Writing a Takedown Policy

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Audience

The following are a list of considerations on which institutions can reflect as they write a takedown policy and procedure. Some considerations and questions are rhetorical and meant to help an institution solidify their understanding of what their process will be. Others are considerations that can guide the language of the policy.

  • Who will this policy be primarily written for?

  • Will more than one policy version be needed? For example:
    • An outward facing document might present the institution’s position and process at a high level, and be accompanied by an inward facing policy that might include step-by-step instructions for the process or a detailed list of what does or does not qualify for the policy.
    • The full policy available on a website, accompanied by excerpted policy statements embedded where users view/access the digital object at the point of engagement or need

  • Where is the policy hosted (on the institution website? In the digital library?) How easy is it to find? Is it linked from the digital object metadata?

  • Does the policy need to be reviewed and approved by upper administration, legal counsel, or others at your institution?

  • Who else — either internal or external to your organization — could be consulted for assistance creating and implementing the policy? Examples could include legal counsel, expert staff or community members from marginalized communities who can offer best practices, cultural, historical, and/or anthropological researchers specializing in cultural norms for a community whose collection items you hold, etc.?

  • Review contracts with vendors/publishers; you may not have the ability to redact content yourself for certain collections (example, newspaper collections)

Purpose

Develop an understanding of the function that this policy will provide.

  • Can you define what a “takedown” policy means to your institution? 

  • What goals or purpose will this policy fulfill?

  • Is this policy an extension of a mission, vision, values, commitment, or other statement issued by your institution or parent institution?  Can you connect them?

  • Does an institution’s commitment to open or accessible content conflict with requests for takedown? If so, how does the institution view this tension?

  • What responsibilities does the institution take for objects that are taken down? Or for objects that are NOT taken down? What legal or policy constraints will compete with this?

Parameters

Clearly outline the criteria and guidelines for the type of content and actions this policy will cover. Where possible, post criteria and procedures publicly in the takedown policy.  Where not possible, keep detailed information that can be updated frequently and document all decisions and communications about those decisions.

  • What types of digital content qualify for this takedown policy? What types do NOT qualify? For instance, consider under which circumstances your institution would keep,  restrict, remove, or provide content warnings for items or collections that include:
    • Content belonging to communities that did not agree, individually or communally, to having material hosted online
    • Content that might require culturally determined access levels
    • Content with violent images or descriptions
    • Content that could be considered culturally or racially insensitive
    • Content depicting, describing, or promoting hate crimes

  • What types of user concerns qualify for this takedown policy? What types do NOT qualify?  Situations to consider might include:
    • Profanity in content
    • Depictions of public figures that might be considered insensitive
    • Pornographic images/content
    • Violent images/content
    • Reputational damage
    • Defamatory content
    • Content that does not align with a cultural perspective or preference

  • What considerations will the institution make for copyright, sensitive material, privacy, personal threat, violation of laws, etc.?

  • How will your institution address problematic digital objects (where the object itself has or promotes misinformation) versus problematic metadata?

  • Are there different levels of takedown that could occur? For example:
    • Removal of digital object from public-facing systems (but could extend to digital preservation system or internal servers)
    • De-indexing of digital object (removes from search engines or system indices but does not remove object, which is still viewable via direct link)
    • Suppression of digital object (remains in system, but cannot be publicly viewed and/or only metadata can be publicly viewed)
    • Restriction of digital object (remains in system, but can only be viewed by authorized people/groups)
    • Content warning (digital object remains in system and is accessible but requires the user to click through an acknowledgement that what they’re about to see may be offensive, disturbing, sensitive, etc.)
    • Redacted: digital object remains in digital library but the optical character recognition (OCR) is removed and/or images are altered (for example, blocking out or fuzzing a person’s face or removing the OCR of their name)
    • Metadata editing or versioning (digital object remains in the system but metadata is edited to remove or correct offensive/outdated terminology or sensitive/personally identifiable information, potentially including explanations of what was changed)
    • Anonymizing digital object (digital object remains in system but all identifying information is removed from the object and the metadata; for example, removing all personally identifying information from an oral history)

  • How does this policy connect with or differ from other institutional policies? For instance, does it align with a harmful language policy or a copyright infringement policy?

  • How does takedown of digital objects impact how originals/physical objects are described and made available? For example:
    • If one object in a collection is taken down but the other objects remain, then the institution would publicly document that: “This collection contained 10 objects. In January 2022, one object was deemed insensitive and removed based on our institutional guidelines.”
    • If an object is available online with the same description it has in the finding aid how does the takedown of that object impact the finding aid or catalog record? Where else does the object (or description of the object) reside besides the repository and how should the institution treat them?

Process

Outline the procedures for what takedown will look like, both from an institutional level and also from the requestor’s perspective.

  • How should a requestor notify an institution that an object needs to be taken down?
  • Can you provide an anonymous channel for takedown requests?
  • What are the steps that will be taken by the institution when this request is received?
  • Who will be involved in the decision making? Will you need to bring in outside stakeholders?
  • Is there a time frame within which requests will be reviewed?
  • Will the object be taken down during the review process or afterwards and, if so, how? Will this be recorded publicly during the review process?
  • How will the institution communicate with the requestor throughout the process? How and with what frequency throughout the process will the requestor be notified of actions, decision, or status?
  • How can the requestor communicate with the institution throughout the process? Is there a point of contact?
  • Will the requestor be involved in the decision-making or appeals process? And if so, to what extent?
  • How will the takedown request be documented? Will information about the request and subsequent actions be included in finding aids, digital preservation systems, etc.?
  • Where do changes/redactions/takedowns need to be duplicated? For example, is a statewide digital library or the Digital Public Library of America harvesting the item/collection?
  • How will the process look different between a full takedown request and an embargoed time/event-specific request? Do any triggers need to be put in place to restore access to an item at a given point in time or a specific event? Are these future proof?
  • If an appeals process will be provided, what will it look like?  How will it be different from the original process?

Revision

Consider the lifespan of this takedown policy and determine how it will be reviewed or renewed in the future.

  • When / how frequently will this policy be reviewed and updated? Is this review cycle noted publicly?

  • How is the documentation for takedown requests stored?  Is versioning available?  Is the ability to record past takedown request events easily connected to, stored with, or accessible from the process documentation?

  • Are there any events or circumstances that can trigger a review in between review dates?

Prevention

Consider existing policies and practices that might not adequately prepare the institution or collection/item donors for the reality of having or hosting materials online.

  • What language is included in the donor/deposit agreement/informed consent documents?  For instance, re-consider uses of the term “deposit”, which connotes security and restricted access. Consider strong language that clearly outlines where material will show up and who will be able to find it, such as:
    • “Contributing this item/collection means that your work (article, pictures, oral history, datasets, etc.) will be submitted to a website run by a cultural heritage organization. If there are no restrictions, your work will be available online for anyone to find, view, and download. Even if there are restrictions, the metadata for your work will still be made available and indexed by search engines.”

  • Do donors or contributors for collections understand what it means to have material hosted online? Consider demonstrating similar online collections to donors or contributors so that they understand the context before signing consent documents.

  • Does your institution have reasonable procedures in place to redact sensitive or private information that should not be included in public spaces prior to content being put online? Are there legal or policy requirements regarding what sorts of information should be redacted (e.g., personally identifiable information as defined at institutional or other levels) and/or required mechanisms or compliance metrics for doing so?

  • Has your institution reviewed legacy collections for content that could violate reasonable privacy for non-public individuals, culturally sensitive information, or harmful language or depictions?

Template and examples

Takedown Policies: Tutorial
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