ARTICLE 19 Tech company responses and the UNGP There is no easy answer to this problem. Nonetheless: The tech sector needs to consider how it can mobilise greater sector-wide action and develop stronger industry standards on human rights. Where the choice is between exiting a country and complying with human rights violations, tech companies should engage in transparent, responsible exit discussions, including clearly and publicly accounting for how they make decisions to stay or leave based on human rights, legal, and commercial considerations. Tech companies should not rely on general references to the importance of staying in a particular market to explain compliance with government demands, as Facebook has sometimes done in Vietnam. This report offers some practical lessons about how tech companies can be most successful in promoting human rights in authoritarian contexts. Tech companies have had some success when presenting organised opposition to data localisation requirements. Industry voices seemed to have an impact on the military in Myanmar withdrawing the draft Cybersecurity Law and on the easing of a data localisation requirement in a proposed Vietnamese regulation. One reason for this is that companies can make a strong economic and commercial case for the harms of data localisation – an argument that authoritarian regimes may be more responsive to. However, tech companies should also speak out more frequently, and collectively, on other issues which raise freedom of expression and privacy concerns. Devoting resources and staff to human rights issues also matters. In Myanmar, Facebook’s past scandals meant that it had developed Myanmar-specific knowledge and staff, and it was relatively better equipped than other companies to respond to the 2021 military coup, although the consistency of its response has been a concern. In contrast, the consequences of inadequate human rights staffing by Facebook in Vietnam, or at least insufficient outreach by this staff to local civil society groups, has meant that it has failed to develop a strong strategy for misuse of its content moderation system by government-linked users. Lack of comprehensive partnership with civil society Finally, this report also highlights the crucial role of civil society. Tech companies are often slow to act until they receive negative publicity. In Myanmar, companies have often removed content because of campaigning by civil society, including eventually even Telegram. In Vietnam, civil society has had to take the lead in reaching out to Facebook to combat abuse 57