Tier 3: Designation
We present here Tier 3 of the TCAP Tiered Alert System: Designation. This policy governs how the TCAP alerts tech platforms to official propaganda produced by terrorist entities designated by selected democratic nations states and supranational institutions.
The scope of Tier 3 (Designation) of the TCAP includes content created by the following entities:
Designated Islamist terrorist organisations (IS including official provinces, al-Qaeda including official affiliates, Tehreek-e-Taliban Pakistan (TTP), Jemmah Islamiyah)
Designated far-right terrorist entities
The pre-requisite for the inclusion of an entity in this tier is to be designated as terrorist by at least one of the following authorities:
- United Nations
- European Union
- United States
- United Kingdom
- New Zealand
The inclusion of these particular authorities is based on a thorough analysis of terrorist designation lists and processes across the globe.(1) The exclusion of other nations’ lists is due to two considerations: firstly, possessing an alternative purpose outside of “terrorism” (e.g. Germany’s list is based on groups being anti-constitutional); and secondly, the strength of the democratic and legal institutions making those decisions. We are aware of setting undue speech norms and want to refrain from doing so, therefore by following the designation lists of democratic nation states and supranational institutions, we ground the TCAP in the rule of law. The designation lists we consult is under constant review and we are considering expanding to include different national lists in the future.
Beyond being designated by one of the stated authorities, we use the following methodology to determine the specific entities we include:
Consensus: We prioritise entities where there is a shared consensus around the entities’ terrorist status (i.e., designation by multiple authorities).
Offline threat assessment: We assess how active the terrorist entity is and the threat it poses. Based on open-source research and consultation with leading experts in the field of counterterrorism.
Online threat assessment: We analyse terrorist entities’ online activity, considering their propaganda outlets, methods of dissemination, audience reach, and incitement to violence. Assessment carried out by our expert Open-Source Intelligence (OSINT) team.
As we expand our inclusion of designated entities based on our growing capacity, we will release blogs explaining our decision making and in reference to the considerations stated above. Existing TCAP entities will be periodically reviewed (every 6 months) to assess whether they still meet the threshold for inclusion. Entities can be de-listed if their status as a terrorist entity has significantly changed, contributing to a significant decrease in their threat (full De-listing Policy below).
Islamist terrorist entities
The TCAP’s initial focus was on official Islamic State (IS) and al-Qaeda (AQ) content. This was due to broad consensus among designating authorities on the terrorist status of these organisations. Therefore, the first iteration of the TCAP included IS and its official provinces, and al-Qaeda and its official affiliates. As the TCAP’s Inclusion Policy expands, designated Islamist terrorist groups not affiliated with AQ and IS will be added to our list.
The areas highlighted in purple show official designations and the areas highlighted in orange show designation by synonym, or umbrella group, or by affiliation.
Far-right terrorist entities
As stated above, the TCAP is grounded in the rule of law and therefore follows the legal designation of far-right terrorist groups and individuals by democratic nation states and supranational institutions. Notably, two designated far-right individuals are included within the TCAP: James Mason and the Christchurch attack perpetrator. However, we include the Christchurch attack perpetrator in the Crisis Tier given we only alert the attacker’s livestream and manifesto (I.e. crisis material). For James Mason, his designation due to his role as a neo-Nazi ideologue rather than as an attack perpetrator enables us to include a broader range of material produced by him. The implications for alerting online content related to an individual such as James Mason are slightly different to an organisation, more details of which can be found in this dedicated blog.
There is less consensus in the designation of far-right entities with most countries’ designation lists heavily skewed towards Islamist terrorist groups.(2) This disparity makes it necessary to be more agile and reactive to far-right designations, considering a far-right entity for inclusion based on a singular designation by a relevant authority. We closely follow the designation of further violent far-right organisations and individuals and will consider newly designated entities for the TCAP as soon as they are legally designated by the above democratic institutions and nation states.
The infographic below summarises which far-right entities are currently designated by these democratic entities, and therefore, included in the TCAP.
Designation under an “alias” (same group/different name)
Terrorist entities are sometimes designated under different names by different authorities. This can be because they are known by multiple names, or they change names despite retaining the same core membership. In these cases, the group will be designated under an alias (e.g. Scottish Dawn/NS131/System Resistance Networks are all proscribed as alias’ for National Action).
- National Action/ Scottish Dawn/ NS131/ System Resistance Network
Designation by affiliation (official affiliates/provinces of designated group)
Some groups are not necessarily designated by name but due to their official affiliation with an umbrella organisation. This is the case with some affiliates of Islamic State. Since central IS is designated by all countries and bodies we consult, as well as propaganda from these provinces being disseminated through central IS propaganda channels, we include all officially recognised IS provinces in the TCAP and identify them by their province names.
- IS Algeria
- IS Central Africa Province (ISCAP)
- IS India
- IS Pakistan
- IS Tunisia
In other situations, a new group can be designated by authorities due to its close affiliation with a previously designated group. This breakaway group which no longer shares operational ties will be designated as a splinter group (e.g. National Socialist Order (NSO) proscribed as a splinter of Atomwaffen Division (AWD) by UK).
Terrorist organisations can be very fluid and split between different factions, leading to new groups with new names emerging. This can make it difficult for designation lists to stay up to date and be responsive to new splinter groups, especially given the slow legal processes they often rely on.
In these circumstances, Tech Against Terrorism may have to rely on its own intelligence assessment to ascertain whether a newly formed group has emerged from a designated one.
Our first step would be to lobby for that group to be designated as a splinter organisation by any relevant authorities. If this approach fails, we will consult with counterterrorism and intelligence experts endeavouring to assess with a high degree of confidence that the new group is run by members of the previous group and retains similar goals and methods that it was designated for. For full transparency, we would then explain our reasoning for including the group in the TCAP as a splinter of a previously designated one.
- National Socialist Order (NSO)
- Hurras al-Din (HAD)
“Imitation Policy”: Use of official terrorist branding
For our purpose of alerting online terrorist content, we will consider all content that uses official branding or claims to be official within scope of the TCAP, when it relates to a designated entity within our Inclusion Policy. This policy is aimed at addressing the non-hierarchical, ephemeral, and transitory nature of many terrorist organisations. We will not distinguish between officially produced and supporter produced propaganda when official branding (such as a logo) is identified, given the content serves the same propaganda purpose of promoting a designated entity. Additionally, we cannot always verify the source of the content and confidently assess whether it is produced by a member of the organisation or a supporter.
The line between official and unofficial content is often blurred, especially for far-right terrorist content. For example, in contrast to the typically centrally produced content produced by al-Qaeda and Islamic State, Atomwaffen Division (AWD) propaganda is often produced by supporters who utilise the brand to glorify the ideology of the group and incite accelerationist violence. The “Imitation Policy” ensures the TCAP captures this type of content, alerting it to tech companies when we find it on their platforms.
In line with the TCAP’s compliance with human rights, a de-listing policy is important for protecting freedom of speech online when an entity’s terrorist status significantly changes. This is consistent with global designation processes we adhere to, most of which have de-listing mechanisms following internal review or external appeal (or both).
Existing TCAP entities will be periodically reviewed (every 6 months) to assess whether they still meet the threshold for inclusion. If an entity is delisted from all designation lists followed by the TCAP, it will also be removed from the TCAP’s Inclusion Policy.
Entities can also be de-listed from the TCAP if their status as a terrorist entity has significantly changed, contributing to a significant decrease in their offline threat. This status should relate to a fundamental shift in the organisational structure of the group into a governmental or quasi-governmental entity. This is likely to shift the incentives of the group away from violence towards governance, and significantly increases the risks of removing official content online. For instance, advising tech companies to remove public service announcements by designated entities relating to COVID-19 or disaster relief is unethical as it will likely affects civilians’ ability to access support. This is not the purpose of the TCAP.
This assessment will consider open-source research and consultation with leading experts in the field of counterterrorism and our own Academic Advisory Board (AAB). It will also be based on the international legitimacy of this status change, to what extent the entity’s new status is recognised by supranational institutions and democratic nations states. Online factors such as a significant reduction in online activity or propaganda output are insufficient for delisting, given the possibility for re-posting of historical content or production of future content. Following a group’s delisting, historical content (all content prior to date of delisting) shall continue to be alerted by the TCAP.
Limitations of designation
The TCAP consults the designation lists of supranational institutions and democratic nations to ensure our alerts are grounded in the rule of law, providing tech companies with a clear legal basis for removal as well as clarity as to what is “terrorist content.” However, we do recognise that reliance on designation is by no means a perfect solution. Aside from the humanitarian and constitutional concerns around designation processes and their offline impact, these legal processes are not currently equipped to respond effectively to the fluidity of the online realm. In particular, designation systems are slow to respond to a rapidly evolving threat picture and are insufficient for tackling the threat of far-right entities as well as lone and non-affiliated terrorist actors.(3)
The TCAP’s tier system is designed to fill these gaps and provide a more balanced and holistic response to terrorist and violent extremist content online. The Tier system will enable the alerting of crisis content relating to lone actors (Tier 2) as well as non-designated far-right terrorist content (Tier 4).
(1) Tech Against Terrorism, Who Designates Terrorism?