A/HRC/35/22
37.
The censorship resilience of content delivery networks has also made them targets of
disproportionate restrictions on freedom of expression. In Egypt, the blocking of The New
Arab website in August 2016 also disrupted access to content on other sites that, although
unaffiliated, shared the same content delivery network, which led researchers to believe
authorities had targeted that particular network. 71 In China, a national filter has reportedly
blocked EdgeCast content delivery network, which handles content for a number of large
websites in the country.72
38.
Since content delivery networks process large volumes of user requests for Internet
content from multiple websites and platforms, they are also vulnerable to government
surveillance. In 2016, for example, Amazon Web Services, which houses one of the world’s
biggest content delivery networks,73 reported that government requests to access data more
than doubled from the previous year. 74 Researchers also believe that mass surveillance
activities strategically target content delivery networks to maximize information collection,
but specifically how this is conducted and the extent of content delivery network
involvement, if any, is unclear.75
D.
Network equipment vendors
39.
Vendors supply the hardware and software that form the basis of Internet and
telecommunications networks. Network equipment typically includes routers, switches and
access points, which enable multiple devices and networks to connect with each other (see
A/HRC/32/38, para. 18). Vendors have also diversified their business to provide Voice over
Internet Protocol (VoIP) equipment, which enables wireless calls and Internet of Things
(IoT) technology, which enables networking among smart devices. 76 Vendors are rarely
consumer-facing: their main customers are network operators, such as governments, ISPs,
or content delivery networks. As a result, they are required to configure networks to the
technical standards specified by these operators, including standards dictated by local law
(such as law enforcement and national security requirements). However, vendors may also
design or modify equipment and technology to ensure consistency with private or
government specifications.
40.
Given their business model, vendors are required to navigate the human rights
challenges that their customers face or create. In the area of surveillance, vendors are often
bound by “lawful interception” measures, which require the configuration of networks to
enable government access to user data. 77 Additionally, vendors may be contracted to
establish “administration and mediation systems” that facilitate the sharing of intercepted
data between the network operator and the government authority as well as the government
systems that process the intercepted data.78 In arrangements where vendors also manage the
networks that they have built, they may also be responsible for handling government
requests for user data on the operator’s behalf.79
71
72
73
74
75
76
77
78
79
12
Leonid Evdokimov and Vasilis Ververis, “Egypt: Media censorship, Tor interference, HTTPS
throttling and ads injections?”, Open Observatory of Network Interference (27 October 2016).
Joss Wright, “A quick investigation of EdgeCast CDN blocking in China”, blog, Oxford Internet
Institute (18 November 2014).
At the time of writing the present report, Amazon Cloudfront served the largest number of website
domains in the world.
Amazon Information Request Report (June 2016).
See, for example, Harrison Weber, “How the NSA & FBI made Facebook the perfect mass
surveillance tool”, Venture Beat (15 May 2014).
Michael E. Raynor and Phil Wilson, “Beyond the dumb pipe: The IoT and the new role for network
service providers”, Deloitte University Press (2 September 2015).
See, for example, Council of the European Union resolution of 17 January 1995 on the lawful
interception of telecommunications, Official Journal C 329; and Privacy International submission, pp.
2-3.
IHRB, “Human rights challenges of telecommunications vendors: addressing the possible misuse of
telecommunications systems: case study: Ericsson” (November 2014), p. 16.
Ibid., p. 17.
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