23 Jan 2023

GPD provides comments on UNESCO content regulation guidance

GPD has provided comments on UNESCO’s “Guidance on Regulating Digital Platforms: a multistakeholder approach”, a document which aims to provide high-level guidance to states and other relevant stakeholders considering how to regulate online content. The development of this guidance document is part of a broader UNESCO initiative: “Internet for Trust: Regulating Digital Platforms for Information as a Public Good”.

GPD recognises the potential value of such a document in guiding stakeholders. But, based on our analysis, we believe that there are aspects of the document that should be modified to better reflect a rights based-approach and mitigate risks to human rights.

In our submission, we provide specific comments on the content of the guidance. We also set out several overarching recommendations on how UNESCO should approach the ongoing development of this guidance, in terms of both process and substance:

  • That UNESCO extend the consultation process for the development of this guidance document and develop a more robust plan for stakeholder engagement to ensure that participation in the process is open, inclusive and transparent.
  • That the text of the guidance document provide more explicit references to existing relevant frameworks and guidance.
  • That UNESCO coordinate with existing bodies and initiatives that are already committed to developing standards for the regulation of online content from a human rights perspective. This should involve outreach efforts with key partners, bodies and initiatives to reinforce the legitimacy of the guidance document as a UN-based tool which builds on and expands upon other efforts at the global, regional and national levels.


Next steps

The current consultation period ended on 20 January 2023, and further discussion and development of the guidance document will take place at the UNESCO Global Conference in February 2023.

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