Curtailing Free Expression, Opinion and Information Online in Southeast Asia Information Security, which was presented to the United Nations’ SecretaryGeneral by Member States of the SCO in 2011 and then in 2015 in updated form, did not refer to the right to privacy at all and focuses on national security and preserving State “sovereignty”.104 The FOC’s ‘Recommendations for Freedom Online’ (also known as the ‘Tallinn Agenda’) affirms that the “same rights that people have offline must also be protected online” and signals the commitment of its 30 Member States to “adopt and encourage policies and practices, nationally and internationally, that promote the protection of human rights. ” However, it fails to draw clear links between international legal standards –including the obligations on States – and the realization of these commitments.105 Proposals developed by private ICT sector companies, including for example, Microsoft, Siemens, Nornickel and Google, and by academic coalitions or think-tanks, such as the Global Commission on the Stability of Cyberspace and the Bright Internet Agenda, proposing norms governing information security and protection against cyber-attacks face similar limitations.106 International efforts to negotiate normative standards governing cybersecurity have been fragmented and inconsistent. A fundamental challenge is the difference of interpretation between States about the application of international human rights and humanitarian law to cybersecurity and cyber conflicts.107 At the UN level, two separate mechanisms currently exist, working in parallel on the regulation of cyberspace within the context of international security, led by States with different visions – the United States and the Russian Federation.108 104 105 106 107 108 Tajikistan and Uzbekistan to the United Nations addressed to the Secretary-General’, 13 January 2015, UN Doc. A/69/723, Available at: https://regmedia.co.uk/2015/02/04/un-internet-security13jan15.pdf; Freedom Online Coalition, ‘An Internet Free and Secure’, Available at: https:// freeandsecure.online/about/; Global Forum on Cyber Expertise, ‘About the GFCE’, Available at: https://www.thegfce.com/about Sarah McKune, ‘An Analysis of the International Code of Conduct for Information Security’, The Citizen Lab, 28 September 2015, Available at: https://citizenlab.ca/2015/09/international-code-ofconduct/ FOC, ‘Recommendations for Freedom Online’, 28 April 2014, Available at: https:// freedomonlinecoalition.com/wp-content/uploads/2014/04/FOC-recommendations-consensus.pdf Eneken Tikk and Mika Kerttunen, ‘The Alleged Demise of the UN GGE: An Autopsy and Eulogy’, Cyber Policy Institute, 2017 (‘Tikk and Kerttunen, 2017’), p5, Available at: https://cpi.ee/wpcontent/uploads/2017/12/2017-Tikk-Kerttunen-Demise-of-the-UN-GGE-2017-12-17-ET.pdf Tikk and Kerttunen, 2017, pp. 10, 11, 16, 17; Deborah Brown, ‘UN General Assembly adopts record number of resolutions on internet governance and policy: Mixed outcomes for human rights online’, Association for Progressive Communications, 10 January 2019 (‘APC, 10 January 2019’), Available at: https://www.apc.org/en/news/un-general-assembly-adopts-record-numberresolutions-internet-governance-and-policy-mixed Disagreement in the UN General Assembly’s First Committee focusing on disarmament and international security in the cyber sphere led to the United States and Russia putting forth two separate resolutions – the US-led resolution mandated the creation of a new GGE to continue the GGE process “to study, with a view to promoting common understandings and effective implementation, possible cooperative measures to address existing and potential threats in the 37