they are designed as a starting point, prepared to incorporate lessons as the GNI and its
participants discern them.
The expectations cover roughly the same terrain as the Principles, but place ‘‘responsible company decision making’’ first, suggesting the overall frame within which the
activities occur. Companies are expected to form internal cross-functional teams to
lead implementation, to train employees (and the board) on approaches and procedures, to provide whistle-blowing mechanisms for employees, and to encourage business partners and others to adopt the Principles.
With a priority placed on preventing incidents, participants will undertake human
rights impact assessments to identify circumstances when expression and privacy
rights may be jeopardized or advanced (e.g., entering new markets; designing and
introducing new technologies, products, or services; selecting partners; responding
to policy change) and develop steps to mitigate risks and to leverage opportunities.
Companies will elaborate procedures and policies that govern these occurrences and
the possible issues that arise within them.
The Guidelines state that authorities seeking to limit expression or privacy will be
expected to do so in writing along with the legal basis for the restriction and the
name of the requesting official, and that when required by governments to limit access
to information and ideas, companies will interpret laws and requests narrowly and
communicate actions to users when legally permissible. When they are confronted
with a practice that appears inconsistent with domestic law and procedures or international human rights laws and standards on expression or privacy, companies will challenge it. Companies will document these requests and demands to permit tracking and
review.
Governance, Learning, and Accountability Framework
Much of the value of the collective is created by means of the activities described in the
Framework, which include the GNI’s organizational structure and responsibilities,
along with those of the participating companies and the independent assessors. The
Framework covers basic institution-building responsibilities including recruiting of
new participants and outreach, fostering learning and collaboration on policy issues,
offering a communications channel for external parties and users, publishing an annual report, and creating an accountability mechanism.
Independent monitoring, which begins with an orientation toward process and
becomes increasingly comprehensive over the GNI’s first five years (ultimately including incident review), supports corporate accountability, remediation where necessary,
development of good practice among participants, and continued evolution and refinement of the GNI. The accountability process moves from capacity building (2009–
2010), to independent process review (2011), and independent process and case review
(2012 and beyond). The phasing process was designed to accommodate the lack of
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Colin M. Maclay
participants discern them.
The expectations cover roughly the same terrain as the Principles, but place ‘‘responsible company decision making’’ first, suggesting the overall frame within which the
activities occur. Companies are expected to form internal cross-functional teams to
lead implementation, to train employees (and the board) on approaches and procedures, to provide whistle-blowing mechanisms for employees, and to encourage business partners and others to adopt the Principles.
With a priority placed on preventing incidents, participants will undertake human
rights impact assessments to identify circumstances when expression and privacy
rights may be jeopardized or advanced (e.g., entering new markets; designing and
introducing new technologies, products, or services; selecting partners; responding
to policy change) and develop steps to mitigate risks and to leverage opportunities.
Companies will elaborate procedures and policies that govern these occurrences and
the possible issues that arise within them.
The Guidelines state that authorities seeking to limit expression or privacy will be
expected to do so in writing along with the legal basis for the restriction and the
name of the requesting official, and that when required by governments to limit access
to information and ideas, companies will interpret laws and requests narrowly and
communicate actions to users when legally permissible. When they are confronted
with a practice that appears inconsistent with domestic law and procedures or international human rights laws and standards on expression or privacy, companies will challenge it. Companies will document these requests and demands to permit tracking and
review.
Governance, Learning, and Accountability Framework
Much of the value of the collective is created by means of the activities described in the
Framework, which include the GNI’s organizational structure and responsibilities,
along with those of the participating companies and the independent assessors. The
Framework covers basic institution-building responsibilities including recruiting of
new participants and outreach, fostering learning and collaboration on policy issues,
offering a communications channel for external parties and users, publishing an annual report, and creating an accountability mechanism.
Independent monitoring, which begins with an orientation toward process and
becomes increasingly comprehensive over the GNI’s first five years (ultimately including incident review), supports corporate accountability, remediation where necessary,
development of good practice among participants, and continued evolution and refinement of the GNI. The accountability process moves from capacity building (2009–
2010), to independent process review (2011), and independent process and case review
(2012 and beyond). The phasing process was designed to accommodate the lack of
96
Colin M. Maclay