Google Wellness Standards for Sensitive Content Moderation
Google is committed to supporting the wellbeing of our provisioned* extended workforce members who perform sensitive content moderation activities (“Content Moderators”) for/on Google products and services. We expect our sensitive content moderation suppliers (“Suppliers”) to implement these Wellness Standards for Sensitive Content Moderation (“Standards”) and to provide safe and healthy working conditions for this work. Sensitive content moderation activities mean those activities requiring review of content of a graphic, violent, sexual, or egregious nature.
These Standards set out minimum expectations only. Suppliers should continue to comply with: all applicable laws; legal regulations, directives, and guidelines; all obligations in any contract that Suppliers may have with Google; and the Google Supplier Code of Conduct. Suppliers should stay apprised of and adopt appropriate research-based and industry practices to support the wellness of Content Moderators.
Suppliers remain solely responsible for safely administering the sensitive content moderation services and ensuring that Content Moderators have access to mental health and wellness resources commensurate with the sensitive content moderation activities, including determining the type, nature, availability, and schedule of wellness activities and benefits, and handling all related concerns from Content Moderators. Suppliers are also responsible for determining the applicability of these Standards for workers other than Content Moderators that may have variable exposure to sensitive content, such as support teams (e.g., quality analysts, trainers, team leads).
Wellness Standards Expectations
A. Conformance. Google will periodically review Supplier compliance to the Standards and may re-evaluate its service engagements if expectations are not met.
B. Commitment. Wellness program information and related metrics should be used to monitor effectiveness of the program, and not to penalize individual Content Moderators for availing themselves of wellness program activities. Use of wellness breaks, resources, activities, training, opt out, and counseling services should not negatively impact performance ratings or job opportunities for Content Moderators.
C. Updates. Wellness programs associated with content moderation continue to evolve and develop. As a result, these Standards are subject to change to reflect legal and regulatory updates and industry practices. Suppliers should periodically check for updates and subsequent versions of these Standards to stay apprised of current expectations.
I. Pre-Hire & Onboarding
A. Job Descriptions. Content Moderator job descriptions should state that the role involves sensitive content moderation. Job descriptions should accurately reflect the scope of role and activities the Content Moderator is expected to perform, with sensitive content moderation activities explicitly identified.
B. Interviews/Internal Transfers. A consistent set of questions and talking points should be used during the hiring process to explain the nature of the role. A detailed description of the nature of the work and examples of types of content to be reviewed should be provided to interviewees.
C. Content Moderator Onboarding. Content Moderators should complete mandatory training prior to working on sensitive content moderation services, with additional ongoing refresher trainings offered. The training should include: an overview of the wellness program and resources; psychological coping skills; and policies/procedures to request an alternative work placement. Suppliers should collect a signed acknowledgement from every Content Moderator that they understand the wellness resources and the alternative work placement policies and procedures available to them.
D. Manager Training. Managers that supervise Content Moderators should be trained to support the wellbeing and mental health of workers, including for employees in distress. Mandatory training should take place within 2 weeks of onboarding to their role as manager with additional ongoing refresher trainings offered.
II. Ongoing Engagement
A. Wellness Team. A dedicated global wellness team should manage wellness operations. The wellness team should, at a minimum, have a program manager with a public health, mental health, or workplace wellbeing background. The program manager should be someone other than the clinician providing counseling services.
B. Counseling. Content Moderators should have access to individual and group counseling services provided by a licensed and experienced clinician. Information shared in the course of counseling should be kept confidential. Individual counseling sessions should be: onsite whenever possible, with virtual options available; at least 45 minutes; and available during each shift. If the counseling options are inadequate, Suppliers should provide access to additional counseling options outside of workplace offerings (example: through medical benefits). Suppliers should also ensure that there is at least 1 crisis-trained individual onsite whenever Content Moderators are working.
C. Employee Assistance Program. Employee assistance programs (“EAP”) should be available to Content Moderators with features including 24/7 support, virtual counseling, and critical incident response.
D. Peer Support Groups. Peer support groups focused on mental health and wellbeing should be made available to meet at Content Moderators’ discretion. Suppliers should provide reasonable resources to enable these peer support groups to meet at least monthly.
E. Wellness Breaks. Content Moderators should be provided paid wellness breaks that they should use for wellness activities or counseling. This time is in addition to other standard employee breaks and is separate from time spent on role related training. Suppliers should provide a schedule of wellness breaks to Content Moderators. Content Moderators should be able to take breaks at-will, if needed. Mechanisms should be in place to ensure that sensitive content moderation will not exceed 5 hours a day, though Content Moderators should be paid for the full shift per their contract. Any overtime should be voluntary, and Suppliers should provide additional wellness break time to Content Moderators proportional to the amount of overtime worked.
F. Physical Space. Spaces used for wellness purposes should be allocated and equipped according to the needs of the applicable wellness activities (example: spaces for counseling sessions should be private with appropriate acoustic adjustments).
G. Wellness Training & Activities. Content Moderators should have access to and be made aware of voluntary wellness training and activities offered regularly, including group and self-guided formats. Wellness training or activities should be offered at least weekly and during each shift.
H. Resources. A complete list of wellness resources and all Supplier policies related to the Standards should be updated and communicated at least annually to Content Moderators, in addition to being shared at onboarding. Detailed information about the wellness program components and wellness team should be included in those communications.
I. Surveys. Suppliers should survey Content Moderators at least annually to seek feedback on the wellness program offerings and their effectiveness. Surveys should request feedback regarding the effectiveness of onboarding, counseling, and resources available to Content Moderators. Content Moderators should have formal and anonymous mechanisms for submitting wellness related feedback. Feedback should be analyzed and incorporated to improve wellness program practices. The aggregated results of the feedback and related actions should be communicated to Content Moderators.
J. Opt-Outs. Policies and procedures should be in place to support opt out requests and consider alternative work placement outside of sensitive content moderation activities. Suppliers should review and acknowledge opt out requests within 1 business day and close out the request as per their policies and procedures. Opt out requests should not adversely impact Content Moderators (examples: pay and benefits, performance ratings, job opportunities).
III. Exit & Post-Exit Support
Wellness resources, including EAP, should be provided at exit. Suppliers should provide EAP support to Content Moderators for a minimum of 6 months after exit.
IV. Management Systems
Management systems should be adopted or established to carry out the expectations in the Wellness Standards. The management system should be designed to ensure sensitive content moderation operations: (1) comply with all Supplier obligations, including under applicable laws, legal regulations, directives, industry practice, and guidelines; (2) conform to the expectations under these Standards; and (3) identify and remediate issues related to these expectations. It should also facilitate continual improvement:
A. The management system should contain the following elements: executive level commitment and accountability; a communication plan for informing Content Moderators on these Standards and the expectations contained within; processes to identify, monitor, and comply with all applicable laws, legal regulations, directives, industry practice, and guidelines; risk management processes; and regular evaluation of wellness program operations and offerings, ongoing assessments, metrics monitoring, and continued improvement, including corrective action processes.
B. The management system should also include a program that ensures continuous monitoring of feedback and reporting processes, records issues raised, promptly escalates serious issues, and takes appropriate action. Suppliers should update the respective Google product area wellness team at least quarterly on adherence to these Standards. We expect Suppliers to continue following existing incident management protocols.
*Individuals with badge access or systems access at Google.