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Data Privacy - Case Study

Collection of personal data has fuelled the rapid growth of internet-based technology companies.


We started engaging with Meta – formerly called Facebook – in 2019 on data privacy and human rights issues. As a tech giant whose revenues are largely depending on the collection of users’ personal data, the company was part of our engagement focus list. Our main objectives were for Meta to strengthen board oversight of data privacy and human rights issues, increase transparency and reporting on these risks and to take concrete steps to address recurrent related controversies.

Since then we have met with the company at least once a year and over time we have had the opportunity to hold discussions with representatives of various departments, such as investor relations, corporate secretary and operational specialists. We also joined collaborative investor initiatives carrying similar messages to Meta.

Some of our engagement objectives have been met. For example, Meta established a privacy committee at board level and set up the Oversight Board in 2020. These were positive steps with regards to the risks we identified through our research and our engagement targets.

Despite this progress, in 2021 the company found itself once again subject to a content/data privacy controversy – the Facebook Files.26 In our view, it could be a sign of structural oversight problems around these issues.

The company organised a group call to clarify its position around content moderation and human rights issues and emphasised where it had seen success. While we recognise that Meta has made significant efforts to improve policies and transparency on these issues since we started engaging with it, we consider that the most critical point we wanted to be addressed was left unanswered: We do not have any idea of what concrete steps Meta will take to address the recurrent privacy, content and user safety issues it has been facing for quite some time.

In terms of next steps, we will adapt our 2022 voting decisions accordingly. We will also carry on our engagement with Meta – both individually and collectively – and keep pushing for better oversight and management of data privacy, human rights and content moderations issues.

2021 Active Ownership and Stewardship Report
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