GNI’s Comments on UNESCO’s Guidelines for Regulating Digital Platforms

July 2, 2023  |  News, Policy

Update (July, 2023)

GNI appreciates UNESCO’s efforts to improve the consultation process on the Guidelines.  In our submission on Version 3.0, GNI notes with concern the impression that a number of digital rights groups have expressed that their input, while welcomed, has not been heard or taken seriously. When credible civil society organizations express views – whether during in-person meetings or through written statements – those concerns should be taken seriously, regardless of whether the individuals or groups expressing those concerns have submitted them through the formal channels that UNESCO has established.

Dozens of GNI members have participated in the consultations on these Guidelines. Our engagement stems from our long-standing respect for UNESCO and its role in protecting freedom of opinion and expression globally. GNI hopes that these comments, as well as those of our members, will be taken into account going forward.

Read our comments on Version 3.0

Update (March, 2023)

We are pleased to see that UNESCO has taken seriously the feedback that GNI and other organizations have provided and appreciate the time and effort that has gone into its revised Draft 2.0.

GNI appreciates that UNESCO is providing additional opportunity for feedback on the Draft 2.0 and that it has indicated that it will continue to seek feedback on subsequent drafts. We recognize that Draft 2.0 represents an improvement on the earlier version. Notwithstanding these improvements, a number of the concerns set out in our earlier feedback remain.

Read our comments on Draft 2.0

Read our comments on Draft 1.0

GNI and its members appreciate the opportunity to provided comments to UNESCO on the draft “Guidance for regulating digital platforms: a multistakeholder approach,” which will be featured at the upcoming UNESCO Global Conference: Internet for Trust: Regulating Digital Platforms for Information as a Public Good, Paris, 2023.

Over the years, UNESCO has done important work to empower civil society, establish useful guidance for member states, and build trust with the private sector, and GNI has appreciated opportunities to engage and collaborate with UNESCO on various digital policy initiatives. However, in our submission, we note concerns about the failure of UNESCO to model effective multsitakeholder engagement and policymaking in the production of this guidance to date, and share a set of substantive recommendations in line with the GNI Content Regulation Policy Brief. We call on UNESCO to make significant efforts to ensure that the process for continuing to improve the Guidance, including any follow-up coming out of the Global Summit, is transparent, deliberate, and broadly and meaningfully participatory.

The Global Network Initiative (GNI) is a multistakeholder initiative that brings together 85 prominent academics, civil society organizations, ICT companies, and investors from around the world. Members’ collaboration is rooted in a shared commitment to advancing the GNI Principles on Freedom of Expression and Privacy, which are grounded in international human rights law and the UN Guiding Principles on Business and Human Rights (UNGPs). For over a decade, the GNI Principles and corresponding Implementation Guidelines have guided ICT companies to assess and mitigate risks to freedom of expression and privacy in the face of government laws, restrictions, and demands.