Why Facebook actually has not agreed to everything MRC requires in its brand safety audit

In May, Digiday reported that Facebook had committed to allowing the MRC to conduct an independent audit of the transparency reporting data it supplies to GARM. That followed Facebook publicly stating in July 2020 it would allow MRC to evaluate its compliance with GARM’s brand suitability framework and described the decision as a “direct result of feedback from the civil rights community collected through our civil rights audit.” However, “there’s an ambiguity that’s developed,” said Ivie.

The ambiguity revolves around GARM-approved brand safety standards. Facebook and other platforms involved in GARM use the standards, when providing brand-safety related measurement data specifically for GARM’s Aggregated Measurement Report, the first of which was published in April based solely on numbers self-reported by the platforms. Once made official by GARM, the standards for formatting data supplied to GARM will be incorporated into the MRC’s current brand safety audit approach.

However, the standards have yet to be finalized by GARM, and therein lies the rub.

According to Ivie, Facebook did not realize the standards — which will be applicable to the transparency reporting Facebook will supply to GARM — would eventually be a component of the MRC’s audit. He said the MRC assumed that Facebook realized that once finalized by GARM, the standards would be an element of the audit. It is not known when GARM expects to finalize the standards. Several GARM representatives were contacted to comment for this article with no responses.

“Facebook didn’t realize this,” Ivie said, adding, “They came back and said we didn’t agree to auditing that transparency report.”

By contrast, Facebook said it does understand the standards will be incorporated eventually, but does not want to commit to as-yet-unofficial standards. When GARM does finalize its reporting standards, Ivie said integrating them into the MRC audit Facebook has agreed to won’t be too difficult. “It’s pretty easy,” he said, explaining that any changes will encompass things like language and format for information that platforms will need to supply to GARM.

Despite not committing to the GARM transparency reporting standards element of the MRC audit, Facebook claims to be committed to GARM in other respects. For instance, a Facebook spokesperson told Digiday on May 27 that the content monetization and brand safety controls audit by the MRC is “part of our commitments to GARM.” When the company announced its commitment to have the MRC oversee that audit, Facebook said it would include “but not be limited to” assessing its application brand safety controls to ads shown within publisher content such as in-stream, Instant Articles or the Facebook Audience Network, and “an evaluation of the development and enforcement of our Content Monetization Policies and how these policies enforce the 4A’s/GARM Brand Suitability Framework, and comply with MRC’s Standards for Brand Safety.” 

No signed formal agreement

The MRC still plans to launch its audit of Facebook’s brand-safety controls at the end of June. However, there is still no signed formal agreement between MRC and Facebook for that audit yet, according to Ivie. Agreement exists in email communications at this point, and official documentation currently is being finalized, he said. Whether the GARM-approved standards will be part of that audit remains unclear, though.

“If Facebook wants to be audited by us, they have to be subject to the [GARM transparency reporting standards-based] audit,” said Ivie. He also told Digiday, “We’ve learned from experience to discount public pronouncements that platforms might make about auditing, and generally don’t consider agreements to be in place until we have written commitments to a formal agreement that spells out the details of what the audit will entail. Citing agreements prior to then leaves too much gray area that’s subject to interpretation or later shifting of positions by platforms.”

A separate audit

At the risk of further muddying the issue, Facebook will undergo a separate audit of the numbers the platform supplies for GARM reporting.

EY, better known as Ernst and Young, will audit Facebook’s self-published content enforcement and standards reports, according to the Facebook spokesperson. Those are the same numbers that the company supplies for GARM’s platform measurement reports, the spokesperson noted.

But what will be missing from that audit is the MRC, the decades-old measurement oversight body relied upon by advertisers and agencies as a trusted arbiter of all-things media and ad measurement.