A/HRC/41/35/Add.1 47. Finally, the Special Rapporteurs are concerned by reports that the general manager of the Medios Públicos company, Martha Moncayo, has received threats following the process to expose alleged irregularities detected in the public media seized during the tenure of the President Rafael Correa Administration. The Special Rapporteurs note that Ms. Moncayo filed a complaint with the Office of the Prosecutor General in October 2018, and urge the State to investigate the allegations fully, effectively and impartially. 3. Commercial broadcasting 48. During the visit, the Special Rapporteurs were informed about violations of freedom of expression and sanctions that Ecuadorian broadcasters were subjected to under the Organic Law on Communications prior to 2017. As reported by the Ecuadorian broadcasting association, certain provisions of the former Law represented threats to the performance of its communications and business activities. The association also pointed out the lack of legal security in the processes of assignment, revocation and renewal of licences developed during the tenure of the previous Government. The Special Rapporteurs understand that the private broadcasting sector also requires a transition with clear and transparent criteria for the renewal and assignment of frequencies. E. Access to information 49. The Constitution protects universal access to public information (art. 18 (2)). The organic law on transparency and access to public information reinforces the guarantee of access to information. The law expressly states that access to public information is a right of individuals, guaranteed by the State (art. 1). The law specifically applies to the Government and defines public information as any document, in any format, that is in the possession of public institutions and legal persons referred to in the law and any content created or obtained by them that are under their responsibility or have been produced with State resources (art. 5). In addition, non-disclosure criteria are established in articles 17 and 18 of the law. The Special Rapporteurs stress that, in addition to observing the principles of legality, necessity and proportionality, the authorities, when classifying information on the basis of legal exceptions, must conduct what is known as a harm and public interest test. This consists in proving that the disclosure of the information represents a real and identifiable risk of significant harm to the legitimate interest to be protected and that the risk exceeds the public interest of disseminating the information. 50. Although there are legal protections in place to guarantee the right of access to information, journalists and members of civil society organizations report a routine lack of access to government information. Those looking for documents from government ministries and archives are regularly told that the information is subject to some kind of exception to the constitutional guarantee. According to the information provided, there remain challenges in overcoming the culture of secrecy and having greater access to information held by the State. Women’s rights organizations reported that there was a lack of access to statistics that was properly disaggregated, including with regard to cases of femicide and sex crimes and to abortion. Likewise, it was reported that the information provided in response to such requests for information was inconsistent, and that the State in some cases responded incompletely to requests, or alleged that the information did not exist. 51. The Special Rapporteurs stress that international human rights law protects the right of access to publicly held information, a right that is fundamental to promoting transparency and public accountability. Everyone, whether as journalists or members of the public, should be able to file information requests without providing reasons for the request, and the State should have limited bases on which not to disclose. 52. The Special Rapporteurs were pleased to learn that an active transparency monitoring mechanism had been implemented, aiming towards compliance with the standards set forth in article 7 of the organic law on transparency and access to public information, which requires the Government to provide through, inter alia, a website, information regarding government institutions, such as their financial information. The 11