The Global Principles on
Protection of Freedom ofExpression and Privacy

The Global Principles on Protection of Freedom of Expression and Privacy

2017

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The Global Principles on Protection of Freedom of Expression and Privacy

Table of contents
Introduction ................................................................................................................................... 4
Preamble ........................................................................................................................................ 6
Definitions of key terms ................................................................................................................. 8
Section 1: General principles ........................................................................................................ 11
Principle 1: Legal framework for the protection of rights ................................................................. 11
Principle 2: Limited scope of permissible restrictions ....................................................................... 12
Principle 3: Legitimate purpose of privacy causes of action .............................................................. 12
Section 2: Freedom of expression and the right to privacy as mutually reinforcing rights ............. 14
Principle 4: Communications surveillance ......................................................................................... 14
Principle 5: Mandatory data retention .............................................................................................. 14
Principle 6: Anonymity, mandatory user registration and real-name requirements ........................ 14
Principle 7: Encryption ....................................................................................................................... 15
Principle 8: Data disclosure by companies ........................................................................................ 16
Principle 9: Protection of sources ...................................................................................................... 16
Principle 10: Search and seizure ........................................................................................................ 17
Principle 11: Trans-border data flows ............................................................................................... 17
Section 3: Reconciling the right to freedom of expression and the right to privacy ....................... 18
Principle 12: Publication of personal information ............................................................................. 18
Principle 13: Public figures................................................................................................................. 19
Principle 14: Open justice .................................................................................................................. 20
Section 4: Reconciling freedom of expression, data protection and privacy .................................. 21
Principle 15: Protection of publicly available information................................................................. 21
Principle 16: Requests to delete content authored and originally published by oneself .................. 21
Principle 17: Requests to delete content published by third parties ................................................ 22
Principle 18: Requests to be de-listed from search results ............................................................... 22
Principle 19: Data protection exemptions ......................................................................................... 24
Section 5: Reconciling the right to information, data protection and the right to privacy .............. 25
Principle 20: General principles on the right to information ............................................................. 25
Principle 21: Maximum disclosure of personal information about public officials ........................... 25
Principle 22: Official records .............................................................................................................. 25
Section 6: Remedies and sanctions ............................................................................................... 27
Principle 23: General principles ......................................................................................................... 27
Principle 24: Criminal penalties ......................................................................................................... 27
Principle 25: Pecuniary awards .......................................................................................................... 27
Principle 26: Prior restraint, super injunctions, mandatory pre-moderation and notice prior to
publication ......................................................................................................................................... 28
Principle 27: Interim injunctions ........................................................................................................ 28
Principle 28: Blocking injunctions ...................................................................................................... 29
Principle 29: Intermediary liability and content removal .................................................................. 29
Principle 30: Blanket prohibitions on Internet access on grounds of privacy protection .................. 29
Background .................................................................................................................................. 30

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The Global Principles on Protection of Freedom of Expression and Privacy

Introduction
Freedom of expression and privacy are mutually reinforcing rights – all the more so in the digital age.
Both are essential foundations for open and democratic societies, and among the basic conditions for
its progress, and for each individual’s self-fulfilment. For democracy, accountability and good
governance to thrive, freedom of expression and opinion must be respected and protected. The
same is true of the right to privacy, which also acts as a powerful bulwark against state and corporate
power in the modern age.
While freedom of expression is fundamental to diverse cultural expression, creativity and innovation
as well as the development of one’s personality through self-expression, the right to privacy isessential to ensuring individuals’ autonomy, facilitating the development of their sense of self andenabling them to forge relationships with others.
Privacy is also a pre-requisite to the meaningful exercise of freedom of expression, particularly
online. Without privacy, individuals lack the space to think and speak without intrusion and todevelop their own voice. Without freedom of expression, individuals would be unable to develop
their sense of self. At the heart of the protection of these rights lies the respect for, and protectionof, human dignity and individuals’ ability to live freely and engage with one another.
At the same time, one person’s right to freedom of expression may impinge on someone else’s rightto privacy and vice versa. This tension is exacerbated by digital technologies. Whilst they have been
central to the facilitation of the exercise of freedom of expression and the sharing of information,
digital technologies have also greatly increased the opportunity for violations of the right to privacy
on a scale not previously imaginable. In particular, digital technologies present serious challenges tothe enforcement of the right to privacy and related rights because personal information can becollected and made available across borders on an unprecedented scale and at minimal cost for bothcompanies and states. At the same time, the application of data protection laws and other measures
to protect the right to privacy can have a disproportionate impact on the legitimate exercise of
freedom of expression.
These Principles were developed in order to provide a systematic analytical framework for assessing
the ways in which the rights to freedom of expression and privacy are mutually reinforcing, and for
determining the permissible limits which can be placed on these rights where they are in conflict,both on and offline. In particular, the Principles seek to ensure that both of these fundamental rights
are effectively respected and protected in the digital age. As we demonstrate in these Principles,international law provides a framework to resolve tensions and maximise the enjoyment of bothrights. The Principles we set out here offer a progressive interpretation of international law and bestpractice in individual states, as reflected, inter alia, in national laws and the judgments of national
courts. They should be interpreted in the most favourable way for human rights.
These Principles should neither be taken as foreclosing nor as approving restrictions designed toprotect other interests – including the protection of reputation by defamation laws – which deserve
separate treatment and are addressed in their entirety in a separate set of principles.
It is our intention and hope that these Principles will be used by individuals, activists, campaigners,
legal practitioners, intermediaries, judges, elected representatives, parliamentarians, and public

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The Global Principles on Protection of Freedom of Expression and Privacy

officials around the world as they seek to respect, protect, and fulfil the rights to freedom of
expression and privacy.

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The Global Principles on Protection of Freedom of Expression and Privacy

Preamble
We – individuals and organisations – who endorse and agree to these Principles
Affirming that the rights to freedom of expression and to privacy are among the essential
foundations of an open and democratic society, and among the basic conditions for its progress andfor the enjoyment of other human rights and fundamental freedoms;
Considering that the protection of the right to privacy is a necessary pre-condition for the meaningful
exercise of the right to freedom of expression and human development;
Noting that individuals are much more likely to express controversial viewpoints or share sensitive
information in the knowledge that their anonymity and the privacy and security of theircommunications are protected, including through the use of anonymity, encryption, and othersecurity tools;
Fully aware that the right to freedom of expression is also a necessary component of thedevelopment of individuals’ personality and identity;
Considering that the rights to freedom of expression and privacy are therefore often mutually
reinforcing rights;
Taking note, however, that the right to freedom of expression and the right to privacy may in certain
circumstances come into conflict, including where privacy claims may be used without justification toprevent the dissemination of information about individuals in order to restrict reporting on mattersof public interest and to avoid public scrutiny, or deliberately mislead others;
Recognising at the same time that the dissemination of private information without justification may
seriously infringe the right to privacy, particularly that of persons in situations of vulnerability;
Desiring to promote a clear framework for the protection and promotion of both the rights tofreedom of expression and privacy where they are in conflict, especially online;
Taking into account the relevant provisions of the Universal Declaration of Human Rights, theInternational Covenant on Civil and Political Rights, the African Charter on Human and Peoples’
Rights, the American Convention on Human Rights, the European Convention on Human Rights andthe EU Charter of Fundamental Rights and Freedoms;
Having regard to the UN Guiding Principles on Business and Human Rights (Ruggie Principles), theOECD Guidelines on the Protection of Privacy and Transborder Flows of Personal Data, theInternational Principles on the Application of Human Rights to Communications Surveillance (The
Necessary and Proportionate Principles), the Johannesburg Principles on National Security, Freedomof Expression and Access to Information, the Global Principles on National Security and the Right toInformation (Tshwane Principles), the Revised Defining Defamation: Principles on the Freedom ofExpression and the Protection of Reputation, the Manila Principles on Intermediary Liability and the
Joint Declaration on Freedom of Expression and the Internet of the UN Special Rapporteur on
Freedom of Opinion and Expression, OSCE Representative on Freedom of the Media, OAS Special

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The Global Principles on Protection of Freedom of Expression and Privacy

Rapporteur on Freedom of Expression and ACHPR Special Rapporteur on Freedom of Expression andAccess to Information on 1 June 2011;
Noting that nothing in these Principles should be interpreted as setting a lower threshold for theprotection of the rights to freedom of expression and privacy than that provided by relevantinternational and regional instruments;
Bearing in mind that the dissemination of, and access to, information is a basic requirement to foster
accountability and a society free of corruption, to promote access to knowledge, development andculture, which is the common heritage of all humankind, and which should be cherished, upheld, andmade accessible for the benefit of all;
Recognising that the Internet is a global resource which should be managed in the public interest andthat digital technologies have greatly enhanced freedom of expression and access to informationwhilst, at the same time, posing great challenges to the protection of individuals’ right to privacy andto the protection of personal data;
Concerned about the serious risks big data poses to the right to privacy and to the protection of
personal data, while noting the potential benefits of opening large data sets for society as a whole;
Considering that data protection is essential to ensure that individuals are involved in decisions
concerning their personal data and to ensure that states and companies that gather and record
personal data are transparent about the data they hold; follow fair and lawful processes on thecollection, use, retention and maintenance of security of that data; and ensure that personal datacollected for one purpose is not used for another;
Aware that data protection legislation can be misused or abused to prevent, end or restrict thelegitimate public dissemination of accurate personal information in order to enable individuals tocontrol their reputation at the expense of freedom of information, the right to truth and the wider
public interest;
Call on all appropriate bodies at international, regional, national and local levels and on private
actors, to endorse, promote, respect, and apply these Principles in their policies and practices. We
also recommend that they give effect to these Principles and engage in their dissemination,
acceptance, and implementation at all levels.

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Definitions of key terms
For the purposes of these Principles,a)

The term confidential information means any information to which a “duty of confidence”
applies. A duty of confidence is created when:i.

Private information has been passed or disclosed in such a way that the person receiving
the information knew, or ought to have known, that the information was being
imparted on the basis of confidentiality; orii. When private information has been disclosed in circumstances where it is reasonable toexpect that the information will be held in confidence.
Confidential information must not be used or disclosed without the explicit consent of theindividual concerned, absent a specific legal basis, or absent a robust public interest or legal
justification to do so;b)

The term data controller means the natural or legal person which, alone or jointly with otherpersons, determines the purposes for which, and the manner in which, any personal data
are, or are to be, processed;c)

The term data protection rights refers to the range of rights that individuals (data subjects)
possess under data protection law. Data protect rights include but are not limited to the:i.

Right to ensure that data is stored and processed lawfully (on the basis of consent orsome other lawful basis laid down by law), fairly and securely;ii. Right to know what personal data is held about them by controllers (right of access) andfor what purpose;iii. Right to seek to correct that data when it is inaccurate (right of rectification);
iv. Right to demand that data be deleted when it is no longer necessary for the permitted
purpose, when it is irrelevant or out-of-date, when consent has been withdrawn andthere is no other lawful basis, when the data has been unlawfully processed, or when it
has been made public without justification (right to erasure);
v. Right to receive one’s personal data from a data controller for the purpose of changing aservice (data portability); andvi. Right to object to the processing of data for particular purposes, including for direct
marketing and profiling, where certain conditions apply (right to object).

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The Global Principles on Protection of Freedom of Expression and Privacyd)

The term informed consent in the context of data protection means an individual’s freely
given agreement (not obtained under duress, coercion, or by fraud), based on adequate
knowledge and understanding of information relevant to the processing of his/her personal
data. The individual giving consent must be informed about the purpose of the datacollection, processing or use of the data, and the consequences of a refusal to give consent if
necessary or if the individual so requests. The consent must be referenced to a clearly
determined processing; to the extent sensitive personal data are concerned the consent
obtained must refer explicitly to such sensitive personal data;e)

The term journalism refers to the function of regularly or professionally engaging in thecollection and dissemination of information to the public via any means of masscommunication. It involves but is not limited to the collection (research, interviews or
freedom of information requests) and production (including writing, data analysis, andverifying material) of information. It can also include editorial, publication or broadcast
activities, and management of standards (including staff training, management, andsupervision);f)

The term personal data means any information relating to an identified or identifiable
natural person; an identifiable natural person is one who can be identified directly or
indirectly, in particular by reference to an identifier or to one or more factors specific to his
or her physical, physiological, mental, economic, cultural, or social identity;g)

The term principle of maximum disclosure refers to a presumption that all information heldby public bodies should be subject to disclosure and that this presumption may be overcome
only in very limited circumstances;h)

The term public interest encompasses matters in which the public has an interest or concernof being informed. This includes, but is by no means limited to, information about mattersthat affect the functioning of the state, public officials and public figures, politics, publichealth and safety, law enforcement and the administration of justice, the protection ofhuman rights, consumer and social interests, the environment, economic issues, the exercise
of power, art and culture, or matters that affect general interests or entail major
consequences;i)

The term public figure means an individual engaged in public life. It includes leaders of statesand elected representatives, public officials, business leaders, people in the public eye whohave a platform as a result (including “celebrities”) or individuals engaged in a public interest
activity or performing a public function;j)

The term public authority means any natural or legal person exercising administrative
authority, or holding public responsibilities or functions, or providing public services, or
operating with substantial public funds for public matters;k)

The term request to be de-listed means a remedy that enables individuals to request to bede-listed from search results produced on the basis of a search term which includes theirname. This remedy has been derived from the “right to erasure” under data protection law
by some international and domestic courts and is sometimes inaccurately referred to as “theright to be forgotten”;

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The Global Principles on Protection of Freedom of Expression and Privacyl)

The term right to truth means the right to seek, receive and impart information about humanrights violations. It is a collective right drawing upon history, recent or current events toprevent violations from recurring in the future. Its corollary is a “duty to remember”, which
the state must assume, in order to guard against the perversions of history that go under thenames of revisionism or negationism. States have a corresponding obligation to facilitate theuncovering of information about human rights violations, whether past or present,
particularly where violations have occurred on a large, systematic scale and entire societies
need to come to terms with the events which occurred;m)

The term sensitive personal data means personal data consisting of information relating to
the data subject with regard to racial or ethnic origin; political opinions; religious beliefs orother beliefs of a similar nature; trade union membership and membership in otherassociations; physical or mental health or condition; sexual life, sexual orientation, gender
identity or expression; genetic data; biometric data for the purpose of uniquely identifying anatural person; the commission or alleged commission by the data subject of any offence; orany proceedings for any offence committed, or alleged to have been committed, by the data
subject, the disposal of such proceedings or the sentence of any court in such proceedings;n)

The term search engines refers to software programs that use sophisticated algorithms toretrieve data, files or documents from a database or network in response to a query. The
information retrieved is usually indexed and presented as a series of hyperlinks on a
webpage;o)

The term social media platforms refers to platforms the distinctive feature of which is thatthey encourage individuals to connect and interact with other users and to share content;p)

The term substantial harm means actual, or substantial risk of, physical harm, severe mental
distress or anguish, loss of, or detriment to, employment. Mere embarrassment or
discomfort and potential loss of business or job prospects are not sufficient to qualify as
substantial harm;q)

The term web hosting providers or hosts refers to bodies (typically companies) that rent web
server space to enable their customers to set up their own websites;r)

The term persons in situations of vulnerability is used to describe persons whose particularsocial location in society more broadly and within the community renders them at aparticularly high risk of physical or emotional harm. Persons in situations of vulnerability
include, but are not limited to, children, elderly, persons with disabilities, the recently
bereaved, the seriously ill or persons who face discrimination based on their gender, or
sexual orientation or gender identity.

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Section 1: General principles
Principle 1: Legal framework for the protection of rights

States should ensure that the right to freedom of opinion and expression, the right to informationand the right to privacy are enshrined in domestic constitutional provisions or their equivalent, in
accordance with international human rights law. Domestic legislation should include that everyone
has:a)The right to freedom of expression, which includes the freedom to seek, receive and impart
information and ideas of all kinds, regardless of frontiers, either orally, in writing or in print,
in the form of art, or through any other media or other platforms of his or her choice. The
right to freedom of expression includes the right to offend, criticise, comment or talk aboutothers, including on aspects of their private life, which are either private or known to the
public, without their consent;b)

The right to hold an opinion without interference or limitations as defined under Principle 2;c)

The right to information, which includes the right of everyone to seek, receive, use, andimpart information held by or on behalf of public authorities, or to which public authorities
are entitled by law to have access, and information held by private bodies exercising public
functions and required for the exercise or protection of any right or fundamental freedom;d)

The right to privacy, which includes the right of individuals to respect for their private andfamily life, home, and communications and the right to the protection of the law against
arbitrary or unlawful interference or attacks against them. The right to private life extends toaspects relating to personal identity, such as a person’s name, images, or physical and moral
integrity; it is primarily intended to ensure the development, without outside interference, ofthe personality of each individual in his/her relations with other human beings;1e)

The right to personal data protection, which may be derived from, and be related to, theright to privacy; and which regulates the way in which information about individuals, which
may be either private or public, is collected, processed, stored and retained electronically byboth public and private bodies. Personal data must be processed lawfully and fairly forspecified purposes and on the basis of the informed consent of the person concerned, orsome other legitimate basis laid down by law. Without prejudice to the applicability of dataprotection rights under this Principle, personal information may be processed without theconsent of the individual if the information is publicly available. Everyone should have theright of access to data held by third parties (data controllers) concerning him or her, and theright to have it rectified or deleted, subject to legitimate exceptions.

1

This provision should not be used to prevent states providing full protection of rights as provided for by Article 18 of theInternational Covenant on Civil and Political Rights.

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Principle 2: Limited scope of permissible restrictions
2.1.

States should ensure that domestic constitutional or legal provisions clearly set out the scopeof permissible restrictions on the rights and freedoms set forth in these Principles. Statesshould provide that such restrictions may only be justified if they are:a) Provided by law: any restriction must have a formal basis in law, which is accessible andformulated with sufficient precision to enable individuals to foresee whether a particularaction is in breach of the law and to assess the likely consequences of any breach;b) In pursuit of a legitimate aim: any restriction must be shown by the state to have thegenuine purpose and demonstrable effect of protecting a legitimate aim recognised underinternational law, which includes the rights and freedom of others;c) Necessary and proportionate in pursuance of a legitimate aim: any restriction is necessary
and proportionate in a democratic society if it is the least restrictive means available forprotecting that interest; andd) Restrictions on the right to hold an opinion (as provided for in Principle 1b) are neverpermitted.

2.2.

States should ensure that domestic legislation provides for sufficient safeguards andremedies against abuse, including prompt, full and effective scrutiny, by an independent
court, tribunal or other independent adjudicatory body of the validity of the restriction.

2.3.

States must not merely abstain from interfering with the rights and freedoms set forth inthese Principles, they also have positive obligations to protect them, including frominterference by third parties.

2.4.

Private actors should respect the rights and freedoms set forth in these Principles, including
the limited scope of permissible restrictions on them as provided herein.

Principle 3: Legitimate purpose of privacy causes of action
States should recognise and give effect to the following:a)Laws providing for privacy offences and/or torts may constitute legitimate restrictions on theright to freedom of expression if they are sufficiently clear and narrowly defined and theirgenuine purpose and demonstrable effect is to protect individuals from unlawfulinterferences in, or attacks on, their right to private and family life, home andcommunications;b)

Laws protecting individuals from substantial harm, including but not limited to harassment,
threats of violence, the malicious disclosure or distribution of private sexual content(including photographs or films), or malicious disclosure of sensitive personal information or
personal information other than a person’s name or other identifier without consent canconstitute a legitimate restriction on the right to freedom of expression provided that they
are narrowly drawn, contain sufficient defences for the protection of freedom of expression
and do not impose disproportionate sanctions;

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The Global Principles on Protection of Freedom of Expression and Privacyc)Laws providing for privacy offences and/or torts cannot be justified if their purpose is merely
to protect individuals against harm to a reputation which they either do not have or do not
merit. In particular, privacy offences or torts cannot be justified if their purpose or effect is toprevent legitimate criticism of public figures, the exposure of corruption, official wrongdoing,or to protect the reputation of heads of state or other public officials or public figures;d)Laws providing for privacy offences or torts cannot be justified on the grounds that they help
maintain public order, national security, or friendly relations with foreign states orgovernments.

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Section 2: Freedom of expression and the rightto privacy as mutually reinforcing rights
Principle 4: Communications surveillance
4.1.

The indiscriminate and untargeted collection, storage and analysis of digital and traditional
communications or communications data without specific, individual reasonable suspicion(“mass surveillance”) by state and non-state actors impinges on the very essence of the rightto privacy. It also has a chilling effect on the exercise of the right to freedom of expression
and the right to hold and form an opinion by searching and accessing and disseminating
information online. As such, mass surveillance is always a disproportionate interference withthe rights to privacy and freedom of expression.

4.2.

States should ensure that their legislation, practices, and procedures regarding thesurveillance of communications comply with the International Principles on the Applicationof Human Rights to Online Communications Surveillance.

Principle 5: Mandatory data retention

Mandatory retention laws – requiring Internet and telecommunications service providers tocontinuously collect and preserve the content of users’ communications, communications data as
well as information about users’ online activities and identity – significantly interfere with the rights
to freedom of expression and privacy. States should ensure that their data retention regimes andschemes fully comply with standards set forth in these Principles taking into consideration thefollowing:a)

General and indiscriminate mandatory retention measures are a disproportionate restriction
on the rights to privacy and freedom of expression and should be abolished; andb)Targeted retention measures should only be imposed where they are necessary for the
purpose of fighting serious crime, where the categories of data to be retained and theretention period is limited to what is strictly necessary, and where they are accompanied bysafeguards against abuse.

Principle 6: Anonymity, mandatory user registration and real-name requirements
6.1.

Everyone should have a right to exercise his/her right to freedom of expression
anonymously, which includes through anonymous speech, to read anonymously or to accessinformation in online and physical environments anonymously.

6.2.

There should be a presumption in favour of exercising this right. States should repeal:a) Blanket prohibitions on anonymity as these are unnecessary and disproportionate
restrictions on the rights to privacy and freedom of expression;b) Laws, regulations and policies requiring the registration of real names or otheridentifiable information or imposing the registration of devices and connections as a pre-ARTICLE 19 – Free Word Centre, 60 Farringdon Rd, London EC1R 3GA – www.article19.org – +44 20 7324 2500
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requisite for access to the Internet or Internet services, as these constitute a violation of
the rights to freedom of expression and privacy.
6.3.

Service providers should ensure that their users can communicate anonymously, and thus
refrain from imposing real-name policies or requiring the registration of other identifiable
information on their platforms, as such requirements severely undermine the rights tofreedom of expression and privacy.

Principle 7: Encryption
7.1.

Everyone should have a right to use secure communication tools, in particular any hardware
and software encryption products and other cryptographic methods of their choice.

7.2.

States should recognise in their legislation and practices that encryption is a basic
requirement for the protection of the confidentiality and integrity of information and that, assuch, it is essential to the protection of the rights to privacy and freedom of expression
online.

7.3.

States and companies should promote end-to-end encryption of communications as thebasic standard for the protection of the right to privacy online. They should also promoteprivacy by design in technical standards and company products.

7.4.

States should promote digital literacy (the set of enabling skills that are required to use
digital technology) in the use of encryption tools and promote the use of open source
software, including by ensuring that it is regularly and independently maintained and audited
for vulnerabilities, including by civil society experts.

7.5.

States should refrain from adopting or repeal all legislation that prohibits individuals fromusing encryption or prohibits companies from including encryption in their systems andproducts.

7.6.

States should refrain from adopting measures requiring or promoting technicalvulnerabilities (“backdoors”) to be installed in hardware and/or software encryption
products as a disproportionate restriction on the right to privacy and a disproportionate formof compelled expression.

7.7.

States should repeal or refrain from adopting laws requiring the disclosure of decryption
keys. Court-ordered decryption of encrypted data or devices (as opposed to disclosure ofdecryption keys) may only be permissible when it results from transparent and publicly
accessible laws applied solely on a targeted, case-by-case basis to individuals responsible forthe encryption and only when subject to judicial warrant and respect for due process rights
of individuals, including the right against self-incrimination.

7.8.

States should refrain from adopting laws establishing key escrow systems.

7.9.

States should lift import/export restrictions on encryption hardware and software.

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Principle 8: Data disclosure by companies
8.1.

Service providers should only be required to disclose personal information about their users
subject to a court order, which must be in line with the requirements of legality, legitimate
aim, necessity, and proportionality under international human rights law.

8.2.

Service providers should notify their users that access to their personal data has been soughtby state authorities or third parties except in cases where non-disclosure has been
specifically ordered by a court for a limited period of time because disclosure would create areal risk of harm to another individual or would allow individual suspects to destroy evidence
and seriously jeopardise an investigation.

8.3.

Service providers should publish transparency reports with specific information about all
requests and/or orders for disclosure of personal data they receive from states, courts, andprivate parties. This should also include information about actions taken by the company onsuch requests or orders.

8.4.

Consistent with Principle 8.3, states should repeal laws, regulations and policies prohibiting
service providers from publishing transparency reports on data requests or communications
surveillance.

Principle 9: Protection of sources
9.1.

The right to freedom of expression implies that everyone who obtains information from
confidential sources with a view to exercising a journalistic activity has, subject to Principles
9.2 a) and b), a duty not to disclose the identity of their confidential sources and a right not
to be required to do so.

9.2.

States should provide for the protection of the confidentiality of sources in their legislationand ensure that:a) Any restriction on the right to protection of sources complies with the three-part test
under international human rights law, as set out in Principle 2;b) The confidentiality of sources should only be lifted in exceptional circumstances and only
by a court order, which complies with the requirements of a legitimate aim, necessity,and proportionality. The same protections should apply to access to journalistic material;c) The right not to disclose the identity of sources and the protection of journalistic material
requires that the privacy and security of the communications of anyone engaged injournalistic activity, including access to their communications data and metadata, must be
protected. Circumventions, such as secret surveillance or analysis of communications data
not authorised by judicial authorities according to clear and narrow legal rules, must not
be used to undermine source confidentiality; andd) Any court order under 9.2 b) and c) must only be granted after a fair hearing where
sufficient notice has been given to the journalist in question, except in genuine
emergencies.

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Principle 10: Search and seizure

Access to, and search and seizure of, information represents a significant interference with the rightto privacy and freedom of expression. States should take immediate steps to ensure that measuresregulating access to, search and seizure of, information fully comply with the following conditions:a)Access to, and search and seizure of information is only justified if the measures strictly
comply with the requirements of legality, legitimate aim, necessity, and proportionality;b)

Search of individuals’ home or workplace, online accounts, remote data storage, collection of
metadata and any seizure of information may only be compatible with the rights to freedomof expression and privacy if ordered by a court and if strictly compliant with therequirements of legality, legitimate aim, necessity, and proportionality under international
human rights law;c)

In determining whether the search or seizure of information is necessary and proportionate,special weight must be given to the confidentiality of sources, journalistic material, andprivileged information in appropriate cases; andd)General search and seizure warrants, which are not narrowly drawn and based on reasonablesuspicion are inherently disproportionate.

Principle 11: Trans-border data flows
11.1.

The meaningful exercise of the right to freedom of expression requires that the right toprivacy and personal data protection be strongly protected, including in legal agreements fordata flows. In order to ensure a consistent level of protection of personal data, the dataprotection principles set forth in Section 1 and Section 2 must also apply to data transfers
between companies and states.

11.2.

In data transfer agreements, states should ensure that the applicable law is the one
providing the highest protection for personal data. The level of data protection applicable toan individual’s personal data must not be lowered because of the data being transferred.

11.3.

All states should adopt data protection laws. Any data localisation laws should ensure strong
privacy protections and include limits on access and data retention as set out in Principles 5
and 8.

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Section 3: Reconciling the right to freedom of
expression and the right to privacy
Principle 12: Publication of personal information

National legal systems should make it clear, either explicitly or through authoritative interpretation,that in the context of the publication of personal information in the news media (including printpress and broadcasting) and other platforms:a)When seeking to reconcile the right to freedom of expression and the right to privacy,
particularly in cases involving the publication of personal information, public authorities, thecourts or other independent adjudicatory bodies should give regard to all the circumstancesof the case, including the following factors:i.

The extent to which the publication at issue contributes to a debate of public interest
as defined in the Key Definitions;ii.

The degree of notoriety or vulnerability of the person affected;iii.

The subject covered by the publication and the extent of the private nature of theinformation at issue;iv.

The prior conduct of the person concerned;v.

Content, form, and consequences of the publication, including the sarcastic, humorous
or satirical tone used by the author of the publication and the extent to which theharm suffered as a result of the publication of private information has interfered withhis or her private life so as to undermine his or her personal integrity;vi.

The way in which the information was obtained and whether this is consistent with
Principles 12 b) and 12 c);vii.

The intent of the individual or entity disseminating the information at issue, and inparticular whether it was malicious; andviii. The extent to which the individual whose privacy is at issue is a public figure, as per
Principle 13.
b)

Where the published material includes photographs, video footage or sound recordings,
regard should be had to the circumstances in which the materials were obtained, including,inter alia:
i. Whether the individual concerned voluntarily took, or consented to the taking, use ordissemination of the photograph, video footage or sound recording;ii.

Whether the individual consented to the use, disclosure or dissemination of thematerial;

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The Global Principles on Protection of Freedom of Expression and Privacy

c)

iii.

Whether the material was obtained without the individual’s knowledge or was
obtained by subterfuge or other illicit means;iv.

The nature and seriousness of the intrusion bearing in mind that images and soundrecordings are particularly sensitive personal information, as they reveal a person’s
unique characteristics; andv.

Any measures taken to minimise the intrusion into the individual’s privacy.

The use of privacy-invasive investigating techniques, such as hidden cameras, drones,“hacking”, undercover reporting or subterfuge, for the purposes of journalism, should only
be permitted in circumstances where:
i.

There is an overriding public interest in the dissemination of the information sought or
discovered;ii. Such information could not be obtained by any other less privacy-intrusive means; andiii. Efforts have been made to address privacy concerns by, inter alia, blurring the face of
the individual/s concerned, editing out information of a private nature or otherwise
minimising the intrusion into the individual/s’ privacy.

Principle 13: Public figures
13.1.

National legal systems should make it clear, either explicitly or through authoritativeinterpretation, that open and free debate on matters of public interest is at the very core of ademocratic society. Public figures, especially heads of state, elected representatives,
individuals with a role in public life, exercising a public function or otherwise engaged inpublic activities, inevitably and knowingly lay themselves open to close scrutiny by bothjournalists and the public. They therefore have a lower expectation of privacy than ordinary
individuals or lesser public officials in relation to matters of public interest.

13.2.

The public interest may extend to aspects of their private life as it relates to, or affects, their
public role but does not include purely private matters in which the interest of members of
the public is, if any, merely salacious or sensational.

13.3

A person (“celebrity”) who does not carry out a public function may still be considered to bea public figure for the purposes of Principle 13, if they are a public figure by virtue of theirnotoriety; or if they draw benefit from being in the public eye and are able to disseminate
their views through the media as a result of their being in the public eye.

13.4.

The more significant a public figure is, especially in relation to their being an elected
representative or to exercising any public function, the more they should be subject to, andtolerant of, the highest levels of scrutiny in accordance with the principles of democratic
pluralism.

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Principle 14: Open justice
14.1.

States should guarantee in their national legislation, and protect and promote in theirpractices, the principle of open justice or publicity of all judicial actions. This principle
demands that the public have a right to know the identity of the parties involved in court
proceedings, including suspects in criminal investigations, defendants and witnesses incriminal proceedings, and private parties in civil proceedings; it also implies that court
hearings must be held in public and that filming, recording, broadcasting, using social media,
and the taking of photographs should be permitted during court proceedings.

14.2.

Restrictions on Principle 14.1, including anonymity orders, hearings held in private and banson the filming, broadcasting, the use of social media or taking of photographs in certain typesof proceedings, should only be permitted by an independent court and can only be justified
in exceptional circumstances, including:a) Where the need to protect victims, witnesses, defendants or their close family members
from a real and substantial risk of physical violence or other tangible harm clearly
outweighs the free expression rights of individuals to report on court proceedings;b) Where the need to protect the welfare of children or other persons in situations ofvulnerability, including their right to privacy, outweighs the public interest in open
justice;c) Where identifying one of the parties would inevitably lead to the unjustified ordisproportionate disclosure of confidential information;d) Where publicity would defeat the object of the hearing, bearing in mind that thesensibilities of the parties involved are no basis for exclusion of the public from judicial
proceedings;e) Where the subject matter of the case involves discussion of justifiably confidential
information of one of the parties and a public hearing would undermine that
confidentiality; andf)Where this is required by the interests of justice, for example to prevent prejudice tojudicial proceedings.

14.3.

Video recording of court proceedings should comply with data protection principles andshould take place so as not to disturb the hearing.

14.4.

The fact that the public may misinterpret or act inappropriately as a result of court reporting,however accurate, cannot justify a ban on publication of such reports by the press or the
public at large.

14.5

In circumstances where some degree of confidentiality is required, it is preferable – where
possible – to achieve this through contestable orders (“reporting restrictions”) made on
notice to the media, rather than by holding hearings in camera.

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Section 4: Reconciling freedom of expression,
data protection and privacy
Principle 15: Protection of publicly available information
15.1.

Once information becomes publicly available, the presumption is that it must remain
accessible in the public domain indefinitely. The presumption in this Principle does not
extinguish any claim for breach of the right to privacy or the application of data protection
principles.

15.2.

Notwithstanding Principle 15.1, access to publicly available information may be restrictedsubject to the strict three-part test laid down in Principle 2.

15.3.

There should be a presumption that personal information published by an individual about
themselves on public platforms, including on social media platforms in which privacy settings
have been set to public, may easily become publicly available and that there is therefore acorrespondingly low expectation of privacy in respect of such information.

15.4.

Companies should have an obligation to make privacy protections clear and easily
understandable and ensure that individuals are given adequate control over the information
they want to make public and the information they want to keep private or limited to adefined group online. Companies should not change privacy settings unless it is to provide ahigher protection of privacy and they should proactively inform their users of any changes toprivacy settings.

Principle 16: Requests to delete content authored and originally published by oneself
16.1.

There should be a presumption that the right to freedom of expression includes the right not
to speak, to change one’s opinion and to delete, or to request a hosting provider or third
party to delete, content authored and originally published by oneself, including online.

16.2.

Principle 16.1 does not apply to content authored by others and hosted or published by third
parties about oneself.

16.3.

In deciding whether a request for the deletion of content authored and originally publishedby oneself should be granted by hosts and third parties, regard should be had to thefollowing factors:a) Whether the request has been made by a child, or a young person;b) Whether the request has been made by a person in a situation of vulnerability;c) Whether the request has been made by someone who was a child, a young person or aperson in a situation of vulnerability at the time the content in question was authored or
published;d) Whether the content represents that person’s own authorship;

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The Global Principles on Protection of Freedom of Expression and Privacye) Whether the person making the request is a public figure or was at the time the content
was authored or published;f)

Whether the content at issue is in the public interest; andg) Whether it is necessary and proportionate to remove the content taking into
consideration all the circumstances of the case.

Principle 17: Requests to delete content published by third parties
17.1.

Hosts and third parties should not be required to delete or otherwise remove content
containing personal information published by third parties on the basis of national dataprotection laws or the so-called “right to be forgotten”.

17.2.

Hosts may only be required to delete content containing personal information published bythird parties where the publication of the information by a third party constituted an
unlawful act, such as it related to privacy offences or offences such as harassment, threats ofviolence or malicious disclosure or distribution of personal information or private sexual
content (such as photographs or films). In determining whether a request for the deletion ofcontent containing private information published by third parties should be granted, regard
should be had to Principle 17 and the factors set out in Principles 12 and 13.

17.3.

Any deletion or removal of content on any basis must comply with the Manila Principles on
Intermediary Liability.

Principle 18: Requests to be de-listed from search results
18.1.

To the extent that a so-called “right to be forgotten” is recognised in some jurisdictions,states should ensure that any such “right” is limited to the right of individuals under dataprotection law to request search engines to delist inaccurate or out-of-date search results
produced on the basis of a search for their name.

18.2.

As a matter of principle, de-listing requests should be subject to ultimate adjudication by the
courts or independent adjudicatory bodies with relevant expertise in freedom of expression
and data protection law. As the same time, search engines are more likely to be the first portof call for such requests. Therefore, it is vital that both parties have the right of appeal to anindependent and impartial court or adjudicatory body in disputed cases.

18.3.

In determining whether or not to grant a de-listing request, the courts or other independent
adjudicatory bodies should address themselves to the following non-exhaustive list offactors:a) Whether the information is personal information;b) Whether the claimant or plaintiff had a reasonable expectation of privacy with respect tothe information, having regard to his or her prior conduct, whether consent had been
given, and the prior existence of the information in the public domain;

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The Global Principles on Protection of Freedom of Expression and Privacyc) Whether the information is in the public interest, as defined in the Key Definitions;d) Whether the information at issue pertains to a public figure, as set forth in Principle 13;e) Whether the information is part of the public record, in particular whether the material
at issue has been published or recorded for journalistic, artistic, literary, or academic
purposes or has been published by the government in discharge of a legal obligation to
make personal data publicly available;f)

In cases where the information at issue is of a public nature or has been made publicwith the consent of the claimant or plaintiff, whether the claimant or plaintiff has
demonstrated substantial harm as a result of the availability of search results linked totheir name;g) How recent the information is and whether it retains public interest value, having regard
to the fact that the more recent the information, the more likely it is to be of public
interest value, and that certain types of information may retain public interest value
indefinitely;h) Whether alternative remedies, such as seeking voluntary deletion of the content fromany third party publisher, a right to reply or a defamation claim would be more
appropriate; and whether such remedies should have been exhausted first or instead;i)

Whether granting a request to be de-listed is a proportionate restriction on the right tofreedom of expression, having regard to all the circumstances of the case.

18.4.

De-listing orders must be limited in scope to the domain name corresponding to the country
where the right is recognised and where the individual concerned has established substantial
damage.

18.5.

Any de-listing of content on the basis of national data protection laws must apply the Manila
Principles on Intermediary Liability and include the following procedural safeguards:a) Data publishers should be notified and have a right to challenge de-listing requests;b) Data publishers and search engines should have a right of appeal against de-listingorders.

18.6.

Consistent with Principles 24 and 25 below, states should refrain from imposing large
punitive fines merely for failure to comply with a de-listing request as this is likely toconstitute a disproportionate restriction on freedom of expression, due to the inherent
chilling effect of such measures.

18.7.

Relevant Internet service providers, public bodies and the courts should publish transparency
reports about the number and nature of de-listing requests, as well as statistics about the
number of requests which are granted or rejected.

18.8

Where de-listing has occurred, in the interests of transparency this should be made clear in
the presentation of the search results.

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Principle 19: Data protection exemptions
19.1.

States should ensure that the enforcement of data protection rights, as defined for the
purpose of these Principles, includes broad exemptions or limitations for the exercise of
freedom of expression.

19.2.

At a minimum, there must be exemptions from the application of, and/or limitations
embedded in, data protection laws for the protection of journalistic, literary, academic, andartistic purposes and for the discharge of any legal obligation to make information publicly
available, such as the maintenance of archives for historical or other public interest
purposes, or under right to information laws; and such exemptions or limitations must be
interpreted broadly so as to give meaningful effect to the rights to freedom of expression
and to information.

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Section 5: Reconciling the right to information,
data protection and the right to privacy
Principle 20: General principles on the right to information
20.1.

Public bodies, as well as private bodies carrying out public functions, delivering public
services, managing public resources or utilising public funds should apply the principle ofmaximum disclosure when dealing with right to information requests or proactively
publishing information about their activities.

20.2.

The scope of exceptions to the right to information, including the right to privacy andprotection of personal data, must be limited and subject to strict “harm” and “public
interest” tests.

20.3.

Public bodies must proactively disclose government data, including through the use ofaccessible formats and anonymised datasets (“open data”), subject to safeguards for theprotection of the right to privacy, of the right to personal data protection (as set forth inPrinciple 1), and of confidential sources (under Principle 9).

Principle 21: Maximum disclosure of personal information about public officials
21.1.

States should enable in their legislation and practices that personal information about public
officials can and should be disclosed if it:a) Relates to those individuals’ official capacities or is required for the exercise orprotection of any right or fundamental freedom; andb) Relates to a public official’s employment, such as his or her performance, salary, assets,
and conflicts of interest.

21.2.

Consistent with Principle 13, personal data, which may include private information, aboutpublic officials should be disclosed where the information at issue is in the public interest.
The public interest (as set forth in the Key Definitions) in disclosing the information must be
particularly strong when the information is of a purely private or highly sensitive nature.

Principle 22: Official records
22.1.

State authorities may hold personal information about private citizens in court records, social
programme records, public registers, professional records, archives, public subsidies forbusiness purposes, and records of beneficial ownership in companies. In determining
whether to make those records public or (partially) anonymised, governments should haveregard to:a) The free flow of information;b) Transparency and accountability;

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The Global Principles on Protection of Freedom of Expression and Privacyc) Other aspects of the public interest, such as open justice and anti-corruption;d) Natural persons’ rights to privacy;e) Legal persons’ legitimate rights to, and interests in, confidentiality;f)

Accountability for fair handling of information;g) Public safety and security; andh) Discrimination against minorities and other persons in situations of vulnerability.
22.2.

There should be a presumption that:a) Court records should be made public where anonymity orders or other reporting
restrictions can adequately protect the right to privacy or to a fair trial where the court
deems it necessary;b) Health records, because of their inherently sensitive nature, should not be made public
unless there is a strong countervailing public interest in publishing such information in
individual cases; andc) Public records about children, whether medical or pertaining to social programmes, andpublic records about victims of sexual, institutional, or other types of criminal violence
should not be made public other than in an anonymised format.

22.3.

In determining whether, under Principle 22.1 or 22.2, it would be fair for personal
information held in such records to be made publicly available, the relevant independent
authorities should have regard to the following factors:a) How the information was obtained;b) The subject’s likely expectation regarding disclosure of information;c) The effect of the disclosure on the data subject, in particular whether he or she would
suffer substantial harm as a result of the disclosure;d) Whether the party expressly refused consent to the disclosure of the information;e) The content of the information; and
f)

22.4.

The public interest (as defined in Key Definitions) in the information.

When personal information is made publicly available in data form, including in public
databases, there should be no restrictions on the re-use of such data for the purposes of theexercise of freedom of expression, including journalistic, artistic, and literary purposes.

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Section 6: Remedies and sanctions
Principle 23: General principles
23.1.

States should ensure that redress mechanisms for alleged privacy or data protection
violations should be easy to use, quick and effective, and comply with due process standards.
Self-regulatory or voluntary redress mechanisms, alternative dispute resolution schemes,such as ombudspersons, and non-pecuniary remedies should be made available andaccessible in addition to effective court action.

23.2.

Any sanctions imposed by the courts or other independent adjudicatory bodies in order toprotect the right to privacy must be proportionate to the harm suffered.

23.3.

The courts or other independent adjudicatory bodies should address themselves to thequestion of whether the remedy being sought is the most appropriate to deal with thebreach of privacy or data protection whilst fully respecting the right to freedom of
expression.

23.4.

The courts or other independent adjudicatory bodies should consider whether non-pecuniary
remedies, including an apology, retraction, correction or declaration, or a combination ofthese, is or are a more proportionate remedy for dealing with privacy or data protection
violations than civil or criminal sanctions.

23.5.

In cases relating to the Internet, the courts or other independent adjudicatory bodies should
consider whether the case has a real and substantial connection with the country in which
the court is based and whether the claimant can establish that he or she has suffered
substantial harm in that jurisdiction.

Principle 24: Criminal penalties

States should ensure in their domestic legislation and practices that criminal penalties, including
imprisonment and punitive fines, are proportionate to the seriousness of the infringement of theright to privacy or data protection, and, if used at all, should be restricted to the most serious cases
where there is wilful disregard of the rights of others or gross negligence.

Principle 25: Pecuniary awards
25.1.

In assessing the quantum of pecuniary awards for breaches of the right to privacy or dataprotection, courts should take into account the potential chilling effect on freedom of
expression. In particular, they should ensure that pecuniary awards are neverdisproportionate to the harm suffered and take into account any available non-pecuniary
remedies.

25.2.

States should ensure in their domestic legislation and practices that the circumstances inwhich punitive damages may be awarded must be strictly limited to circumstances where
there is a wilful disregard (including gross negligence) of the rights or others.

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25.3.

A fixed ceiling to the quantum of such punitive damages must be applied in privacy or dataprotection cases where there is non-material harm, and must be related to the ability to payof the party being punished.

Principle 26: Prior restraint, super injunctions, mandatory pre-moderation and notice prior
to publication
States should recognise in legislation and in practice that:a)
As a matter of principle, prior restraint is never compatible with the protection of the right tofreedom of expression, even on the grounds of protecting privacy;b)Interim non-disclosure orders containing a prohibition on reporting the fact of proceedings(i.e. super-injunctions), including the existence of the injunction and any details contained
within it, should be considered a disproportionate restriction on the right to freedom of
expression;c)

A legal requirement to give notice to an individual whose right to privacy might be engagedprior to publication, so as to enable him or her to seek an injunction is incompatible with theprotection of the right to freedom of expression; andd)A legal requirement to pre-moderate user-generated content constitutes a form of priorrestraint and as such is incompatible with the right to freedom of expression.

Principle 27: Interim injunctions
27.1.

Insofar as interim injunctions prohibiting the publication or further publication of private
information (i.e. interim non-disclosure orders) may be permitted by law in certain
jurisdictions, states should ensure that such injunctions should only be permitted by order ofa court in the most exceptional cases where all of the following conditions are met:a) The applicant can show that he or she would suffer irreparable damage which could not
be compensated by subsequent remedies should publication or further publication takeplace;b) The court is satisfied that the applicant is likely to establish at a later full hearing (seePrinciple 27.3 below) that publication or further publication should not be allowed;c) The court has had particular regard to the impact on freedom of expression, and where
the proceedings relate to journalistic, literary or artistic material, the extent to which
the material has or is about to become available to the public or the extent to which itis, or would be in the public interest for the material to be published; andd) The court has had regard to the protection of the rights set out in Principle 1 and has
carefully applied the three-part test set out in Principle 2 to the facts of the case.

27.2.

Advance notice of an application for an interim non-disclosure order must be given to
respondents and any non-parties which have an existing interest in the information sought tobe protected by the order. Failure to provide advance notice can only be justified by

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compelling reasons, including where there is a real prospect that were a respondent or nonparty to be notified they would take steps to defeat the order’s purpose.
27.3.

Permanent injunctions should never be obtained without a full and fair hearing of the meritsof the case. Permanent injunctions should be limited in application to the specific statements
found to be in breach of the right to privacy and to the specific people found to have been
responsible for the publication of those statements.

Principle 28: Blocking injunctions

States should ensure in their legislation and practice that:a)Filtering, blocking, removal and other technical or legal limits on access to content – asserious restrictions on freedom of expression – can only be justified if they strictly comply
with the three-part test under international law (as set forth in Principle 2); andb)Wholesale blocking of the Internet or of online services, platforms, or applications for the
purposes of protecting the right to privacy are a disproportionate restriction on freedom of
expression.

Principle 29: Intermediary liability and content removal
29.1.

States should ensure in their legislation and practices that intermediaries which provide
services – such as, for example, those providing Internet access, or searching for, or thetransmitting, hosting or caching of information – should in principle be immune from both
civil and criminal liability for privacy-infringing content disseminated by third parties using
those services.

29.2.

Intermediaries should not be required to monitor their services actively to prevent privacy
infringements.

29.3.

Laws governing the liability of intermediaries in respect of privacy-infringing content must
contain due process safeguards sufficient to protect freedom of expression and the right toprivacy. In principle, intermediaries should only be required to remove privacy-infringing
content if the measure is provided by law and ordered by a court, tribunal or otherindependent adjudicatory body in accordance with the rule of law. Any removal of content
should be consistent with the Manila Principles on Intermediary Liability.

29.4.

Principle 29.1 and Principle 29.3 are without prejudice to voluntary redress mechanisms that
Internet intermediaries should provide for privacy violations under their terms of service inline with the Manila Principles on Intermediary Liability.

Principle 30: Blanket prohibitions on Internet access on grounds of privacy protection

States should refrain from mandating blanket prohibitions on access to the Internet on the grounds
of protection of the right to privacy, as these are always a disproportionate restriction on the right tofreedom of expression.

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Background
These Principles are part of ARTICLE 19’s International Standards Series, an ongoing effort toelaborate in greater detail the implications of protecting and promoting the right to freedom of
expression in different thematic areas.
These Principles are the result of a process of study, analysis, and drawing on the extensive
experience and work of ARTICLE 19’s regional offices and partner organisations in many countries
around the world. An original draft of the Principles prepared in coordination with the Steering
Committee (consisting of Access Now; The Centre for Internet and Society, India; Derechos Digitales;
Electronic Frontier Foundation; KICTANet, Kenya; Open Net Korea and Tactical Tech) and further
elaborated in a series of consultations, organised by ARTICLE 19, with high-level experts from Africa,
Latin America, North America, Europe, and Asia: activists, legal practitioners, academics, and otherexperts in international human rights law, freedom of expression, privacy, and data protection law.
The consultations included one expert meeting in San Francisco on 28–29 March 2016 and a global
public consultation launched online in 2016. Broader discussions also took place around the draftthat emerged from the meeting and global consultation. The final version of the Principles wasproduced on the basis of these consultations.
ARTICLE 19 appreciates the input and support of all the individuals and organisations that
contributed to the development of these Principles.
These Principles were developed as a part of the project supported by a grant from the Ford
Foundation and the Foundation Open Society Institute in cooperation with the Program on
Independent Journalism of the Open Society Foundation. The Ford Foundation and The Foundation
Open Society Institute do not necessarily share the opinions here within expressed.
ARTICLE 19 bears the sole responsibility for the content of the Principles.

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