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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