Australian disinformation code of practice strengthened with independent oversight and public complaints facility

Monday October 11, 2021: Today, the Digital Industry Group Inc. (DIGI) bolstered the governance of The Australian Code of Practice on Disinformation and Misinformation with independent oversight and a facility for the public to report breaches by signatories of their code commitments.

Under the code, signatories must commit to safeguards to protect against online disinformation and misinformation, including publishing and implementing policies on their approach, and providing a way for their users to report content that may violate those policies. Every signatory commits to producing an annual transparency report documenting their efforts under the code’s commitments, the first set of which were released publicly in May.

DIGI, the industry association that developed the code, has appointed an independent Complaints Sub-Committee to resolve complaints about possible breaches by signatories of their code commitments, and a portal on its website for the public to raise such complaints. The independent members of that sub-committee are Dr Anne Kruger, Victoria Rubensohn AM and Christopher Zinn (bios below).

These independent members will also work with signatories, through an Administration Sub-Committee, to oversee the various actions taken by signatories to meet their obligations under the code.

In addition, DIGI has appointed an independent expert to fact check and attest signatories’ annual transparency reports going forward under the code, in order to incentivise best practice and compliance. Hal Crawford will assume this role (bio below).

On the introduction of the governance arrangement, DIGI Managing Director Sunita Bose said: “Especially in a pandemic, we can increasingly all agree that combating misinformation to protect public health and democracy is essential.

“The Australian Code of Practice on Disinformation and Misinformation provides a strong framework for continued technology industry action and transparency on these complex challenges, and we wanted to further strengthen it with independent oversight from experts, and public accountability.”

Through the new complaints portal, DIGI will accept complaints from the Australian public where they believe a signatory has breached the code’s commitments. DIGI will not be able to accept complaints about individual items of content on signatories’ products or services, which should be directed to the signatory via their reporting mechanisms or otherwise. The code requires all signatories to have such reporting mechanisms.

Self-regulatory codes of practice developed by industry associations are used in a range of industries, including the media, advertising and telecommunications. As the code developer, DIGI acts as secretary on this Complaints Sub-Committee, but has no vote on decisions regarding complaints brought to it, in order to avoid conflicts of interest as an industry association.

The code has already been signed by Apple, Adobe, Facebook, Google, Microsoft, Redbubble, TikTok and Twitter, and DIGI encourages other technology companies to adopt it. The code was developed in response to Australian Government policy announced in December 2019, where the digital industry was asked to develop a voluntary code of practice on disinformation.

DIGI developed this code with assistance from the University of Technology Sydney’s Centre for Media Transition, and First Draft, a global organisation that specialises in helping societies overcome false and misleading information, and with input from the overseeing regulator the ACMA and the public through a consultation process.

More information about The Australian Code of Practice of Disinformation and Misinformation, including the new governance arrangements, is at Bios of the independent experts are included below. For more information, email

Bios of independent experts involved in the governance of the The Australian Code of Practice of Disinformation and Misinformation:

Dr Anne Kruger

Dr Anne Kruger sits on the Complaints Sub-Committee and the Administration Sub-Committee. Anne launched the Australian and now Asia Pacific bureau of First Draft, a global organisation that specialises in helping societies overcome false and misleading information. Throughout 2020, the APAC bureau’s investigations formed the backbone of analysis reports by a wide range of high profile outlets such as the New York Times, Washington Post, NBC, South China Morning Post, and across the ABC in Australia. Anne is co-chief investigator at the University of Technology Sydney’s Centre for Media Transition which, together with First Draft, assisted DIGI with the development of its disinformation industry code. She has a PhD in social media verification education, has established verification and media literacy programs internationally including with UNESCO. Anne was previously a journalist and presenter at CNN Hong Kong during SARS, Bloomberg and ABC TV.

Victoria Rubensohn AM

Victoria Rubensohn AM sits on the Complaints Sub-Committee and the Administration Sub-Committee. She has extensive experience in media and communications regulation in Australia and overseas, and with codes of practice in broadcasting, telecommunications, content classification and advertising. Victoria is currently Consumer Director of Communications Compliance Ltd and Principal of Omni Media. From 2011 to late 2020, Victoria was an Independent Reviewer for Ad Standards Australia; From 2015 to 2019, she was a Consumer Member of the Code Authority of ADMA; and from 2009 to 2015, she was Convenor of the Classification Review Board.  Victoria has chaired federal government policy review committees on copyright convergence and digital radio. From 1994 to 2009, Victoria chaired the Telephone Information Services Standards Council regulating value-added telecommunications services. She is a Director of the Australian Communications Consumer Action Network (ACCAN), the Centre for Inclusive Design, chair of the Communications Law Centre Ltd and is an Advisory Board Member of the Centre For Media Transition at UTS. She also serves on the advisory committee of the International Institute of Communications Australian Chapter, and was formerly President of the Communications and Media Law Association and Chair of the National Film and Sound Archive.

Christopher Zinn

Christopher Zinn sits on the Complaints Sub-Committee and the Administration Sub-Committee. He has led various successful and disruptive campaigns to help consumers make better decisions in complex markets such as energy, private health insurance and financial services. Christopher heads the initiative, is the CEO of the Private Health Insurance Intermediaries Association, sits on the statutory authority reforming the funeral industry, and is on a self-regulatory code committee for the charitable sector. He was also director of communications and campaigns for consumer group CHOICE and has been a reporter and producer for TV, radio and newspapers both in Australia and overseas including the ABC, the Daily Telegraph, Channel Nine, and the UK Guardian.

Hal Crawford

Hal Crawford is the independent reviewer. Hal is a news executive and consultant with 25 years’ experience in digital and broadcast media, and currently runs Crawford Media Consulting. He was recently the News Director at one of New Zealand’s biggest newsrooms, Newshub, managing news and current affairs on TV, online and radio platforms. Hal was previously Editor-in-chief at ninemsn, and a non-executive director of youth content publisher Pedestrian. Hal is currently chair of the Advisory Board for the Centre for Media Transition at UTS, and has made other contributions to industry and regulatory frameworks for broadcast and digital media. Hal was the co-founder of a social media news sharing project, Sharewars, which gathered and analysed content data from the world’s biggest news publishers. He co-authored the book All Your Friends Like This, published by HarperCollins in 2015, about social media and news.