Summary of Teleperformance Internal Review in the US, following allegations against one of its Content Moderation operations.
PARIS, November 13, 2022
Promptly following publication of the Forbes article about Teleperformance USA’s content moderation services in early August, Teleperformance’s senior management engaged the Group’s Global Audit Team to complete an audit of our US operations for a key content moderation client. The specific focus of the review was to identify whether apparent child sexual abuse materials (“CSAM”) were being used during Teleperformance’s employee onboarding or in Company-provided training programs and continuing education documents.
During the audit, the Global Audit Team reviewed hundreds of documents, including all Company-provided enhanced and supplemental training materials, the DRRs referenced in the Forbes article, and other relevant guidance documents on the Teleperformance platform and on the client’s platform. The Global Audit Team also conducted testing of the Teleperformance and client systems, including a review of workstation restrictions, tools used in providing the services, access controls, user restrictions, internet access restrictions and use of any snipping tools.
The Global Audit Team conducted numerous interview sessions virtually with several TPUSA content moderation employees in El Paso, Texas and Boise, Idaho. In addition, TPUSA’s leadership held eight larger in-person focus groups among the content moderation employees in El Paso, Texas.
As part of the audit, the Global Audit Team interviewed leaders and team members in all support functions, including Information Technology, Operations, Human Resources, Information Security, Recruiting, Legal, Wellness, Learning & Development, and Trust & Safety.
Upon completion of the audit, the Global Audit Team found no evidence to support the claims made within the Forbes article. The Global Audit Team further observed that the Teleperformance Operations teams were operating within the requirements of the client contract scoped for this portion of the audit. Minor areas of operational improvement were identified, and corrections were implemented.
Separately from the internal audit, upon receipt of a letter from the Senate Commerce Committee, Subcommittee on Consumer Protection, Product Safety, and Data Security, TPUSA engaged Latham & Watkins LLP as outside counsel to assist it in addressing the questions and issues raised in the Senate letter about the Forbes article.
Latham & Watkins took additional targeted investigative steps that leveraged the information and conclusions developed by Teleperformance’s Global Audit Team, including traveling to El Paso for a three day in-person site visit and conducting interviews with Teleperformance Trust & Safety personnel, content moderators, training personnel and team leads. Latham & Watkins also reviewed multiple documents involving TPUSA’s content moderation work to enable TPUSA to comprehensively respond to the questions from the Senate Commerce Committee, Subcommittee on Consumer Protection, Product Safety, and Data Security.
Based on the combination of our internal audit, leadership inquiries, and the additional investigative steps of outside counsel, TPUSA concluded that it found no apparent CSAM content in Company-provided ongoing education materials or guidance documents, such as the DRR referenced in the Forbes article, used in El Paso or Boise. In addition, TPUSA confirmed that it has not received any report through its various internal employee reporting mechanisms alleging that TPUSA’s ongoing education or guidance documents contained apparent CSAM.
In addition to the internal audit, TPUSA engaged a nationally-recognized consulting firm, working at Latham & Watkins’ direction, to assess TPUSA’s compliance with its contractual obligations to the content moderation client. None of the findings from the external assessment were inconsistent with the conclusions from TPUSA’s internal audit that TPUSA did not find CSAM content in Company-provided ongoing education materials or guidance documents.
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