What is an HRIA?

Verizon Media conducts Human Rights Impact Assessments (HRIAs) to identify circumstances when freedom of expression and privacy may be jeopardized or advanced. Verizon Media conducts short-form HRIAs for specific, targeted questions. When Verizon Media identifies a significant risk to users’ free expression and/or privacy, we undertake a long-form assessment. The long-form HRIA provides a comprehensive background on the business plans, human rights issues, potential risk mitigation strategies, and other relevant information concerning the issue.

When do we conduct HRIA?

There are a variety of circumstances that trigger an HRIA, including:

  • Entry into new markets
  • Launch of new products or services that may impact users’ rights to privacy or free expression
  • Review and revision of internal procedures for responding to government demands for user data or content restrictions in existing markets
  • Data storage decisions
  • Review of the free expression and privacy-related policies, procedures, and activities of potential partners, investments, suppliers, and other third-parties
  • Review of internal processes or mechanisms to enforce policies, such as our terms of service, that may impact users’ rights to privacy or free expression.

How do we conduct HRIA?

The HRIA is the starting point for our ongoing review of the human rights landscape and of Verizon Media’s business plans. HRIAs inform our evolving strategies to promote and protect our users’ rights to free expression and privacy. When we conduct an HRIA, we review a number of factors, including: 

  • The international legal and moral foundations for the rights to freedom of expression and privacy.
  • The general human rights landscape in the relevant country or region, with a particular focus on rule of law, free expression, and privacy.
  • Local laws about free expression and privacy
  • Verizon Media’s business and product plans for entry into the market.
  • The existing and potential benefits of the Internet to the citizens of the relevant region or country.

Based upon what we learn, we identify potential human rights risks and opportunities  that could arise from Verizon Media’s products and operations. We then make recommendations to avoid or mitigate those risks, and to protect our users, and promote human rights with our products and on our platforms.

As part of the HRIA process we also consult with a variety of local and regional experts, including GNI participants, government agencies, human rights organizations, academics, journalists, and other experts.

How does this work in practice?

Yahoo (now part of Verizon Media) pioneered the HRIA process in the tech sector. When Yahoo was considering how to engage responsibly in Vietnam, it conducted a human rights impact assessment. Yahoo reviewed a variety of sources, including reports from the following sources: 

  • Amnesty International
  • Committee to Protect Journalists
  • Economist Intelligence Unit
  • Human Rights Watch
  • Office of the US Trade Representative
  • Reporters Without Borders
  • The Congressional Record
  • University of Minnesota Human Rights Library
  • US Department of State

The Yahoo team met with multiple stakeholders, from bloggers and government officials to human rights activists and journalists, both inside and outside Vietnam. The research and conversations helped Yahoo identify both the human rights opportunity (i.e., while traditional forms of media were heavily censored, expression was much less restricted online and political expression in online spaces was much more robust) and the human rights risk (i.e., there remained a high risk related to government requests for user information or for censorship).

All of the foregoing helped Yahoo tailor its business operations to be as consistent as possible with our corporate human rights commitments. Yahoo decided to manage and operate its Vietnamese language services out of Singapore so the services would be governed by laws with stronger protections than those in Vietnam.

The HRIA also informed Yahoo’s choices about legal structures, internal policies, user terms of service, data access policies, and data location, which were all tailored to protect users and employees.  When issues or questions arise related to such things as the enforcement of our terms of service, we may refer to our HRIAs, which contain information on high-level principles and guidelines, as well as guidance for decision-making.