– Michel Protti, Chief Privacy and Compliance Officer, Product
Led by Chief Privacy and Compliance Officer, Product, Michel Protti, the product risk & compliance organisation is made up of dozens of teams, both technical and non-technical, focused on guiding the company on privacy strategies.
The product risk & compliance organisation is at the centre of our company’s commitment to its comprehensive privacy programme. Its mission – to instil responsible practices and enable innovation across Meta – guides this work by ensuring that people understand and trust how Meta products and services use their data responsibly.
The product risk & compliance organisation is just one organisation among many across the company that is responsible for privacy. There are thousands of people in different organisations and roles across Meta, including public policy, legal and product teams, who are working to embed privacy, safety, security and other areas of risk management, into all facets of our company operations. Getting privacy right is a deeply cross-functional effort, and we believe everyone at Meta is responsible for that effort.
Led by Erin Egan, Vice President and Chief Privacy Officer, Policy, the Privacy and Data Policy team leads our engagement in the global public discussion around privacy, including new regulatory frameworks, and ensures that feedback from governments and experts around the world is considered in our product design and data use practices.
To do so, the Privacy and Data Policy team consults with these groups through a variety of consultation mechanisms. This includes:
A core component of our privacy education approach is delivered through our privacy training. Our privacy training covers the foundational elements of privacy and is designed to help everyone here at Meta feel empowered to identify privacy risks and make responsible decisions that help mitigate them, so we can all take pride in not only what we build, but how we build it. One key theme is ensuring that Meta personnel are aware that they are the first line of defence to guard against privacy risks and to mitigate such risks.
Both our annual privacy training and our privacy training courses for new hires and new contingent workers provide scenario-based examples of privacy considerations aligned with our business operations and include an assessment to test the understanding of the relevant privacy concepts. These trainings are updated and deployed annually to ensure that relevant information is included in addition to core concepts.
In addition to our foundational privacy training, Meta regularly deploys specialist privacy education to targeted audiences, tailored to evolving topics and risks.
Another way we drive company-wide awareness around privacy is through regular communication to employees. In addition to our privacy training courses, we deliver ongoing privacy content through internal communication channels, updates from Meta’s leadership and internal Q&A sessions.
In addition to our robust mitigations and safeguards, we also maintain a process to (1) identify when an event potentially undermines the confidentiality, integrity or availability of data for which Meta is responsible, (2) investigate those situations, and (3) take any needed steps to address gaps we identify.
Our incident management programme operates globally to oversee the processes by which we identify, assess, investigate and remediate privacy incidents. Although the privacy and data practices team leads the incident management process, privacy incidents are everyone's responsibility at Meta. Teams from across the company, including legal and product teams, play vital roles. We continue to invest time, resources and energy in building a multi-layered programme that is constantly evolving and improving, and we highlight three components of our approach below.
Third parties are external partners who do business with Meta, but aren’t owned or operated by Meta. These third parties typically fall into two major categories: those who provide a service for Meta (such as vendors who provide website design support or technology solutions to enable our business) and those who build their businesses around our platform (such as app or API developers). To mitigate privacy risks posed by data and personal information exchanged with third parties, we developed a dedicated third-party oversight and management programme, which is responsible for overseeing third-party risks and implementing appropriate privacy safeguards.
Our anti-scraping team is dedicated to detecting, investigating and blocking patterns of behaviour associated with unauthorised scraping. Scraping is the automated collection of data from a website or app and can be either authorised or unauthorised. Using automation to access or collect data from Meta’s platforms without our permission is a violation of our Terms of Service.
The risk review process – which includes privacy review – is a central part of developing new and updated products, services and practices at Meta. Through this process, we assess how data will be used and protected as a part of new or updated products, services and practices. We review an average of 1,800 products, features and data practices per month across the company before they are sent to assess and mitigate risks.
Our strategy is focused on embedding hundreds of high-quality, reusable internal requirements into our risk review system designed to meet external expectations globally. An example of a requirement is mandating that when requested, user data be deleted within a certain period of time. This way, product teams can consider privacy risks at the start of the product development process, and easily apply requirements to maintain high standards of compliance.
To help ensure that those requirements are working in practice, we’ve developed consolidated and uniform technical solutions to satisfy a given requirement, with continuous compliance checks to confirm the solution is effective.
For newly developed products which may not be covered by internal requirements, such as certain AI products and features, we have a robust process in place to triage critical decisions with senior-level subject matter experts. Decisions are then codified into requirements.
By embedding privacy into Meta’s tools and processes, teams can think about privacy earlier in the product development lifecycle and more easily and consistently deliver privacy benefits for our users.
We’re investing in technological innovations that scale and improve our approach to privacy. By combining the efficiency and scalability of AI with the nuance and expertise of human judgment, we’re better able to ensure consistent decisions that deliver innovative products.
We’ve become a privacy-first product development company ensuring that from inception to delivery, any product or feature considers the privacy implications from the start. This is part of our commitment to delivering privacy in both new product innovations and updates to existing products. To reinforce this commitment, Privacy is a core component of performance evaluation for our engineering teams.
You can see this in many examples of products we’ve delivered:
– Michel Protti, Chief Privacy and Compliance Officer, Product
Protecting users’ data and privacy is essential to our business and our vision for the future. To do so, we’re continually refining and improving our privacy programme and our products, as we respond to evolving expectations and technological developments – working with policy makers and data protection experts to find solutions to unprecedented challenges – and sharing our progress as we do.