[IRPCoalition] Council of Europe's Internet Governance Strategy 2016-19

Adamantia Rachovitsa adamantia.rachovitsa at gmail.com
Fri Dec 4 20:52:34 EET 2015

Dear Catherine,

thank you for this.

If I may, a few comments for my part:

1. Para. 16: I am surprised that the document does not mention at all the
Internet Engineering Task Force as a key stakeholder to engage with.

2. Para. 9: Everybody agrees on criminalising cyberbullying/ harassment
online? There is a huge debate at the moment on these issues. Could we add
at least a note of caution?

3. "Prioritising online safety and security for all" as a Strategic
Objective: Prioritising these over what?
My main concern with this draft (following up your last comment too) is
that it articulates a very specific narrative (see also paras 11 (b), 13).
This is a narrative of "human rights online v. security" which is neither
technically correct nor accurately reflects the human rights paradigm. I
agree that the document should make it clear that we need to balance the
different concerns and interests involved. Furthermore, as the Special
Rapporteur on Freedom of Expression, the technical community and many
scholars have stressed, privacy and security are not necessarily
conflicting concepts online. In many instances, privacy is a precondition
for ensuring the users' security and, hence, directly relevant to the
discussion on protecting cybersecurity and national security. The
relationship between human rights and security is much richer and complex
to making a binary choice (or even a balancing exercise).The Strategy is
not informed by basic technical understanding of the Internet's features
and functions. Perhaps we can stress the need for implementing the
Strategy's objectives on the basis of a sound understanding of how the
internet works and active collaboration with the technical community.

With kind regards,

Dr Adamantia Rachovitsa

Ph.D (Nottingham)

Assistant Professor of International Law

Founder & Secretary - ILA Qatari Branch

2015-2016 Fellow UC Berkeley - Centre for Technology, Society & Policy

College of Law | Qatar University | P.O. Box: 2713 Doha – Qatar

Tel.: (+974) 4403 6519 | Fax: (+974) 4403 5253

E-mail: rachovitsa at qu.edu.qa

On 4 December 2015 at 20:20, Easton, Catherine <c.easton at lancaster.ac.uk>

> Dear all,
> Due to the IRPC's observer status in relation to the Council of Europe's
> Steering Committee on Media and Information Society, we have been asked to
> comment on the new draft of their Internet Governance Strategy (attached).
> I have drafted a short statement on this below but would appreciate input
> from the wider membership.  The deadline is tight and we would need to
> finalise this by Monday.  Please could you post your comments and I
> will draw them together in a final submission.
> Many thanks,
> Catherine
> Response:
> IRPC Comment on the Council of Europe Steering Committee on Media and
> Information Society’s Internet Governance Strategy
> The strategy is effectively embedded within existing human rights
> instruments.  It accepts that internet governance requires the
> co-operation of numerous stakeholders.  The decision to place a strong
> emphasis on ensuring that the Internet is people-centred is particularly
> praiseworthy.
> In relation to the development of a “Magna Carta” for the Internet, the
> IRPC would like to draw your attention to the Charter of Human Rights and
> Principles for the Internet:
> http://internetrightsandprinciples.org/site/charter/  This was developed
> using a multi-stakeholder approach and has been referenced in a number of
> legal and policy instruments.
> In relation to prioritising online safety and security for all, the
> measures outlined are clear and strategic but reference should be made at
> this point to the need to balance freedom of expression with targeted
> measures to address online security.  This section would be improved with
> a statement of the need for a proportionate response to online threats.  This
> would sit well with the statement’s initial focus on democracy and
> upholding human rights.
> _______________________________________________
> IRP mailing list
> IRP at lists.internetrightsandprinciples.org
> https://lists.internetrightsandprinciples.org/mailman/listinfo/irp
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