Vodafone’s global business is made up of separate subsidiary companies, each of which operates under a local licence (or other authorisation) issued by the government of the country where it is located. Each subsidiary company is therefore subject to the domestic laws of that country.
In this section, we disclose the volume of each country’s agency and authority demands, wherever that information is available and publication is not prohibited.
How we prepared this information
Each local market where we operate has a nominated and security-cleared point of contact responsible for managing and administering law enforcement assistance.
The information collated and published in this report (wherever available and wherever publication has not been prohibited) has been overseen by the relevant Disclosure Officer, although they will not typically be made aware of the context of any lawful demand issued by agencies and authorities.
We have robust processes in place to manage and track each demand for the two categories of agency and authority demand – lawful interception and communications data.
How this report is prepared
Although the details of individual demands remain highly confidential and cannot be communicated, Vodafone’s security and audit teams conduct reviews of the overarching processes and policies that are in place to ensure the integrity of our law enforcement disclosure systems.
It should be noted that while the statistics for communications data demands are overwhelmingly related to communications metadata, the statistics we report might also include demands for other types of customer data such as names, physical addresses and services subscribed. Our reporting systems do not necessarily distinguish between the types of data contained in a demand and, in some countries, a single demand can cover several different types of data. In some countries, there is a lack of legal clarity regarding whether we can lawfully disclose the aggregate number of law enforcement demands received.
In countries experiencing continuing periods of significant political tension, it remains very challenging to ask questions related to national security and criminal investigation matters; as such, Vodafone has to strike a balance between asking legitimate questions and mitigating the potential risk this poses to Vodafone employees.
Explanation of the information presented
In each country, and for each of the categories of law enforcement demands issued – lawful interception and communications data – there are a number of different possible outcomes that can arise from our decision to publish the information collated.
Where there are no restrictions preventing publication, and there are no alternative appropriate sources of information indicating total demand volumes across all operators in a specific country, we have published the data available from our own local operating business.
Our view of the shortcomings of this approach is set out in the accompanying Statement.
Read more our explanation of the information presented
It remains our view that in countries where the government publishes certain statistical information on the law enforcement demands they issue and individual operators also publish some of the data they hold for their own operations, the net effect is confusion. In statistical terms, the datasets are irreconcilable and contradictory. We continue to advocate that it would be much more effective if governments provided consistent and comprehensive metrics spanning the industry as a whole. This would provide the public with a better understanding of the law enforcement activity being undertaken in their country.
It is important to emphasise that attempts to compare one country’s metrics with those of another are essentially meaningless given the very wide variations between legal frameworks, record keeping and reporting regimes, as there are no consistent points of common reference that could be used to underpin such analysis. Similarly, it is difficult in many cases to draw accurate conclusions from year-on-year changes in reported metrics within a country, as these can be influenced by a range of factors.
These could include amendments to legislation or new laws, developments in agency or authority or accepted industry practices, or changes to the approaches used to log, aggregate, and disclose lawful demands. Any of these may apply, and therefore year-on-year changes cannot provide a reliable indication of actual trends in law enforcement activity.
Government disclosure reports
- Country by Country Disclosure of Law Enforcement Assistance Demands 2019-20
- Country by Country Disclosure of Law Enforcement Assistance Demands 2018-19
- Country by Country Disclosure of Law Enforcement Assistance Demands 2017-18
- Country by Country Disclosure of Law Enforcement Assistance Demands 2016-17
- Country by Country Disclosure of Law Enforcement Assistance Demands 2015-16
- Country by Country Disclosure of Law Enforcement Assistance Demands 2014-15
- Country by Country Disclosure of Law Enforcement Assistance Demands 2013-14