these were enforced against our Community Guidelines because our Community Guidelines encapsulate illegal content. 

In addition to user-generated content and accounts, we moderate advertisements if they violate our platform policies. Below are the total ads that were reported and removed in the EU. 

Trusted Flaggers Notices (Article 15.1(b))

For the period of our latest Transparency Report (H2 2023), there were no formally appointed Trusted Flaggers under the DSA. As a result, the number of notices submitted by such Trusted Flaggers was zero (0) in this period.

Proactive Content Moderation (Article 15.1(c))

During the relevant period, Snap enforced the following content and accounts in the EU after engaging content moderation at its own initiative:

All of Snap’s own-initiative moderation efforts leveraged humans or automation. On our public content surfaces, content generally goes through both auto-moderation and human review before it is eligible for distribution to a wide audience. With regards to automated tools, these include:

  • Proactive detection of illegal and violating content using machine learning;

  • Hash-matching tools (such as PhotoDNA and Google's CSAI Match);

  • Abusive Language Detection to reject content based on an identified and regularly updated list of abusive key words, including emojis


Appeals (Article 15.1(d))

During the relevant period, Snap processed the following content and account appeals in the EU via its internal complaint-handling systems:


* 阻止对儿童进行性剥削是当务之急。 Snap 为此投入了大量资源,并对此类行为采取零容忍态度。  审核 CSE 申诉需要特殊培训,而且由于其内容的图像性质,只有有限的代理人团队处理这些审核。  2023 年秋季期间,Snap 实施了影响某些 CSE 执法的一致性的政策更改,我们通过代理人再培训和严格的质量保证,解决了这些不一致问题。  我们预计下一份透明度报告,将展示在缩短 CSE 申诉响应时间和提高初始执法精度方面取得的进展。 

用于内容审核的自动化途径(第 15.1(e) 条)

在我们的公开内容层面上,内容通常会经过自动审核和人工审核,然后才有资格分发给广大受众。关于自动化工具,这些工具包括:

  • 使用机器学习,主动检测非法和违规内容;

  • 散列匹配工具(如 PhotoDNA 和 Google 的 CSAI Match);

  • 辱骂性语言检测,可以根据已识别并定期更新的辱骂性关键词(包括表情符号)列表,拒绝内容。


自动审核技术处理所有危害的准确率约为 96.61%,错误率约为 3.39%。


内容审核保障措施(第 15.1(e)条))

我们承认内容审核存在风险,包括言论和集会自由的风险,这些风险可能是由自动化和人工审核偏见以及包括政府、政治选区,或组织有序的个人在内的滥用报告引发的。 Snapchat 通常不是发布政治或激进内容的地方,特别是在我们的公共空间中。 


尽管如此,为了防范这些风险,Snap 进行了适当的测试和培训,并制定了强大、一致的程序来处理非法或违规内容的报告,包括来自执法部门和政府当局的报告。 我们不断评估和改进我们的内容审核算法。 虽然很难检测到对言论自由的潜在危害,但我们没发现任何重大问题,并且我们为用户提供报告错误的途径(如果发生错误)。 


我们的政策和系统促进一致和公平的执法,如上所述,为 Snapchatter 提供机会,通过通知和申诉流程对执法结果提出有意义地争议,该流程旨在维护我们社区的利益,同时保护 Snapchatter 个人权利。

我们不断努力改进我们的执法政策和流程,并在 Snapchat 上打击潜在有害和非法内容和活动方面取得了长足进展。 这反映在我们最新的透明度报告所显示的举报和执法数字的上升趋势中,以及 Snapchat 上违规行为发生率的总体下降中。


庭外和解(第 24.1(a)条)

在我们最新的透明度报告(2023 年下半年)期间,不存在根据 DSA 正式任命的庭外争议解决机构。 因此,在此期间提交给此类机构的争议数量为零(0),我们无法提供结果、和解的中位数周转时间以及我们执行该机构决定的争议份额。 



帐户暂停(第 24.1(b)条)

在 2023 年下半年,我们没有任何根据第 23 条强制实施的帐户暂停。Snap 的信任与安全团队已制定适当的程序,以限制用户帐户频繁提交明显缺乏根据的通知或投诉的可能性。 这些程序包括限制重复的报告创建和使用电子邮件过滤器,以阻止经常提交明显缺乏根据的报告的用户继续这样做。 Snap 对帐户采取适当的执法行动,正如 Snapchat 审核、执法和申诉说明中所解释的那样,有关 Snap 帐户执法级别的信息,请参阅我们的透明度报告(2023 年下半年)。 此类措施将继续进行审核和迭代。


审核员资源、专业知识和支持(第 42.2 条)

我们的内容审核团队遍布全球,全天候帮助保障 Snapchat 用户的安全。下面是人工审核资源按审核员的语言专业分类的细目(请注意,有些审核员擅长多种语言)(截至 2023 年 12 月 31 日):

The above table includes all moderators who support EU member state languages as of December 31, 2023. In situations where we need additional language support, we use translation services.

Moderators are recruited using a standard job description that includes a language requirement (depending on the need). The language requirement states that the candidate should be able to demonstrate written and spoken fluency in the language and have at least one year of  work experience for entry-level positions. Candidates must meet the educational and background requirements in order to be considered. Candidates also must demonstrate an understanding of current events for the country or region of content moderation they will support.

Our moderation team applies our policies and enforcement measures to help protect our Snapchat community. Training is conducted over a multi-week period, in which new team members are educated on Snap’s policies, tools, and escalations procedures. After the training, each moderator must pass a certification exam before being permitted to review content. Our moderation team regularly participates in refresher training relevant to their workflows, particularly when we encounter policy-borderline and context-dependent cases. We also run upskilling programs, certification sessions, and quizzes to ensure all moderators are current and in compliance with all updated policies. Finally, when urgent content trends surface based on current events, we quickly disseminate policy clarifications so teams are able to respond according to Snap’s policies.

We provide our content moderation team – Snap’s “digital first responders” – with significant support and resources, including on-the-job wellness support and easy access to mental health services. 

Child Sexual Exploitation and Abuse (CSEA) Media Scanning Report


Background

The sexual exploitation of any member of our community, especially minors, is illegal, abhorrent, and prohibited by our Community Guidelines. Preventing, detecting, and eradicating Child Sexual Exploitation and Abuse (CSEA) on our platform is a top priority for Snap, and we continually evolve our capabilities to combat these and other crimes.


We use PhotoDNA robust hash-matching and Google’s Child Sexual Abuse Imagery (CSAI) Match to identify known illegal images and videos of child sexual abuse, respectively, and report them to the U.S. National Center for Missing and Exploited Children (NCMEC), as required by law. NCMEC then, in turn, coordinates with domestic or international law enforcement, as required.


Report

The below data is based on the result of proactive scanning using PhotoDNA and/or CSAI Match of media uploaded by a user’s camera roll to Snapchat.

Stopping child sexual exploitation is a top priority. Snap devotes significant resources toward this and has zero tolerance for such conduct.  Special training is required to review CSE appeals, and there is a limited team of agents who handle these reviews due to the graphic nature of the content.  During the fall of 2023, Snap implemented policy changes that affected the consistency of certain CSE enforcements, and we have addressed these inconsistencies through agent re-training and rigorous quality assurance.  We expect that the next transparency report will reveal progress toward improving response times for CSE appeals and improving the precision of initial enforcements.  

Content Moderation Safeguards

The safeguards applied for CSEA Media Scanning are set out in the above “Content Moderation Safeguards” section under our DSA Report.


European Union Terrorist Content Online Transparency Report

Published: June 17, 2024

Last Updated: June 17, 2024

This Transparency Report is published in accordance with Articles 7(2) and 7(3) of Regulation 2021/784 of the European Parliament and of the Council of the EU, addressing the dissemination of terrorist content online (the Regulation). It covers the reporting period of January 1 - December 31, 2023


General Information
  • Article 7(3)(a): information about the hosting service provider’s measures in relation to the identification and removal of or disabling of access to terrorist content

  • Article 7(3)(b): information about the hosting service provider’s measures to address the reappearance online of material which has previously been removed or to which access has been disabled because it was considered to be terrorist content, in particular where automated tools have been used


Terrorists, terrorist organizations, and violent extremists are prohibited from using Snapchat. Content that advocates, promotes, glorifies, or advances terrorism or other violent, criminal acts is prohibited under our Community Guidelines. Users are able to report content that violates our Community Guidelines via our in-app reporting menu and our Support Site. We also use proactive detection to attempt to identify violative content on public surfaces like ​​Spotlight and Discover. 


Regardless as to how we may become aware of violating content, our Trust & Safety teams, through a combination of automation and human moderation, promptly review identified content and make enforcement decisions. Enforcements may include removing the content, warning or locking the violating account, and, if warranted, reporting the account to law enforcement. To prevent the reappearance of terrorist or other violent extremist content on Snapchat, in addition to working with law enforcement, we take steps to block the device associated with the violating account and prevent the user from creating another Snapchat account. 


Additional details regarding our measures for identifying and removing terrorist content can be found in our Explainer on Hateful Content, Terrorism, and Violent Extremism and our Explainer on Moderation, Enforcement, and Appeals



Reports & Enforcements 
  • Article 7(3)(c): the number of items of terrorist content removed or to which access has been disabled following removal orders or specific measures, and the number of removal orders where the content has not been removed or access to which has not been disabled pursuant to the first subparagraph of Article 3(7) and the first subparagraph of Article 3(8), together with the grounds therefor


During the reporting period, Snap did not receive any removal orders, nor were we required to implement any specific measures pursuant to Article 5 of the Regulation. Accordingly, we were not required to take enforcement action under the Regulation.


The following table describes enforcement actions taken based on user reports and proactive detection against content and accounts, both in the EU and elsewhere around the world, that violated our Community Guidelines relating to terrorism and violent extremism content

Enforcement Appeals
  • Article 7(3)(d): the number and the outcome of complaints handled by the hosting service provider in accordance with Article 10

  • Article 7(3)(g): the number of cases in which the hosting service provider reinstated content or access thereto following a complaint by the content provider


Because we had no enforcement actions required under the Regulation during the reporting period as noted above, we handled no complaints pursuant to Article 10 of the Regulation and had no associated reinstatements.


The following table contains information relating to appeals and reinstatements, both in the EU and elsewhere around the world, involving terrorist and violent extremist content enforced under our Community Guidelines.

Judicial Proceedings & Appeals
  • Article 7(3)(e): the number and the outcome of administrative or judicial review proceedings brought by the hosting service provider

  • Article 7(3)(f): the number of cases in which the hosting service provider was required to reinstate content or access thereto as a result of administrative or judicial review proceedings


As we had no enforcement actions required under the Regulation during the reporting period, as noted above, we had no associated administrative or judicial review proceedings, and we were not required to reinstate content as a result of any such proceedings.

EU DSA: Average Monthly Active Recipients (August 2024)
(DSA Articles 24.2 and 42.3)

As of 1 August 2024, we have 92.4 million average monthly active recipients (“AMAR”) of our Snapchat app in the EU. This means that, on average over the last 6 months, 92.4 million registered users in the EU have opened the Snapchat app at least once during a given month.

This figure breaks down by Member State as follows: