Network shutdowns (‘shutdowns’) refer to the intentional disruption of electronic communications mandated by a government.
These can be geographically targeted and therefore affect specific communities, or implemented nationally and can apply to all communications and/or specific platforms. Under its operating licences, Vodafone must comply with shutdown orders when compelled to do so in accordance with local law. We have identified shutdowns as one of our salient human rights issues.
Shutdowns limit citizens’ freedom of expression and may block journalism, potentially shielding governments from scrutiny and often isolating vulnerable communities at times of their greatest need. They prevent citizens accessing emergency services and services that are essential to everyday life, such as mobile money and online education, and in times of crisis they can restrict access to critical assistance such as humanitarian relief.
Our approach
Vodafone’s policies governing our approach to network shutdowns are our Law Enforcement Assistance Policy (our ‘LEA Policy’) and our Human Rights (including Child Rights) Policy (our ‘Human Rights Policy’). Our Human Rights Policy is informed by the United Nations Guiding Principles on Business and Human Rights, the United Nations Global Compact Principles, the Global Network Initiative Principles and the UNICEF Children's Rights and Business Principles. The policy requires that we seek ways to respect human rights, even when faced with conflicting requirements, and that we give special consideration to the rights of vulnerable groups. Our LEA policy requires that when we assist law enforcement authorities, we do so only under certain carefully prescribed circumstances.
All shutdown demands must be evaluated by an appropriately qualified and senior solicitor of the operating company, to determine whether the demand has been issued in accordance with local law and whether the operating company has a legal obligation to comply. Our operating companies interpret shutdown demands as narrowly as is lawfully possible, to mitigate the impact on rightsholders. If a shutdown demand appears overly broad, unlawful or otherwise inconsistent with applicable law, the operating company will seek clarification or modification from authorised officials.
Vodafone advocates for governments to end the indiscriminate use of shutdowns.