Global Alliance against Minor Exploitation
www.GAME4kids.org
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October 29, 2013

Mr. Mark Zuckerberg
Ms. Sheryl Sandberg
Facebook Board of Directors

Dear Directors,

This is going to be a long letter, but allow me to get straight to the point. Facebook policies and/or the lack of implementation thereof are a DANGER TO CHILDREN. It is as simple as that.

Several months have passed since our final communication with Mr. Fred Wolens, the last of which where he claimed that we should consult federal law enforcement, i.e. DoJ and FBI, on their opinion on Facebook’s policies on child sexual abuse content, since Facebook’s policies are “according to best practices prescribed by these organizations”.

This claim, combined with many other such denials and disregard over widespread international concern over Facebook’s lackadaisical approach to child safety, as well as the stalling on the implementation of some sort of child sexual abuse & child harassment reporting function were what prompted our withdrawal from communications at the time.

Yet, we are unable to remain silent any longer in view of the recent policy to loosen restrictions on minors posting publicly as well as – despite all denials made publicly in the past as well as by Mr. Wolens to us – the ever-prevalent child sexual abuse and exploitation content, cyberbullying and harassment of children via the network, and Facebook’s utter disinterest or inability to control and contain said content. Not to mention also the recent policy u-turn on posting violent beheading videos that has been unilaterally criticized by the international media, your own Safety Advisory Board and concerned parents worldwide.

For years now dozens of petitions have been made, lobby efforts started, child safety activists and NGO’s worldwide have campaigned for stringent safety measures, yet to all of this Facebook has turned a blind eye out of ignorance to the dangers and risk being forced upon the millions of teens and preteens around the world freely using the network and being exposed to pornography, child sexual abuse material, child sexual predators, vile graphic violence and online harassment and bullying, all of which has led to numerous children’s lives lost due to online grooming, murder and suicide.

Earlier in the year when we lobbied Facebook via Mr. Wolens for a comprehensive priority reporting mechanism for such content to be incorporated into the current Facebook content reporting system, we were immediately told that Facebook had tested such a system before on behalf of the New Jersey Attorney-General and that it was deemed not feasible on the grounds that “lesser numbers of valid reports are received” and claimed that “if all of our customers only needed one minute of customer service every other year, and we didn’t even accept user reports on content, we would still need over 200,000 people (about the size of all of FedEx).”

Mr. Wolens eventually refused to discuss the issue of adding such a function for users further, until we proposed a compromise in which such a report system would be a stand-alone function, similar to that for under-aged users and convicted sex offenders. Yet, after weeks of stalling, waiting and empty promises, and with no sign of any positive development, we gave up. We realized that Facebook has no intention whatsoever – counter to your many claims to the contrary – to ensure the safety and security of your young users.

Yet, while Facebook stock climbs daily to new highs, the technology is further developed and enhanced to enable Facebook users to communicate more freely and in more ways, and the total volume of ad revenue increases, so is the level and amount of profiles of convicted sex offenders, fake profiles made for the sharing of child sexual abuse material, pages and profiles made for the explicit use of encouraging child sexual exploitation, and abuse, harassment and bullying of minors.

Convicted & Registered Sex Offenders on Facebook

We recently found and provided the confirmed profiles of more than 200 registered sex offenders existing openly on Facebook to the New York Post, and subsequently I.C.E., which remarkably were found by cross-referencing sex offender registries with Facebook profiles. It only took 3 people, with no tools other than using Facebook search functions, less than one week to accomplish in their spare time. Why can Facebook – with all the technology and resources at your disposal – not endeavor to do the same or much more? It may be safe to say thousands such profiles still exist.

Here is one example of a Facebook user who is a registered sex offender, convicted of two child sexual offenses and using Facebook to publicize and further his religious work with children, not only in the USA but also abroad.

https://www.facebook.com/christianjerry
https://www.facebook.com/ChristianIzquierdoMinistryPage

Possession of child pornography:
http://www.sexoffenderrecord.com/citydirectory/NV/Henderson/Christian_Jerry_Izquierdo_267603

Lewd or lascivious acts with a child under 14:
http://www.sexoffenderrecord.com/directory/CA/I/Christian_Izquierdo_1272965

Cyberbullying of children on Facebook

The recent spate of teen suicides attributable partially or in full to cyberbullying on social media has again put the spotlight on how Facebook thoroughly ignores the issue. Maybe Facebook can explain to Carol Todd, Kim Loik, Tricia Norman and the countless other parents suffering the grief of a loved one, how Facebook policies best protect children.

Reporting bullying and harassment on Facebook has virtually no actual use. It just does not work. What is the point of only blocking your harasser, when the abuse still continues? How does this policy of “out of sight – out of mind” actually benefit the person being harassed and bullied? The abuse still continues and the abusers still continue their actions, often through multiple fake accounts that cannot be successfully reported. Facebook will NOT remove those accounts, even if mass reported. We have tried.

Yet, when pressed on the issue, Mr. Wolens responded that additional reporting functions and safeguards in this regard were not needed. Tell that to Todd Loik & Rebecca Sedwick.

Tell that also to the friends and family of Dillion Burns who committed suicide due to the bullying initiated by the “Erie on Blast” series of pages last Christmas. How many thousands of reports by hundreds of individuals were needed to take the pages down? But not before two kids took their lives and a third was possibly narrowly avoided due to concerned members of our group interceding and involving the police and local clergy. How can Facebook claim that their policies are adequate when children commit suicide while the abuse is not being removed even while mass reported?

[box type=”shadow” align=”aligncenter” ]“I , the mother of a child that was harassed, that was bullied on Facebook – who took his life because of it – am disgusted that Facebook with its millions, or billions of dollars does not have the means to protect our children from the vile that continues to occur on Facebook . It seems to me that if T.V and news papers have to follow strict guide lines, why is Facebook not held accountable for what is on it? Our governments have laws that papers and TV have to follow yet Facebook seems to be above the law in any regards. It needs to STOP & they need to be held ACCOUNTABLE. HOW many more children do we have to lose?

“WHAT IF IT WAS THEIR CHILD? Would it CONTINUE? WHAT IF………….”

~ Kim Loik, mother of Todd Loik[/box]

Unauthorized R.I.P. / Memorial Pages on Facebook

Which brings us to the issue of R.I.P. / Memorial pages that are set up without the families’ authorization. We have received numerous complaints from the families of teens that have passed away that Facebook refuses to remove hundreds of pages made in their children’s names. Facebook claims that these kids are now “public figures” which entitles anyone to use their names and images to set up memorial pages even when the parents of these minors object.

A minor is a minor even in death and the absolute right of the parent to decide who may or may not share or distribute the child’s image persists. These unauthorized pages in most instances eventually become obsolete and not updated and overrun with further abuse and comments by RIP trolls and cyberbullies. The images used by these pages are lifted from authorized media articles or the official memorial pages set up by the families without consent from the parents. Members of the general public – even friends of the deceased – unknowingly end up paying their respects on a page totally unrelated to the family and what was supposed to be a tribute to the child becomes either overrun with spam & trolls, forgotten or hacked, as was the case with an April Jones memorial page not too long ago.

Only a parent has the exclusive right to decide where and when their child’s name and image may be used. Facebook does NOT have that right. Neither does any other member of the public. Any legitimate and respectable news organization will request – out of decency and respect to the child and family – for permission to reproduce and publish a photograph, which we have seen personally. Yet Facebook believes that parents of deceased minors do not have such rights. Yet, you claim your policies best protect children.

Please explain that to Glen Canning, Carol Todd, Dave & Deb Smith, Warren Penpraze and the countless other parents who have complained about this issue to no avail.

According to Facebook, the above page did not violate your Community Standards and the father of Rehtaeh received the following automated response from you after being reported.


Adult Trolls & Cyberbullies on Facebook

Adult trolls and cyberbullies have always been a major problem on Facebook, yet the network has done absolutely nothing to combat the problem. How many times in the past 6 months have we complained directly to you about trolls such as Jamie Card, who harasses other users, steals photos of small children, and then offers them “up for sale”? Yet, the last time we got a response from Facebook on the issue, this is what was said when we politely explained that trolls such as Mr. “Card” always uses the same profile name of Jamie + Card with slight variations. It boggles the mind that Facebook is not “able to” block this person after 3 years of using thousands of profiles with almost the same account name for bullying and harassing other Facebook users.

[box type=”shadow” align=”aligncenter” ]“On putting names on the watch list, we have found this to be incredibly problematic in the past. For example, there are over 100 James, Jamie, and Jim Cards on Facebook the vast majority of whom are legitimate, and each would need to have submitted government ID such as a driver’s license if they did indeed want to open an account.

Plus that would do nothing to stop them from using a fake name, thus we prefer to use more leverage means of identifying fake accounts or those that are abusive. Have a good weekend Fred”

~ Received May 17, 2013 from Fred Wolens, Facebook Spokesperson & Public Policy Manager[/box]

This particular troll – Jamie Card – has been given full freedom to make thousands of profiles on Facebook over the past 2 or more years since Facebook, with all your resources and technology, cannot find him? We just type Jamie + Card into graph search.

Now look at news reports of this troll’s activities on Facebook with the latest report dated today, October 29, 2013:

October 29, 2013
http://www.stuff.co.nz/southland-times/news/9335517/Facebook-page-a-nightmare-for-parents

October 26, 2013
http://www.couriermail.com.au/news/queensland/girl-3-up-for-sale-on-facebook/story-fnihsrf2-1226747179997

August 22, 2013
http://www.dailypost.co.uk/news/north-wales-news/facebook-troll-hijacked-womans-account-5765947

September 11, 2012
http://www.mirror.co.uk/news/uk-news/facebook-troll-hijacks-mums-profile-1318031
http://www.coventrytelegraph.net/news/coventry-news/nuneaton-mum-blasts-facebook-troll-3019265

July 13, 2012
http://www.theargus.co.uk/news/9816776.Cyber_bully___s_taunt_to_Sussex_Police/

May 21, 2012
http://www.womensviewsonnews.org/2012/05/legal-action-to-be-taken-against-facebook-trolls/

Above are just a small selection of news reports regarding this particular troll, one of many, that has been terrorizing Facebook users for years.

A Facebook group called “Remove jamie weekend card from facebook” was set up as far back as early 2011, which just goes to show how long this has been going on. And he is not the only troll who terrorizes other users. There are numerous sick individuals, who make it their daily goal to see how many ordinary members of the public they can offend, harass and bully – names we have provided you in the past, but no action is being taken whatsoever.

Hate Pages on Facebook

Not to mention the vile attacks made by users on infants and children with diseases or disabilities, such as Adalia Rose, pages created to make sick jokes of infant deaths and other diseases with titles such as “SIDS is funny because people die”, “Cancer is funny because people die”, and many more. These pages are allowed and very rarely removed even after thousands of reports.

This is Facebook’s brand of “Freedom of Speech” – It is acceptable to make fun of cancer, SIDS, Progeria Syndrome and just basically have a laugh at the expense of others’ suffering.

Yet your Community Standards clearly indicate that Facebook does not tolerate hate speech, which begets the question: What is “Hate Speech” then?

Facebook Safety Advisory Board

What is the purpose of the Facebook Safety Advisory Board?

https://www.facebook.com/help/222332597793306

At the beginning of this year, John Carr (http://www.huffingtonpost.co.uk/john-carr/) states, “I wonder how much time the Board spent on Sponsored Stories and Graph Search, to take but two recent examples? What advice, in the end, did the Board offer? Did the company follow some of it, all of it or none of it?”

http://www.huffingtonpost.co.uk/john-carr/facebooks-safety-advisory_b_2531828.html

By analyzing media reports of the past year, the Board has only on two occasions called out Facebook policies to our knowledge, and both were only to do with Facebook’s policy on beheading videos. How come your Safety Advisory Board is silent on all the other issues, such as rampant child sexual abuse and exploitation, cyberbullying, harassment and the dozens of accompanying deaths and suicides that may be partly to blame according to news reports? Does this safety Advisory Board in fact serve any specific purpose other than a white-washing attempt? The mystery surrounding this Board only deepens with the fact that till recently Richard Allan, who works as Director for Facebook EU, was Chairman of one of the organizations on the Facebook Safety Advisory Board until we publicized the fact. He has now been replaced by David Pierce.

The five organizations on the Facebook Safety Advisory Board have to step up to the plate and help force real safety procedures on the network or remove themselves. This Board serves no apparent safety purpose judging from the network’s safety record.

Child Sexual Abuse & Exploitation Content on Facebook

Earlier this month the UK House of Commons heard from Peter Davies, chief executive of Child Exploitation and Online Protection Centre, that Facebook is a “major location for online child sexual grooming”.

http://www.telegraph.co.uk/technology/facebook/10380631/Facebook-is-a-major-location-for-online-child-sexual-grooming-head-of-child-protection-agency-says.html

http://www.dailymail.co.uk/news/article-2462492/Investigator-warns-Facebook-major-location-child-sex-grooming-UK.html

There exists on Facebook thousands of pages & groups filled with child exploitation images and requests and offers of such images and videos. Teens and preteens in sexually suggestive poses, in semi-dressed states, in their underwear, and with lewd and sexual comments by adults are allowed and condoned. Pages with names such as “Young sluts going down to the age of 12”, “Sexy schoolgirls”, “Pantyhose schoolgirls”, “Hot schoolgirls”, “Sexy preteens”, “Sexy kids” are all over the network and mass reporting hardly ever is successful.

In June of this year a report in the Mirror explained what we have been complaining to Facebook about for months. The report states very accurately that “Perverts trawl the site copying pictures parents have taken of their kids and those youngsters have shared with friends”. Yet several months ago when we brought this issue to Facebook’s attention and the fact that there are thousands of such profiles, groups and pages sharing such sick images – which incidentally would be considered illegal child pornography, or child sexual abuse images – in most parts of the world, this was their response:

[box type=”shadow” align=”aligncenter” ]“Before we delve into Facebook’s policies, have you spoken to anyone at NCMEC, DoJ, or the FBI about these images?

It might be useful to have the background from these agencies before you hear more from us, as we set our policies to fall inline with the best practices recommended by these organizations.

Hope all is well ,

Fred”[/box]

http://www.mirror.co.uk/news/uk-news/paedophiles-stealing-parents-facebook-pictures-1982052

There is even an Interest List – which we have complained to Facebook before about via email to no avail – called “pthc, lolicon, toddlercon”. PTHC of course stands for “Pre-teen Hardcore”. There are other links to PTHC, including one profile openly advocating the sharing of preteen sexual abuse images with his profile pic containing the words “I ‘heart’ PTHC”. This profile has been reported for more than a week but not removed.

Is Facebook a Tech or a Media Company?

Facebook considers itself a source of news. As your Mission Statement claims, “Facebook’s mission is to give people the power to share and make the world more open and connected. People use Facebook to stay connected with friends and family, to discover what’s going on in the world, and to share and express what matters to them.”

For all practical purposes, this makes Facebook a media company and not a tech company. As Sir Martin Sorrell so clearly stated earlier in the year, “If you have responsibility for the pipe, you can’t ignore the responsibility for the editorial content… you can’t abrogate responsibility.”

http://www.zdnet.com/wpps-sir-martin-sorrell-says-google-facebook-yahoo-aol-are-not-tech-companies-7000017118/

“Will regulators also start to see these US media-tech giants as media companies? If they did and took away their legal protection, which is the same as that given to telecommunications companies, it would result in a massive jump in business costs. They would have to hire tens of thousands of workers to monitor content before it is published.”

Facebook has more than enough revenue to accomplish this, yet has financial greed prevented adequate safety measures?

The above article touches on the core of the issue and you, Facebook, have the responsibility to your billion-plus users. You have the responsibility to keep them safe. You have the responsibility to ensure that abusive and illegal content is removed, either by your own filters or after it is brought to your attention through reporting by users. And this must be done even after just a SINGLE report – not ten, not a hundred, not thousands.

JUST ONE report of illegal or abusive content MUST result in permanent removal of said content.

ALL forms of child sexual abuse & harassment content MUST be removed from the network.

Minors must be given FULL protections and privacy.

Given the above and the years of complaints and publicizing of Facebook’s ridiculous and absurd safety failures, we call on the Governments of the United Kingdom, Canada & Australia to launch full investigations into how Facebook is allowed to operate without any safeguards to our children, without any oversight, and with such an explosion of child abuse, grooming, cyberbullying and offensive content.

We call on investors and advertisers to take note on how Facebook operates and allows said content without concern for the safety of its users. These advertisers and investors need to see how you operate Facebook to the detriment of the millions of teens and preteens around the world.

We call on you, Mr. Zuckerberg, Ms. Sandberg, the Board of Directors, and senior management. It is time that Facebook takes child safety seriously. It is time that Facebook starts spending some of the billions in revenue on child safety.

As we and our partners have shown before with Marks & Spencer, BSkyB and Citibank, there is still oversight. We the general public will not stand for any further delay in implementing radical changes to how you operate.

Freedom of speech is not a universal right.

The safety of our children supersedes that right.

Signed hereby on the 29th of October, 2013

On behalf of the Global Alliance against Minor Exploitation and worldwide partners,

Jay Marshall, Spokesperson, Global Alliance against Minor Exploitation
Carol Todd, mother of Amanda Todd
Dave Smith, father of Hannah Smith
Deb Smith, stepmom of Hannah Smith
Glen Canning, father of Rehtaeh Parsons
Kim Loik, mother of Todd Loik
Tricia Norman, mother of Rebecca Sedwick
Warren Penpraze, father of Olivia Penpraze
Blair Corbett, Ark of Hope for Children
Inesa Jenza, Child Sexual Abuse Prevention & Safety Activist
Marie King, www.harboroughagainstbullying-midlands.org.uk
Rachel Holway, President, Alerta Vida ONG
Ruth Jacobs, Human Rights Activist and Author, www.ruthjacobs.co.uk
Trista Hendren, Author & Activist, www.thegirlgod.com

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