A/HRC/28/39 noted that the effects of online surveillance were often felt offline and were part of a global trend to restrict civic space. Lawful protest movements were monitored by the State and private actors to undermine peaceful actions and related rights, in particular the rights to freedom of expression and assembly. 39. Most delegations reaffirmed that rights held by people offline must also be protected online, as set out in General Assembly resolution 68/167 and Human Rights Council resolutions 20/8 and 26/13. 40. Most delegations considered the right to privacy a precondition to being able to freely express oneself and one of the founding rights of a democratic society. Many delegations noted that surveillance had an impact on rights other than the right to privacy, in particular freedom of expression and of opinion and freedom of assembly and association. It was further noted that privacy and freedom of expression were “interlinked and mutually dependent” (see A/HRC/23/40, para. 79) and that they enabled and facilitated the development of other fundamental rights and sustainable development. To illustrate this, two NGOs noted the concrete harm that large-scale electronic surveillance could have on the work of journalists and lawyers, undermining freedom of expression and association and the right to counsel.7 One delegation referred to attempts to silence the media. Another NGO referred to bloggers facing charges of terrorism, partly because they had encrypted their communications and engaged in digital security training to ensure their privacy. 41. One delegation noted that individuals were often not aware of the extent to which data could be used or shared, even when collected with their consent. Some delegations referred to the right to data protection and to the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data and its additional Protocol as the first binding international instrument in the data protection field and an important contribution to the right to privacy. One delegation referred to a so-called “right to be forgotten”, where the legitimate wish not to be associated with only a particular aspect of one’s life or past might clash with the right to be informed and might also lead to a distortion in collective memory. 42. Many delegations highlighted the measures taken at national level to ensure protection of the right to privacy in the digital age. UNESCO referred to its work in relation to privacy and freedom of expression in the digital age, to a publication on internet privacy and freedom and expression and to a comprehensive study on Internet issues, including a focus on freedom of expression, privacy, access to knowledge and information and the ethics of the information society. B. Legal protection of the right to privacy 43. Most delegations emphasized that international law provided a clear framework for the right to privacy, enshrined in article 12 of the Universal Declaration of Human Rights and article 17 of the International Covenant on Civil and Political Rights. Many observed, however, that the implementation of the right to privacy was lacking and that there was a need for concrete measures to safeguard that right. Some noted that unilateral and unauthorized access to private data and extensive surveillance needed to be addressed comprehensively and calls were made for urgent measures to be taken to stop current surveillance practices and protect individuals from violations of their right to privacy. 7 Human Rights Watch and American Civil Liberties Union, “With liberty to monitor all: how largescale US surveillance is harming journalism, law and American democracy” (July 2014). 11