A/HRC/41/35 demonstrates that it has rigorously implemented its responsibilities under the Guiding Principles with respect to the design, sale, transfer or support of such technologies. This would effectively establish the Guiding Principles as preconditions for companies to participate in the surveillance market. In previous reports, the Special Rapporteur has explained how the information and communications technology sector should fulfil its responsibilities to respect human rights (A/HRC/35/22, paras. 45–75). For private surveillance companies to meet these responsibilities, they must develop, at a minimum, the following:73 (a) Customer policies that unequivocally affirm the responsibility of companies to respect freedom of expression, privacy and related human rights throughout their operations, and that client compliance with international human rights law is a condition for the approval and completion of a sale, transfer or contract of support; (b) Human rights due diligence processes (such as human rights impact assessments) that are triggered when companies engage in activities that have a bearing on freedom of expression and privacy, such as the design, sale, transfer and servicing of surveillance products and services; (c) Internal policies and standard contractual clauses that establish clear and specific prohibitions on product customization, targeting, servicing or assistance that violates international human rights law; (d) Internal processes that ensure design and engineering choices incorporate human rights safeguards, such as flagging systems that detect misuse and kill switches that are triggered in the event of misuse; (e) Regular programmes of audits and human rights verification processes to ensure that use of their products and services comply with international human rights law, including a commitment to publicly disclose key findings from these audits and verification processes; (f) Notification processes that promptly report misuses of their tools to the relevant government oversight bodies (such as national human rights institutions) or intergovernmental bodies (such as special procedures complaints mechanisms); (g) Transparency reporting that discloses the potential uses and capabilities of their products and the types of after-sales support provided, incidents of misuse and data concerning the number and type of sales to law enforcement, intelligence or other government agencies or their agents; (h) Regular consultations with affected rights holders, civil society groups and digital rights organizations about the ongoing or potential impacts of their products and services and the human rights safeguards required to prevent or mitigate these impacts, with particular emphasis on engaging those at risk of surveillance-based discrimination or repression, such as racial and ethnic minorities and historically marginalized groups; (i) Grievance mechanisms that enable individuals to submit complaints concerning human rights abuses facilitated by company products and services, and provide for independent assessment of those complaints and meaningful follow-up; (j) Remedial mechanisms that enable complainants to seek compensation, apologies and other forms of redress, as appropriate, in cases in which complaints are independently verified. E. Co-regulatory initiatives 61. The approaches of States and companies, as described here, may be insufficient to address the global problem of targeted surveillance. They also lack several important inputs – those of civil society actors, whether activists, technologists, academics, victims or those 73 18 Many of these standards draw from the submissions of civil society, which can be found in the addendum to the present report and on the Special Rapporteur’s website.