Intermediary liability and state surveillance Report Year: 2014 - Communications surveillance in the digital age Authors: Elonnai Hickok Organization: Centre for Internet and Society (CIS) India Website: http://www.cis-india.org
By GIS Watch
Introduction
On 30 June 2014,
The Right to Privacy in the Digital Age: Report of the Office of the United
Nations High Commissioner for Human Rights (OHCHR) was published.1 The Report recognizes the relationship between service providers and surveillance and the
increasing trend of privatised surveillance, noting:
There is strong
evidence of a growing reliance by Governments on the private sector to conduct
and facilitate digital surveillance. On every continent, Governments have used
both formal legal mechanisms and covert methods to gain access to content, as
well as to metadata. This process is increasingly formalized: as
telecommunications service provision shifts from the public sector to the
private sector, there has been a “delegation of law enforcement and quasi-judicial
responsibilities to Internet intermediaries under the guise of
‘self-regulation’ or ‘cooperation’”.2
This report will explore how legal requirements, practices and policies pertaining to intermediary liability are feeding into this growing trend through the incorporation of requirements for intermediaries that facilitate surveillance. In doing so, this report will explore aspects of intermediary liability policies and practices, and how these pertain to and enable state surveillance. Lastly, the report will look at gaps that exist in policies pertaining to privacy, surveillance and intermediary liability.
This report will explore how legal requirements, practices and policies pertaining to intermediary liability are feeding into this growing trend through the incorporation of requirements for intermediaries that facilitate surveillance. In doing so, this report will explore aspects of intermediary liability policies and practices, and how these pertain to and enable state surveillance. Lastly, the report will look at gaps that exist in policies pertaining to privacy, surveillance and intermediary liability.
Map of BlueCoat worldwide deployments in
countries of interest. Basemap: Wikimedia Commons, Creative Commons License / Graphics:
John Scott-Railton & Greg Wiseman
Blue Coat
Devices capable of filtering, censorship, and surveillance are being used
around the world. During several weeks of scanning and validation that ended in
January 2013, Citizenlab uncovered 61 Blue Coat ProxySG devices and 316 Blue
Coat PacketShaper appliances, devices with specific functionality permitting
filtering, censorship, and surveillance.
61 of these Blue
Coat appliances are on public or government networks in countries with a
history of concerns over human rights, surveillance, and censorship (11 ProxySG
and 50 PacketShaper appliances). We found these appliances in the following
locations:
Blue Coat
ProxySG: Egypt, Kuwait, Qatar, Saudi Arabia, the UAE.
PacketShaper:
Afghanistan, Bahrain, China, India, Indonesia, Iraq, Kenya, Kuwait, Lebanon,
Malaysia, Nigeria, Qatar, Russia, Saudi Arabia, South Korea, Singapore,
Thailand, Turkey, and Venezuela.
A summary of
data is available for download in a variety of formats:
GoogleDoc: https://docs.google.com/spreadsheet/pubkey=0AtJqKcMmUwTKdDRkU1BiMHc4UGdPaGtNWndiWm5RaEE&output=html
Excel:
https://citizenlab.org/data/planetbluecoat_data.xlsx
CSV:
https://citizenlab.org/data/planetbluecoat_data.csv
Intermediaries
and Privacy
Online
communications, interactions and transactions are an integral component of our
everyday lives. As such, intermediaries – including, though not limited to,
search engines, social networks, cyber cafés, and internet and
telecommunication service providers – play a critical role with respect to user
privacy. As individuals utilise intermediary platforms on a daily and routine
basis, from searching for information on the internet, to posting updates to a
social media account, to using voice-over-internet-protocol (VoIP) services to
connect with friends and colleagues, or using the services of a cyber café,
intermediaries host, retain and have access to vast amounts of personal data of
their users across the world, irrespective of jurisdiction. In this context,
company practices and a country’s legal regulations have a far-reaching impact
on the rights – specifically privacy and freedom of expression – of both
national and foreign users.
Intermediaries,
governments and surveillance
The Right to
Privacy in the Digital Age also notes that the internet and associated
technologies allow governments to conduct surveillance on an unprecedented
scale. This was highlighted by the revelations by Edward Snowden, which
demonstrated the scope of access that the United States (US) government had to
the data held by internet companies headquartered in the US. The revelations
also underscore the precarious position that companies offering these services
and technologies are placed in. Though the scope and quantity of data collected
and held by an intermediary vary depending on the type of intermediary, the
services offered and the location of its infrastructure, governments have
recognised the important role of intermediaries – particularly in their ability
to assist with state surveillance efforts by providing efficient access to vast
amounts of user data and identifying potentially harmful or threatening
content. Within this, there is a shift from reactive government surveillance
that is based on a request and authorised order, to partially privatised
surveillance, with companies identifying and reporting potential threats,
retaining information, and facilitating access to law enforcement. Indeed, the
OHCHR in the Right to Privacy in the Digital Age notes that the surveillance
revealed by Snowden was facilitated in part by “strategic relationships between
Governments, regulatory control of privacy companies, and commercial
contracts.”3
Intermediary
liability and state surveillance
As described by
the US-based Center for Democracy and Technology,4 intermediary liability
relates to the legal accountability and responsibility that is placed on
intermediaries with respect to the content that is hosted and transmitted via
their networks and platforms. Specifically, intermediary liability addresses
the responsibility of companies with respect to content that is deemed by the
government and/or private parties to be objectionable, unlawful or harmful. The
Center for Democracy and Technology points out that, depending on the
jurisdiction, intermediary liability requirements and provisions can be used to
control illegal content online, but also can be misused to control legal
content as well. As described by UK-based Article 19, provisions relating to
intermediary liability can be broken down into three basic models: strict
liability, where intermediaries are fully liable for third-party content; safe
harbour, where intermediaries can be provided immunity from liability by
meeting defined requirements; and broad immunity, where intermediaries are
given immunity for third party content.5 As pointed out by Frank La Rue in the
Report of the Special Rapporteur on the promotion and protection of the right
to freedom of opinion and expression, legal frameworks that hold intermediaries
(rather than the individual) liable for content, transfer the role of
monitoring the internet to the intermediary.6 Some jurisdictions do not have
specific legal provisions addressing intermediary liability, but do issue court
or executive orders to intermediaries for the restriction of content, as well
as placing obligations – including technical obligations – on service providers
via operating licences.
Legal provisions
and orders pertaining to intermediary liability are not always limited to
removing or disabling pre-defined or specified content. Requests for the
removal of content can be accompanied with requests for user information –
including IP address and basic subscriber information. Some jurisdictions, such
as India, have incorporated retention mandates for removed content and
associated information in legal provisions addressing intermediary liability.7
Other jurisdictions, like China, require service providers to have tracking
software installed on their networks, collect and retain user identification
details, monitor and store user activity, report illegal activity to law
enforcement, and have in place filtering software to restrict access to banned
websites.8
Some
jurisdictions are also recognising that the traditional means of seeking
information from intermediaries are inefficient and often slow – particularly
if the intermediary is foreign, and accessing information requires the
government to follow a Mutual Legal Assistance Treaty (MLAT) process.9 Perhaps
in response to challenges posed by jurisdiction, some governments have sought
“collaborations” with intermediaries to restrict illegal and offensive speech
as well as identify perpetrators of the same. For example, in 2007 in India,
the Mumbai Police negotiated with Google to establish a “direct line of
contact”10 with the company, which, according to news items, would allow access
to IP addresses of users posting “objectionable” content on Google’s social
networking site, Orkut.11 Such collaborations combine elements of intermediary
liability and surveillance, and can be prone to misuse if they lack apparent
oversight, legislative grounding or accountability. In this context,
intermediary liability is not only about content online, but also encompasses
the collection and disclosure of data associated with that content and of users
producing and viewing such content.
Types of content
and surveillance measures
Certain types of
content – namely child pornography/adult content, national/cyber security and
copyright – can attract greater obligations on the intermediary to proactively
facilitate surveillance and in some cases take on the role of law enforcement
or the judiciary. The degree to which such obligations are backed by legal
provisions varies and can range from statutory requirements, to policy
initiatives, to forms of collaboration between governments, intermediaries, and
self-regulatory organization. The types of obligations and measures also vary.
Reporting of
illegal content: Some of these measures are focused on the reporting of illegal
or prohibited content. For example, in the US, by law, service providers must
report to law enforcement any and all information with regards to child
pornography. This is mandated by the Protection of Children from Sexual
Predators Act, 1998.12 Similarly, in India, under the rules defining procedural
safeguards for intermediary liability, intermediaries must report cyber
security incidents and share related information with the Indian Computer
Emergency Response Team.13
Voluntary
disclosure of illegal content and activity: Other measures support the
voluntary disclosure of identified illegal content and activity and associated
information to law enforcement. For example, under the 2002 Cyber Security
Enhancement Act in the US, law enforcement can encourage service providers to
reveal information pertaining to an “emergency matter”. The Act further
provides the service provider immunity from legal action if the disclosure was
made in good faith with the belief that it was a matter of death or serious
physical injury.14
Databases of
repeat offenders: Requirements that governments are seeking to impose on
service providers may also directly conflict with their obligations under
national data protection standards. For example, in the context of proposed
legal requirements for identifying and preventing copyright offenders under the
UK Digital Economy Act, in a public statement, the service provider TalkTalk
noted that the company would be required to maintain a database of repeat
offenders – an action that might be illegal under the UK Data Protection Act.15
As of July 2014, service providers, rights holders and the government have
developed a form of collaboration where rights holders will “track” the IP
addresses of suspected offenders. The addresses will be shared with the
applicable UK service provider, who will then send a series of warning notices
to the user.16 This system is potentially dangerous as it allows for proactive
monitoring of individuals’ IP addresses by private parties (the rights holders)
and then subsequent action by another private entity (the service provider). At
no point does this system define or envision safeguards, accountability or
oversight mechanisms.17
Measures that
facilitate surveillance: Other requirements do not directly impose surveillance
obligations on service providers, but can facilitate surveillance. For example,
in the UK, service providers must now offer broadband filters for “adult
content” automatically switched on. Users who do not wish to have the filter on
are required to “opt out” of the filter.18 These measures can make it easy to
track and identify which user is potentially viewing “adult content”.
Types of
intermediaries and surveillance measures
Depending on
services offered and jurisdiction, intermediaries can be subject to differing
types and scopes of surveillance requirements. For example:
Cyber cafés: In
jurisdictions like India,19 cyber cafés are faced with legal requirements that
can facilitate surveillance – such as the collection and retention of
government-issued user identification, retention of user’s browser history, and
provision of assistance to law enforcement and other authorities when required.
Cyber cafés are also strictly subject to the laws of the jurisdiction of
operation.
Service
providers: Similarly, service providers, even when multinational, must abide by
the laws where they are operating. Unlike intermediaries such as multinational
social networks or search engines, service providers are subject to the
requirements found in operating licences that pertain to intermediary liability
and surveillance. For example, in India, internet and telecommunication service
providers are required to take “necessary measures to prevent objectionable,
obscene, unauthorised, or any other content, messages, or communications
infringing copyright, intellectual property etc. in any form, from being
carried on [their] network, consistent with the established laws of the
country.” Furthermore, if specific instances of infringement are reported by
enforcement agencies, the service provider must disable the content
immediately.20 In the case of India, requirements for the provision of
technical assistance in surveillance and retention of call detail records21 and
subscriber information are also included in the operating licences for service
providers.22
Social networks:
Social networks such as LinkedIn, Facebook and Twitter – which are often
multinational companies – are not necessarily subject to the legal intermediary
liability requirements of multiple jurisdictions, but they are frequently faced
with requests and orders for user information and removal of content requests.
To address these pressures, some companies filter content on a country basis.
In June 2014 LinkedIn was criticised in the media for complying with orders
from the Chinese government and filtering content in the region.23 Similarly,
Twitter was criticised by civil society for withholding content in Russia and
Pakistan in May 2014, though in June 2014 the company reversed its decision and
reinstated the withheld content.24 Social media platforms are also frequently
and increasingly used by law enforcement and the state for collecting “open
source intelligence”.25
Technology,
intermediary liability and state surveillance
When
intermediaries implement legal requirements for the blocking or filtering of
content, they do so by employing different techniques and technologies such as
key word filtering software, firewalls, image scanning, URL databases,
technologies that enable deep packet inspection, etc.26 Similarly, complying
with legal mandates for interception or monitoring of communications also
requires intermediaries to install and use technology on their networks. As
pointed out by La Rue, technologies used for filtering also facilitate
monitoring and surveillance as they have the ability to identify and track
words, images, websites and types of content, as well as identify individuals
using, producing or associated with the same.27 For example, YouTube offers
copyright holders the option of YouTube’s “Content ID” system to manage and
identify their content on the platform. Actions that copyright owners can
choose from include muting audio that matches the music of copyrighted
material, blocking a video from being viewed, running ads against a video, and
tracking the viewer statistics of the video. These options can be implemented
at a country-specific level.28
Removing the
service provider from surveillance
While some
governments are placing obligations on intermediaries to assist with
surveillance, other governments are removing such obligations from service
providers through surveillance measures that seek to bypass service providers and
allow governments and security agencies to directly intercept and access
information on communication networks, or measures that require service
providers to allow security agencies a direct line into their networks. For
example, India is in the process of implementing the Central Monitoring System,
which is envisioned to allow security agencies to directly intercept
communications without the assistance of service providers. Though this system
removes obligations on service providers to assist and be involved in specific
instances of surveillance, it also removes a potential safeguard – where
service providers can challenge or question extralegal or informal requests for
surveillance. In the 2014 Vodafone Law Enforcement Disclosure Report, the
company notes that in select countries, law enforcement and authorities have
direct access to communications stored on networks.29
The question of
jurisdiction
 |
| Cairo Protest, Fomeel.com via Creative Commons |
Jurisdiction and
the applicability of local law is a tension that arises in the context of
intermediary liability and surveillance. Some facets of this tension include:
to what extent do legal restrictions on content apply to multinational
platforms operating in a country? To what extent can states access the
communications passing or being stored in its territory? And to what extent do
domestic protections of fundamental rights – including freedom of expression
and privacy – apply to foreigners as well as nationals? The OHCHR in The Right
to Privacy in the Digital Age shed some light on these questions, drawing upon
a number of international instruments and firmly asserting that any
interference with the right to privacy must comply with the principles of legality,
proportionality and necessity, regardless of the nationality or location of the
individual.30 Tensions around mass surveillance of foreign citizens and
political leaders, and a lack of legal constructs domestically and
internationally to address these tensions, have led to questions of direction
and the future of internet governance – discussed at forums like NET mundial,
where principles relating to surveillance and intermediary liability were
raised.31 Similarly, in March 2014, the US announced plans to relinquish the
responsibility of overseeing the body tasked with regulating internet codes and
numbering systems. This move has raised concerns about a backlash that could
result in the division and separation of the internet, facilitating mass surveillance
and content control.32
State
surveillance and intermediary liability: The impact on the user and the role of
the company
Government-initiated
content restrictions and surveillance of individuals’ online communications,
transactions and interactions have widely been recognised as having a negative
impact on users’ right to privacy and a chilling effect on freedom of speech.
Depending on the target and reasons, such actions by governments can have
deeper human rights implications – if, for example, dissenting voices,
activists and journalists are targeted. The gravity and clear human rights
implications of actions related to intermediary liability and surveillance
highlight the complexity of these issues. Numerous cases exist of individuals
being identified and persecuted for speech shared or communicated online, and
the identification of these individuals being facilitated by internet
companies. For example, Yahoo! has been heavily criticised in the international
media for providing the Chinese government in 2006 with user account details
and the content of communications of political dissident and journalist Shi Tao
– allowing police to identify and locate Shi and subsequently imprison him for
ten years.33 Instances such as the Shi Tao case demonstrate the complexity of
issues related to intermediary liability and surveillance and raise questions
about reasonable expectations regarding internet company practices and
responses (particularly multinational companies), adequate national
legislation, international guidelines, and appropriate public response. As
noted in The Right to Privacy in the Digital Age, “the Guiding Principles on
Business and Human Rights, endorsed by the Human Rights Council in 2011,
provide a global standard for preventing and addressing adverse effects on
human rights linked to business activity. The responsibility to respect human
rights applies throughout a company’s global operations regardless of where its
users are located, and exists independently of whether the State meets its own
human rights obligations.” This is a high standard that intermediaries must
adhere to. Some companies such as Google,34Facebook,35 Twitter,36 Vodafone,37
Microsoft,38 Yahoo39 and Verizon40 have begun to shed light on the amount of
surveillance and content requests that they are subject to through transparency
reports. Companies like Vodafone,41 Facebook42 and Twitter43 also have policies
in place for addressing requests from law enforcement.
Conclusions
As demonstrated
above, there is significant overlap between intermediary liability, privacy and
surveillance. Yet jurisdictions have addressed these issues separately – often
having independent legislation for data protection/privacy, intermediary
liability and surveillance. The result is that the present legal frameworks for
intermediary liability, privacy and surveillance are governed by models that do
not necessarily “speak to each other”. When requirements that facilitate
surveillance are embedded in provisions and practices pertaining to intermediary
liability, there is a risk that these requirements can omit key safeguards to
surveillance that have been recognized as critical at the international level,
including necessity, proportionality, legality and legitimate aim. As La Rue
stressed, and as emphasized in other international reports and forums, there is
a need for governments to review, update and strengthen laws and legal
standards addressing state surveillance. Ideally such a review would also
include legal standards for intermediary liability.
Where
multi-stakeholder44 and multilateral45 dialogues are resulting in incremental
and slow progress, some decisions by the Court of Justice of the European Union
and European Parliament are calling attention and efforts to the issue.46
References:
References:
1 www.ohchr.org/EN/HRBodies/HRC/RegularSessions/Session27/Documents/A.HRC.27.37_en.pdf
2 Ibid.
3 Ibid.
4
https://cdt.org
5 Article 19.
(2013). Internet Intermediaries: Dilemma of liability. London: Article 19.
www.article19.org/data/files/Intermediaries_ENGLISH.pdf
6 Frank La Rue,
Report of the Special Rapporteur on the promotion and protection of the right
to freedom of opinion and expression, United Nations General Assembly, 17 April
2013.www.ohchr.org/Documents/HRBodies/HRCouncil/RegularSession/Session23/A.HRC.23.40_EN.pdf
7 The
Information Technology (Intermediaries Guidelines) Rules, 2011, Rule 3(4).
deity.gov.in/sites/upload_files/dit/files/GSR314E_10511(1).pdf
8 Frydnamm, B.,
Hennebel, L., & Lewkowicz, G. (2007). Public Strategies for Internet
Co-Regulation in the United States, Europe, and China. Brussels: Université
Libre de Bruxelles. www.philodroit.be/IMG/pdf/BF-LH-GL-WP2007-6.pdf
9 Mutual Legal
Assistance Treaties are formal agreements reached between governments to
facilitate cooperation in solving and responding to crimes. A critique of the
MLAT process has been that it is slow and inefficient, making it a sub-optimal
choice for governments when faced with crimes that demand immediate response.
For more information see: Kindle, B. (2012, February 14). MLATS are powerful
weapons in financial crime combat, even for private sector. Association of
Certified Financial Crime Specialists.
www.acfcs.org/mlats-are-powerful-weapons-in-counter-financial-crime-combat-even-for-private-sector
Some intermediaries, such as Facebook, have specified that foreign governments
seeking user account data must do so through the MLAT process or letters of
rogatory. For more information see:
https://en-gb.facebook.com/safety/groups/law/guidelines
10 Pahwa, N.
(2007, March 14). Updated: Orkut to Share Offender Data With Mumbai Police;
Google’s Clarification. Gigaom.
gigaom.com/2007/03/14/419-updated-orkut-to-share-offender-data-with-mumbai-police-googles-clarifi
11 Chowdhury, S.
(2014, July 30). Mumbai Police tie up with Orkut to nail offenders. The Indian
Express.
archive.indianexpress.com/news/mumbai-police-tie-up-with-orkut-to-nail-offenders/25427
12 Frydnamm, B.,
Hennebel, L., & Lewkowicz, G. (2007). Op. cit.
13 Information
Technology (Intermediaries Guidelines) Rules 2011, Rule 9.
deity.gov.in/sites/upload_files/dit/files/GSR314E_10511(1).pdf
14 Frydnamm, B.,
Hennebel, L., & Lewkowicz, G. (2007). Op. cit.
15 Jackson, M.
(2014, July 19). Update: UK ISPs Agree Voluntary Internet Piracy Warning
Letters Scheme. ISPreview.
www.ispreview.co.uk/index.php/2014/07/big-uk-isps-agree-voluntary-internet-piracy-warning-letters-scheme.html
16 Ibid.
17 Jackson, M.
(2013, August 9). UK Government to Finally Repeal ISP Website Blocking Powers.
ISPreview. www.ispreview.co.uk/index.php/2013/08/uk-government-to-finally-repeal-isp-website-blocking-powers.html
18 Miller, J.
(2014, July 23). New broadband users shun UK porn filters, Ofcom finds. BBC.
www.bbc.com/news/technology-28440067
19 Information
Technology (Guidelines for Cyber Cafe) Rules 2011, Rule 4, Rule 5, Rule 7.
ddpolice.gov.in/downloads/miscelleneous/cyber-cafe-rules.pdf
20 Licence
Agreement for Provision of Unified Access Services After Migration from CMTS,
Section 40.3. www.auspi.in/policies/UASL.pdf
21 Call record
details consist of information about a subscriber’s use of mobile and broadband
networks and can include: called numbers, subscriber name and address, date and
time of the start and end of a communication, type of service used (SMS, etc.),
international mobile subscriber identity, international mobile equipment
identity, location details. For more information see: Afentis Forensics,
“Telephone Evidence: Mobile telephone forensic examinations, Billing Records,
Cell Site Analysis. afentis.com/telephone-evidence
22 Licence
Agreement for Provision of Unified Access Services After Migration from CMTS,
Section 41.10. www.auspi.in/policies/UASL.pdf
23 Mozur, P.
(2014, June 4). LinkedIn Said it Would Censor in China. Now That It Is, Some
Users are Unhappy. The Wall Street Journal.
blogs.wsj.com/chinarealtime/2014/06/04/linkedin-said-it-would-censor-in-china-now-it-is-and-some-users-are-unhappy
24 Galperin, E.,
& York, J. (2014, June 23). Twitter Reverses Decision to Censor Content in
Pakistan. Electronic Frontier Foundation.
https://www.eff.org/deeplinks/2014/06/twitter-reverses-decision-censor-content-pakistan
25 Open source
intelligence has been widely recognised as an essential tool for law
enforcement and security agencies. Open source intelligence is derived from
information that is publicly available from sources such as the internet,
traditional media, journals, photos, and geospatial information. For more
information see: Central Intelligence Agency. (2010, July 23). INTellingence:
Open Source Intelligence. Central Intelligence Agency.
https://www.cia.gov/news-information/featured-story-archive/2010-featured-story-archive/open-source-intelligence.html
26 Bloxx. (n/d).
Whitepaper: Understanding Web Filtering Technologies.
www.bloxx.com/downloads/US/bloxx_whitepaper_webfilter_us.pdf
27 Frank La Rue,
Report of the Special Rapporteur on the promotion and protection of the right
to freedom of opinion and expression, United Nations General Assembly, 17 April
2013.www.ohchr.org/Documents/HRBodies/HRCouncil/RegularSession/Session23/A.HRC.23.40_EN.pdf
28 YouTube, “How
Content ID Works”. https://support.google.com/youtube/answer/2797370?hl=en
29 www.vodafone.com/content/sustainabilityreport/2014/index/operating_responsibly/privacy_and_security/law_enforcement.html
30 Report of the
Office of the United Nations High Commissioner for Human Rights: The Right to
Privacy in the Digital Age, 30 June 2014.www.ohchr.org/EN/HRBodies/HRC/RegularSessions/Session27/Documents/A.HRC.27.37_en.pdf
31 Powles, J.
(2014, April 28). Big Business was the winner at NETmundial. wired.co.uk.
www.wired.co.uk/news/archive/2014-04/28/internet-diplomacy-netmundial
32 Kelion, L.
(2014, April 23). Future of the Internet Debated at NetMundial in Brazil. BBC.
www.bbc.com/news/technology-27108869
33 MacKinnon, R.
(2007). Shi Tao, Yahoo!, and the lessons for corporate social responsibility.
rconversation.blogs.com/YahooShiTaoLessons.pdf
34 Google
Transparency Report. www.google.com/transparencyreport
35 Facebook
Global Government Requests Report.
https://www.facebook.com/about/government_requests
36 Twitter
Transparency Report. https://transparency.twitter.com
37 Vodafone Disclosure
to Law Enforcement Report.
www.vodafone.com/content/sustainabilityreport/2014/index/operating_responsibly/privacy_and_security/law_enforcement.html
38 Microsoft’s
Law Enforcement Request Report.
www.microsoft.com/about/corporatecitizenship/en-us/reporting/transparency
39 Yahoo
Transparency Report. https://transparency.yahoo.com
40 Verizon’s
Transparency Report for the first half of 2014. transparency.verizon.com
41 Vodafone,
Human Rights and Law Enforcement: An Overview of Vodafone’s policy on privacy,
human rights, and law enforcement assistance.
www.vodafone.com/content/index/about/about-us/privacy/human_rights.html
42 Facebook,
Information for Law Enforcement.
https://www.facebook.com/safety/groups/law/guidelines/
43 Twitter
Guidelines for Law Enforcement.
https://support.twitter.com/articles/41949-guidelines-for-law-enforcement
44 Powles, J.
(2014, April 28). Op. cit.
45 RT. (2013,
October 26). Germany, Brazil enlist 19 more countries for anti-NSA UN
resolution. RT. rt.com/news/nsa-un-resolution-talks-788
46 Powles, J.
(2014, April 28). Op. cit.
_______________________________________________________
This report was
originally published as part of a larger compilation: “Global Information
Society wach 2014: Communications surveillance in the digital age” which can be
downloaded from
http://www.giswatch.org/2014-communications-surveillance-digital-age.
Creative Commons
Attribution 3.0 Licence ‹creativecommons.org/licenses/by-nc-nd/3.0› Some rights
reserved by the Original Publisher
Publication Details
ISSN: 2225-4625, ISBN:
978-92-95102-16-3, APC-201408-CIPP-R-EN-DIGITAL-207
