Developing a Human Rights Impact Assessment Model for Internet Domain Registries

ARTICLE 19, the Danish Institute for Human Rights, and the Dutch Internet Domain-registry SIDN, are developing a model for assessing the human rights impacts of Internet registries.

The freedom of expression organization ARTICLE 19, the Danish Institute for Human Rights (DIHR), and the Dutch Internet domain registry SIDN, which is the foundation responsible for managing the top-level domain .nl, are joining forces to develop a model for assessing the human rights impacts of Internet registries.

Many companies, including companies in the Information and Communications Technology (ICT) sector, have assessed their human rights impacts, but this will be the first model developed specifically for the human rights assessment of the activities of Internet domain registries. “The increased importance of the Internet, and by extension the technical and business actors building, coding and maintaining its technical underpinning, requires a made-to-measure approach. Which is precisely what we hope to provide through this ongoing work.” – said Cathrine Bloch Veiberg, Corporate Engagement Programme Manager, Danish Institute for Human Rights.

Registration of domains

Internet domain registries manage Internet domain names like .com, .org or country-code level domains like .uk or .nl. While the function of registries is often seen as strictly technical, their activities do, as nearly every entity, have a potential human rights impact. They have a role in the Internet infrastructure and with that, are one of the parties that are increasingly approached by rights holders and law enforcement to assist in the enforcement of intellectual property rights and addressing illegal activities. Registries, for example, regularly receive requests from governments to redirect websites with unlawful content to the websites of law enforcement agencies. However, doing so may impact the right to freedom of expression and access to information. At the same time registries publish data with respect to domain registrants and other which may impact the right to privacy.

“Joining this project was therefore a logical step for SIDN”, says Maarten Simon, General Counsel at SIDN: “SIDN is the manager of more than 5.7 million registered .nl domain names. The impact of our work on human rights has never been specifically assessed. Developing a model that can help us and other registries to do just that could raise awareness and transparency on this important subject.”

Overview of the impact on Human Rights

Currently we do not know the full extent of the human rights impact of Internet registries. That is why the Danish Institute for Human Rights, ARTICLE 19 and SIDN have embarked on this joint project to develop a tailored model for how to assess these human rights impacts. The goal is to develop a model that will set a standard for the industry, and serve as a model for other registries interested in mapping the impact of their work on human rights.

Niels ten Oever, Head of Digital, ARTICLE 19, is excited about the project: “ARTICLE 19 welcomes the opportunity to work with these two partners to develop a tailored tool for technical Internet actors to understand and map their impact on human rights, and mitigate any negative impact. The Internet mediates how we exercise our rights, and the infrastructure determines if and how we can do that. Therefore it is of the highest importance that we work on developing models for human rights impact of infrastructure providers.”

In accordance with the UN Guiding Principles on Business and Human Rights, business entities, like SIDN, have a responsibility to respect human rights. In his last report on “freedom of expression and the private sector in the digital age” UN Special Rapporteur on the right to freedom of expression David Kaye also emphasized the responsibility of technical and business actors involved in Internet governance to respect human rights. Human rights due diligence requires companies to identify, assess, address and communicate and report on their human rights impacts.


For more information, please contact

–       Niels ten Oever, ARTICLE 19 – [email protected]

–       Cathrine Bloch Veiberg, Danish Institute – [email protected]

–       Maarten Simon, SIDN – [email protected]


Read more about:

–       The Danish Institute for Human Rights’ work on human rights and impact assessment here:

–       SIDN here: