INTERNET SHUTDOWNS IN 2023 • Engage in a process of open, meaningful consultation with civil society and other stakeholders to establish alternative strategies and strengthen safeguards for human rights; • Implement effective independent oversight mechanisms to protect human rights and begin the process of rebuilding trust between authorities and communities who have experienced repeated harm from internet shutdowns and other abuses; and • implemented shutdowns but have since discontinued the practice, we applaud your change of course and encourage you to: • Make public commitments to #KeepItOn going forward, including through adoption of binding policies to prevent the use of internet shutdowns at all levels; and • Preserve and facilitate the transmission of crucial evidence of potential human rights violations, including any attacks impacting personnel; • Comply with the UN Guiding Principles on Business and Human Rights and OECD Guidelines to avoid causing or contributing to human rights violations when responding to requests to shut down the internet;316 • Ensure full understanding of the human rights impact of all sanctions compliance decisions, and avoid over-compliance, which may inadvertently undermine the rights of the most vulnerable users;317 • Share detailed information with civil society and other accountability partners when facing threatened or actual disruptions to services, including reasons provided by authorities; • For social media and other communications platforms, take heed of the connection between content governance failures and increasing platform blocks, and strengthen policies and practices accordingly with guidance from civil society and impacted communities;318 • Support collective efforts to prevent, document, and circumvent shutdowns by sharing traffic measurement and other relevant data with the #KeepItOn coalition and other stakeholders; and • Facilitate the export, transfer, and activation of secure connectivity technologies, including alternatives to traditional telecommunications infrastructure, such as mesh networking or satellite internet, as safe and appropriate and in coordination with local actors. Document and share learnings about the importance of leaving the practice behind and promoting reliable, affordable, open, and secure internet access.  Private sector actors should: • the context of internet shutdowns in public human rights policy statements, and establish operational policies and procedures adequately prepared for responding to shutdown requests, even in high-pressure situations; Establish and uphold clear mechanisms for remedy and redress for victims of past human rights violations.  To countries that have previously • 55 Address internet shutdowns in human rights policies, anticipate risks through duediligence processes, and adopt mitigation and transparency measures; • Explore all lawful measures to challenge the implementation of disruptions, and ensure the maximum level of transparency in management of such events; • Include a commitment to preventing and mitigating adverse human rights impacts in 316 OHCHR (2011). UN Guiding Principles on Business and Human Rights. https://www.ohchr.org/Documents/Publications/ GuidingPrinciplesBusinessHR_EN.pdf; OECD (2001). The OECD Guidelines for Multinational Enterprises. https://www.oecd. org/investment/mne/1903291.pdf; Access Now (2023). Tech and conflict: a guide for responsible business conduct. https:// www.accessnow.org/guide/tech-and-conflict-a-guide-for-responsible-business-conduct/; Access Now (2012). Telco Action Plan. https://www.accessnow.org/wp-content/uploads/archive/docs/Telco_Action_Plan.pdf 317 Access Now (2023). When sanctions undermine human rights online. https://www.accessnow.org/sanctionsundermining-human-rights/ 318 Access Now (2022). Content governance in times of crisis: how platforms can protect human rights. https://www. accessnow.org/publication/new-content-governance-in-crises-declaration/; see also supra note 37.

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