Balancing our responsibility to respect our customers’ right to privacy with our legal obligations to disclose customer data
Law enforcement disclosure and demands for customer data
In 2014, we published our first Law Enforcement Disclosure transparency report, explaining how we respond to lawful demands for access to our customers’ private data from law enforcement and intelligence agencies.
We offer insights into the legal frameworks, governance principles and operating policies and procedures associated with responding to lawful demands for assistance from law enforcement and intelligence agencies.
Respecting our customers’ rights to privacy and freedom of expression is one of our highest priorities.
Over 3 billion people communicate and share information over our networks, enabling them to connect, innovate and prosper. However, the laws surrounding the communications environment are complex and sometimes require us to respond to lawful demands to share customer data or restrict our services. Our transparency disclosures on matters related to digital human rights include our policies, approach and principles regarding government access to customer data, as well as our approach to managing issues such as freedom of expression, censorship and the digital rights of the child. We explore these issues here.
Freedom of expression and network censorship
We respect and seek to protect our customers’ lawful rights to hold and express opinions and share information and ideas without interference. However, all governments also have the right, through legislation, to limit their citizens’ ability to access and use digital networks and services under certain circumstances and these can vary significantly from country to country.
We provide an overview of the complex challenges faced by telecommunications operators in seeking to respect their customers’ right to freedom of expression along with a set of Freedom of Expression principles. These principles are informed by international laws, standards and reports, including the Universal Declaration of Human Rights and the UN Guiding Principles on Business and Human Rights.
Managing privacy risks effectively and putting customers in control of their data is core to our approach. Our privacy policies and framework govern how we collect, use and manage our customers’ information in order to ensure we respect the confidentiality of their personal communications and any choices that they have made regarding the use of their data. Our commitment to our customers’ privacy goes beyond legal compliance and is focused on building a culture that respects privacy in order to justify the trust that people place in us. It includes:
Openness and honesty
We communicate clearly any actions we take that could affect our customers’ privacy.
When we are required to balance the right to privacy against other obligations necessary to a free and secure society, we work to minimise privacy impacts.
Choice and access
We give people the ability to make simple and meaningful choices about their privacy and allow them – where appropriate – to access, update or delete their personal data.
Fairness and lawfulness
We comply with privacy laws and act with integrity and fairness. We work with governments, regulators and others to shape better, more meaningful privacy laws and standards.
Privacy by design
Respect for privacy is a key component in the design, development and delivery of our products and services.
We are accountable for living up to these commitments throughout Vodafone and with our partners and suppliers.
Alignment with the Industry Dialogue Guiding Principles
Vodafone was a founding member of the Telecommunications Industry Dialogue on Freedom of Expression and Privacy, which was created in order to advance freedom of expression and privacy rights in the telecoms industry. Our statement explains how our policies and process align with the Telecommunications Industry Dialogue Guiding Principles on Freedom of Expression and Privacy. In March 2017, Vodafone became a member of the multi-stakeholder Global Network Initiative.