The Make It Safe Campaign, founded by the Government Accountability Project, has recently published long-requested guidelines dealing with intra-group communications. Here they are:

MISC Steering Committee Guidelines

MISC Steering Committee Guidelines, created 3.25.09

History of Coalition: Comprised of many groups whose interests span federal, corporate, environmental, consumer safety, etc. whistleblower protection

The coalition is broken into two levels of involvement:

1. Steering committee. Frequent meetings and updates.
2. Broader coalition of approximately 50 groups that engage in sign-on letters, receive announcements through our MISC listserve, etc. Quarterly meetings and updates.

Establish a steering committee within MISC for consensus and consistent coalition messages. Steering committee meetings will be held on an as-needed basis.

The steering committee must establish;

1. what is our legislative priority within the working group
2. when we represent the coalition and when we don’t: Must clarify in any context, from Hill meetings to media, that unless there was a previous consensus by the steering committee, each individual is speaking in their own capacity or on behalf of their individual organization, but does not represent the coalition

There must be “rules of the road” for how we present ourselves as a coalition v. an organization.

We should try to reach consensus with interested groups in the coalition on specific issues when possible, but again, cannot speak on behalf of entire coalition unless there is a consensus.

The steering committee needs to at least know about other bills or efforts that effect whistleblowers; is there a consensus, does steering committee have a role? Is it conducive, hurtful, or neutral to whistleblower protection?

When Hill meetings are made on behalf of MISC, there must be at least 3 representatives from the steering committee in attendance and one of them is responsible for reporting out to group.

Hill communication should be funneled through the pioneer contact within the steering committee, unless approached by the staff directly.

The MISC listserv is open to all members. Messages must be whistleblower-related and factual. Attacks against individual members or member groups are not tolerated. All listserv messages must undergo a 24-hour steering committee review period to confirm it meets the listserv criteria. Messages from a member of the steering committee must also undergo the 24-hour review period. [Emphasis added.]

These guidelines, supposedly created back in 2009, are very troubling. (There’s no archived copy in the Wayback machine, as far as I can tell, which raises a question about the factual accuracy of the 2009 date…)

What happens if a member submits a comment that, say, exposes the founder’s public statements that contradict each other? Is that an attack? Is it factually accurate? The founder wouldn’t think so, but then again he’d be a judge in his own cause. What’s the appeal process, if any?

What if a member wants to lodge a grievance that the Steering Committee is not acting in the best interests of the coalition? Is that an attack? Who gets to decide what’s factual or “appropriate”?

Also, more basically, why must a comment be approved? Why the prior restraint? It would be unconstitutional if a government agency did it; isn’t it hypocritical to impose that requirement here? What’s the concern, if not to control the flow and content of information?

There are less paranoid ways to minimize unjustified disruption (not all disruption is bad!). Give warnings, give some due process, and then ban anyone who continues to engage in trolling behavior.

Finally, the power to ban comments means that the censors must respond to grievances about their own conduct, in an honest and forthright manner. Otherwise, one can imagine the membership revoking consent and going elsewhere. The principles behind the First Amendment still apply in any bureaucratic context… the desire to be heard, to have one’s grievances redressed… the desire not to be treated like a subject… Ignore these at your peril, MISC.