A/HRC/32/39 (c) Require that appropriate weapons training is mandatory for all private security personnel; (d) Implement strict gun control regulations with regard to private security personnel, both on and off duty; (e) Require private security providers based or operating within their territory to bring company policies in line with international norms and standards; (f) Implement a system of mandatory reporting of lethal incidents, whether caused by State law enforcement or private security personnel and, where one does not already exist, establish a transparent system for collecting, analysing and publishing the data thus generated; (g) Pass or amend laws to ensure that private security personnel who are found to have used excessive force are criminally accountable and that, in such circumstances, the private security provider itself is held to a standard of strict vicarious liability that ensures victims receive compensation; (h) Clarify their responsibilities in monitoring effectively the use of force by private security providers and providing access to remedy for victims of corporate human rights abuses, particularly in cross-border operations, and ensure that there are no barriers to access to remedy for victims of corporate human rights abuse, both procedurally and in relation to legal bases. 127. Where the State itself is directly contracting security services from a private security provider, it must conduct due diligence with respect to the private security provider’s human rights record, and pay particular attention to procedures and equipment relating to the use of force; States should also engage robust mechanisms to monitor the performance of the private security provider in that regard. Recommendations to private security providers 128. All private security providers should operate in a transparent fashion and publish reports on their activities; they should conduct investigations into allegations of human rights abuses in a transparent and thorough manner. 129. In particular, private security providers should record and publish data on incidents involving the use of force by their personnel. 130. All private security providers should actively participate in and engage with initiatives aimed at fostering respect for human rights among their personnel, including awareness-raising and capacity-building; private security providers are encouraged to align internal policies with international human rights norms and standards, and to put in place the protocols necessary. 131. All private security providers must engage in vetting and training exercises that include a human rights-based approach; they should monitor the use and safekeeping of weapons by both on and off-duty personnel. They should implement oversight and monitoring mechanisms, especially in relation to the use of force by their personnel. 132. While private security providers should set up internal grievance mechanisms for injured parties of misconduct or negligence on the part of the provider, such mechanisms should not be used to address serious abuses of human rights, including violations of the right to life, and must not require applicants to waive their right to seek a judicial remedy where applicable. 22