Written evidence submitted by Facebook





May 12, 2021


Digital, Media, Culture, and Sport Committee

House of Commons, London, SW1A 0AA



The Facebook Company (“Facebook”) welcomes the opportunity to respond to the Digital, Culture, Media and Sport Select Committee’s inquiry into ‘Influencer culture’.

1.      Introduction


Facebook was built to help people stay connected. Our mission is to give people the power to build community and bring the world closer together. We’re committed to building technologies that enable the best of what people can do together. Our products empower more than 2 billion people around the world to keep in touch, share ideas, offer support and make a difference.


People use our products in multiple ways—over $1.8 billion was raised by our community to support the causes they care about in 2020 alone, over 100 billion messages are shared every day to help people stay close even when they are far apart, and over 1 billion stories are shared each day to help people express themselves and connect.


As a company we know that people want to connect with the people they love and the things they care about most – to be inspired across beauty, music, art, fashion and comedy. But the way we discover the things we love has changed thanks to social media. Our services not only connect people with friends and family but also their interests and the people behind them, no matter who they are or where they live.


More and more, people create and consume culture through the individuals they follow - their favorite artists, video creators, public figures, writers, and athletes. People follow not just their favorite team but also the star athletes on the team. Musicians now have ways to break out and get noticed. And people often buy from undiscovered, new and up and coming brands based on the creators who promote them. Creators set trends and signal what’s next.


This is an environment in which start-ups and small businesses thrive, particularly in the UK. Traditional advertising has often been dominated by larger companies who could buy the media space that was available (e.g. a prime-time TV commercial or print advert) and could partner with high profile individuals who were already nationally influential. Social media has transformed the commercial environment for small companies and start-ups - who can now enter a market and find customers with very little cost and a high return on investment - and creators in their chosen field who have new ways of building their own audiences and monetising their success.


We use the term creators rather than influencers and broadly they are people who publish creative and innovative content that people want to see, with the intention of growing their following and/or monetising their brand. Often their personality is part of their brand. And there are now millions of creators who rely on our apps to grow their community and build a business. This includes public figures, artists, musicians, writers, athletes, digital stars, campaigners and activists, comedians, beauty and fashion experts, gaming creators and more.

2.      Facebook and Creators


Facebook and Instagram are key platforms for people across the world to connect with their favorite creators - from video series on Watch to tutorials in Reels. Some of the strongest communities across our apps and services are built by creators using the tools we make available.


We are constantly innovating the tools we make available and the services we provide because we want to make it easy for creators to harness the support from their fans to grow their audience and build their business. And, conversely, we want to give their fans the ability to connect with and support their favorite creators in meaningful ways. We’ve built a range of tools to help support creators’ various needs and ambitions, whether they’re just getting started or already have an established brand. From Watch to Instagram Reels to Gaming and more, our apps and services give creators a way to connect with their fans, grow their communities and make a living.


While many creators have similar needs to those of businesses, there is a wide range of needs specific to creators. For instance, many creators produce content with the intention of monetizing it rather than selling a product or service. That’s why we’ve built products that allow creators to make money off of their content, such as In-Stream ads, fan subscriptions and Badges. Products like these support creators who may not have been well known before they joined social media and they give anyone the power to showcase their passions, build a following and, if they want to, become a small, medium or even large business owner. A few UK examples of how Creators are using some of the tools we make available include:


        @firefoodandsoul: Food blogger featured on the official Instagram @creator account here showing how she uses Reels in creative ways to engage her audience. 

        @sophia_rosemary: Renowned for her vintage inspired style and also the owner of vintage Instagram shop @topofthetownvintage (which uses Shops) where she shares carefully curated collections inspired by people, places, films and songs of eras gone by.

        @tillybuttons: Tilly Walnes creates easy-to-use sewing patterns, books and online workshops for the new wave of DIY dressmakers. She uses Instagram Shops and Guides.


Supporting those starting their career or business isn’t new to Facebook - in fact it is core to our business. This is particularly true in the UK which is a world leader in technology and in advertising. This ecosystem is driven by the relationship between large platforms and small businesses; between creators and their fans. Indeed the thriving and dynamic nature of the UK tech sector, the advanced digital advertising market and the UK’s thriving SME community are one of the reasons companies like Facebook are investing in the UK economy. Over 375 million users worldwide are connected to a UK business on Facebook, and over 2 million UK businesses have a presence on Facebook.


Some of our most recent tools and announcements have been focused on helping aspiring and emerging creators who may be earlier in their careers. For example last month we announced  a set of new audio creation tools so that anyone can create high-quality, creative audio clips and that you’ll soon be able to listen to podcasts directly on the Facebook app. We’ve also been working on new ways to help Creators and startups to grow through connecting creators' accounts with their brands' shopping accounts so you can shop from both. And we announced that we’re working on ways to better connect brands and creators in-app to open up more opportunities for creators earlier in their career.


The Committee has asked about the role of creators, not just with regards to advertising and the economy but in respect of their impact on society and culture. Given the scale and importance of the creator community - to almost every industry, passion, interest or hobby - there are few easy ways to quantify their value to our society, or their role in driving culture forward. Some of this is also global in nature; whether that’s campaigns for racial justice through movements like Black Lives Matter, or global campaigns on climate change driven by the youngest members of our community. However these are just some of the examples of how Creators in the UK are using our tools to build their audiences, create innovative content, monetise their work and campaign on issues they care about in ways that were not possible just a few years ago:


        Changing the face of disability. Oliver LamWatson Oliver was born with a disability that affects his left leg and was told he would spend his life on crutches. Proudly using the hashtag #ChangeTheFaceOfDisability. He documents how he has challenged his disability and is now a Team GB Wheelchair fencer. Oliver recently did a Ted Talk sharing his story and inspiring others to rise up when faced with life’s hurdles.


        Addressing child food poverty in the UK. Facebook and Instagram partnered with Marcus Rashford and Tom Kerridge to produce “Full Time Meals”, a campaign to battle child food poverty in the UK. With content across Reels, IGTV, Stories, FB Watch, Groups and more, this is a year long series of recipes and tutorials to help some of the country’s most vulnerable families feed their children. People will be able to buy the ingredients in food boxes as well as receiving the recipe card, with an ongoing partnership with UK supermarkets.


        Campaigning to improve mental health. Dr Alex George Ex Love Island Contestant and Doctor, Dr Alex George is a mental health campaigner who played an integral role in spreading awareness and education around Coronavirus to his predominantly teen audience. He now uses his community to have positive open conversations about Mental Health and has just embarked on a role as UK Mental Health Ambassador.   


        Changing societal perceptions on body image. Stephanieyeboah is a high-profile body image and self-love advocate and author of ‘Fattily Ever After’, who we have featured on the @instagram account. This month Instagram also partnered with CALM on an initiative to combat male body confidence issues. With research showing that 58% (of 2000 men aged 16-40) have felt negatively about their body as a result of the pandemic, and 48% feel that their mental health as suffered as a result of how they feel about their body we worked with Creators to encourage conversation around male body issues through ‘Body Talks’, a four-part celebrity interview series on IGTV featuring Jamie Laing, Leon Mckenzie and body acceptance activist Stevie Blaine.


        Driving discussion about climate change. Tolmeia is a 20-year old sustainability activist who is using Instagram to drive discussion about how people can make small changes to help tackle climate change. She recently created stickers and an AR filter for people to use on their IG stories when talking about climate change to make it more interactive and engaging.


        Ending period poverty for girls. Amikageorge is an author and founder of the #FreePeriod campaign. Amika used Instagram to generate a following and spread awareness about her mission to end period poverty in schools and to promote her book about how to be an activist to inspire the next generation.


        Driving vaccine uptake and delivering authoritative health information. The Committee noted the huge role that Creators have played in driving vaccine uptake, especially among specific communities who may follow those individuals. Early on during the UK vaccination program it was widely acknowledged that there were issues of vaccine confidence in underrepresented and underserved communities including the South Asian community. One of the ways we tackled this was by engaging with UK-based South Asian Creators to encourage them to post about their vaccinations with the hope this would drive vaccine uptake and confidence - for example this post from Romesh Ranganathan regarding his first vaccine dose. Facebook has developed a wide range of tools to facilitate this type of messaging by its users, for example profile frames which link through to our Covid Information Center.


Finally, Creators form a vital part of the broader shift towards personalised advertising services that has helped to democratise advertising in the UK. Even just a few years ago, effective advertising was simply not an option for large numbers of businesses in the UK: either because it was too expensive (for example, a commercial to air on prime-time TV) and/or too inefficient (for example a print advert which might only be relevant to a fraction of a publication’s readers).


Now however Facebook and Instagram have become an essential means by which SMEs can advertise and promote their services, often through a partnership with a Creator to reach key audiences with new products. For example a 2019 Ipsos survey found that: more than two thirds (69%) of UK small and medium-sized enterprises state Facebook is an important part of their business; more than half (52%) of SMEs agree that their business is stronger today because of Facebook apps and technologies; almost four in ten (38%) of businesses say that use of Instagram has led to a better ability to compete.[1]


Digital advertising, driven in part by Creators, also broadens markets for businesses and supports export growth. A Copenhagen Economics survey of 7,000 businesses across Europe, including the UK, found that businesses in the EU and UK that used Facebook services generated 98 billion euros in experts in 2019; seven in ten businesses using our services export to other countries compared with five in ten for non-users; and six in ten of the businesses surveyed say that our services are helpful in entering new markets. Our global community of Creators and those who follow them helps many brands to grow within the UK and overseas.

3.      Building a safe community


As set out in this response, we are constantly innovating to support creators, their fans and the people who use our services. That includes policies, tools and product features to keep them safe - whether that’s a paid advert, or a livestream.


We view the safety of the people who use our platforms as our most important responsibility and we have developed robust policies, tools and resources to keep people safe. We have over 35,000 people working in safety and security at Facebook with around half of these being content reviewers responsible for actioning reports made to us and enforcing our rules. We work closely with external safety experts from across the world who help inform our policies and practices on safety, as well as with industry and community partners to understand their experiences on our platforms. Our policies are set out in our Community Standards and all content, including advertisements, must abide by them.


In addition we have a set of advertising policies that are designed to help keep our community safe. For example adverts must not contain deceptive, false or misleading claims, such as those relating to the effectiveness or characteristics of a product or service, including misleading health, employment or weight-loss claims that set unrealistic expectations for users. We make it clear that advertisers are responsible for complying with all local laws and regulations, such as the non-broadcast advertising Code administered by the Advertising Standards Authority, which brings with it the outcomes of over 60 years of expertise and consultation. We continually review our ads policy to incorporate community feedback and that from other stakeholders, like regulators and businesses.


While many companies in the UK choose to use more traditional forms of digital advertising to build their businesses on Facebook, many Creators partner with brands to produce branded content. We define branded content as a creator or publisher's content that features or is influenced by a business partner for an exchange of value (for example, where the business partner has paid the creator or publisher). Branded content is different from ads - we don’t receive any money for branded content posts and these posts show up organically in Feed for users following these accounts. If branded content is boosted with ad spend, it will then appear in the Ad library.


On Facebook and Instagram, we believe transparency is important and we encourage everyone to follow industry best practices around transparency with sponsored content - and indicate it clearly. Our policies require creators and publishers to tag business partners in their branded content posts when there's an exchange of value between a creator or publisher and a business partner. Creators cannot accept anything of value to post content that does not feature themselves or that they were not involved in creating. You can read the full policies here, which includes a number of format restrictions and information on common branded content scenarios.



Before ads go live on Facebook or Instagram, they are subject to Facebook's ad review system, which relies primarily on automated review tools to detect keywords, images, and a host of other signals that may indicate a violation of one of the Advertising Policies. If this process detects a violation of these policies, it will reject the ad. We use human reviewers to improve and train our automated systems, and in some cases, review specific ads. No such system is—or ever can be—perfect, so we also rely on user feedback and reports from regulators to help us identify possible policy-violating content.


In the UK online advertising is subject to the strict rules set out in the Code of Non-Broadcast Advertising and Direct & Promotional Marketing (CAP Code), and administered by the independent body, the Advertising Standards Authority (ASA). The CAP Code not only requires that the content of advertising is “legal, decent, honest and truthful and consumer confidence is maintained” but also does not harm, mislead, or offend the public. Certain categories of products are subject to media placement restrictions, regardless of their content. This is to help ensure that children and young people are not targeted directly with age-restricted advertising, and that advertising is not allowed to appear in a medium where children or young people make up a large proportion of the audience.


We provide expert advice to the ASA/CAP on forthcoming issues relating to online advertising regulation, and there is a long history of effective partnership between the ASA and industry. For example, the ASA recently ran a targeted ad on Facebook to raise awareness of its recent rulings on the prohibition against advertising Botox. The ad was seen by c. 1.4m people and viewed over 4.5m times (on average the ad was seen 3.37 times per-person). Over 2.5k people clicked the link, directing them to the ASA website to read the accompanying Enforcement Notice. As part of the project the ASA used its new monitoring technology to discover problem ads, and in turn report the ads to us to investigate and action their removal.


Where issues do occur and the ASA finds ads on Facebook that are in breach of the CAP Code it can report the offending material to us, through the Consumer Policy Channel (CPC), for action. The CPC is a reporting channel dedicated to effective engagement with regulators, and consumer and advertising authorities who can send us take down requests directly to the channel. We work with regulators around the world and receive take down requests about commercially-focused content, i.e. advertisements, commerce listings, and promotional content across the platform. If the content is found to be in breach of our policies (and not already picked up by our ad review process) or locally unlawful, we will take action against it. The ASA is onboarded to this channel and we understand from the ASA’s perspective that this reporting flow has been effective in removing non-compliant material.

Branded Content


To help creators and brands to be transparent about their commercial arrangements we have developed Branded Content tools that we require influencers and brands to use under our policies. This can make clear that for example a piece of content is a ‘Paid Partnerships With…’. All users should tag a business partner when they post branded content. This means that these accounts have a commercial relationship with the business partner that's mentioned, and that they were compensated in some way for the post. 


Facebook and Instagram generally do not have visibility of the type of relationship between a creator and a brand. The challenge of understanding what constitutes a sponsorship or endorsement deal, or even an incentivised gift, isn’t unique to social media – it’s an industry-wide issue. For example we cannot assume there's a monetary relationship between a creator and a brand simply because a brand or campaign is tagged or mentioned. But we are determined to give our community the tools they need to ensure that the relationship between themselves and brands is clear and we have taken the following additional steps over the last year:


        Added the Branded Content tag to new surfaces (Reels and Live) on Instagram

        Expanded access to the Branded Content tag to all users i.e. not just those who identify as creators or influencers.

        Developed a tool that identifies suspected unlabelled Branded Content and generates a flag that refers the creator to our Branded Content policies and requires the creator to confirm that the content is not branded content before the flag can be dismissed.

        Updated our Branded Content Policies to make them simpler and more accessible, for example:

         Added a table of Instagram-specific branded content scenarios, available here

         Moved the Business Partner tagging setting into the main creation flow (as opposed to ‘advanced settings’), for people who actively post Branded Content.

        Amended our Terms of Use to require compliance with our Branded Content Policies (including by requiring use of the Branded Content tool) and link directly to them.

        Published blog posts educating brands about Instagram's Branded Content tool and their ability to report untagged branded content through the trademark reporting channel.


We encourage our community to report any content that they believe violates our community guidelines. We also have manual and automated systems in place to catch offensive and violating content.


Examples of use of the Branded Content tag include:


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Finally, we are always working on new ways to increase transparency, including making our Branded Content Policies simpler and more accessible. In the UK we are working with MediaSmart on a programme to educate young people about Instagram’s branded content policy, how to identify this content on Instagram, and to increase digital awareness among young people of branded content more broadly As part of this partnership, MediaSmart has created educational materials that clearly break down Instagram’s branded content policy that have been circulated to MediaSmart’s network of schools, parents and young people.

4.      Conclusion


At Facebook we are always looking at ways to make it simpler and easier for people to use our tools and have a positive experience on our services. We work closely with trade bodies, regulators and partners, supporting industry-led initiatives to share knowledge, build consensus and work towards making our online services as safe as possible.


As the Committee is well aware, keeping people safe online is complex, requiring well designed regulation that protects people from harm without stifling expression and the benefits that come from online connection. We hope that the information provided in this submission is of help to the inquiry.



[1] Ipsos Public Affairs, 2019, survey of 1,000 UK small and medium businesses (OECD SME definition - n=239owners, n=761employees - September 23 to 30, 2019).