PIR assessed well in each of the assessment sections (Employment, Procurement, Environment and Local Communities, Provision of Service, and Due Diligence). Our policies and operational procedures were found to respect human rights, so they cause few negative impacts. In a few instances we observed that the review topic did not apply given the specific nature of our business and the legal framework in which we operate. For example, some of the procurement aspects didn’t apply to a digital service company like PIR and state employment laws and regulations may differ from international standards.
This should not come as a surprise, though, and is actually a feature of the assessment model intended to be comprehensive but not mandatory. In fact, the workshop and our findings will help further refine the methodology, which was developed through prior assessments of the Dutch domain name registry SIDN (in 2017) and Irish web host and registrar Blacknight Solutions (in 2018) with an eye towards being even more applicable to future domain name industry participants.
Based on our policy review and discussions with the Article 19 and DIHR analysts, we have identified a few areas for improvement and are working to address them. In particular, PIR intends to:
- Incorporate an explicit commitment to international human rights in our existing policies. While our standards and processes already reflect such support, taking such an affirmative step will underscore our commitment to human rights.
- Publish a new Appeal Mechanism for registrants of PIR-managed domain names. We will establish a process that creates a right for registrants to have a suspension of their domain name under the PIR Anti-Abuse Policy reviewed by a neutral third party. That will strengthen the principles at the foundation of our anti-abuse efforts, in particular the observation of due process.
- Publicize a new Vendor Standards of Behavior document. This will set out our expectations of those who provide us goods and services. PIR always has set high standards for the way we conduct business. In turn, we’ll make clear in writing that we expect our vendors to conduct business responsibly, transparently, and with integrity.
- Ensure our Annual Report includes data with a human rights focus. PIR already reports take-down statistics and law enforcement requests for information. In the future we’ll also highlight internal procedural adjustments that better reflect accepted human rights standards and/or to address any negative impacts of our practices.
One of the principles of being an exemplary registry is a continual focus on getting better. For that reason, PIR appreciated the opportunity to work with ARTICLE 19 and DIHR on our human rights impact assessment. We look forward to working with these partners on educating the ICANN community, in particular domain name registries and registrars, on the importance of respecting human rights and remediating any negative impacts.
Together we hope to encourage other Internet infrastructure providers to engage in their own human rights due diligence and accelerate the growing commitment to respect human rights.