Assessing Human Rights Impacts at Public Interest Registry

by Paul Diaz, Vice President of Policy, PIR

Public Interest Registry (PIR) is dedicated to operating as an exemplary domain name registry. This includes a commitment to uphold human rights and related fundamental freedoms. Given the critical role Internet infrastructure providers—not only registries, but also domain name registrars, service providers, content delivery networks, and the other technical actors that make the Internet work—play in our economy and society, it’s a solemn responsibility to respect human rights.

That is why PIR takes frameworks and international standards such as the UN Guiding Principles on Business and Human Rights, the Universal Declaration of Human Rights, and the Core Conventions of the International Labour Organization so seriously. These include, but are not limited to, foundational principles involving freedom of expression, access to information, and access to effective remedy. To more fully gauge PIR’s level of achievement on respecting human rights, and to identify any of our activities that may cause, contribute to, or be directly linked to adverse impacts, we collaborated with ARTICLE 19 and the Danish Institute for Human Rights (DIHR) on a human rights assessment.

The human rights assessment process applied a systematic approach intended to help Internet infrastructure providers understand their impact—both real and potential—on the rights of Internet users, employees and other stakeholders. We collaborated with Article 19 and DIHR to review PIR’s policies, operations, and safeguards as an employer and as a procurer of goods and services. In addition, we looked at the company’s relationship to the environment and local communities. The multi-day workshop also evaluated potential human rights impacts specific to the actions and operations of a registry operator, including the provision and maintenance of domain names, transparency, privacy, and engagement with third parties such as law enforcement agencies.

This is a rigorous but vital exercise. By identifying and assessing these real and potential impacts, PIR took an important step in exercising due diligence and realizing our responsibility to respect human rights.

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.