Our principles and policies
Our Privacy and Law Enforcement Principles
Our Privacy and Law Enforcement Principles set out our commitment to meeting obligations to respond to agencies’ and authorities’ lawful demands without going beyond what is mandated in law (other than under specific and limited circumstances).
Abiding by our principles can be challenging in certain countries at certain times. In practice, laws governing agencies’ and authorities’ access to customer data are often both broad and opaque and frequently lag behind the development and use of communications technology. Furthermore, the powers in question are often used in the context of highly sensitive and contentious developments — for example, during major civil unrest or an election period — which means that Vodafone colleagues dealing with agencies and authorities in the country in question can be put at risk for rejecting a demand on the basis that it is not fully compliant with legal due process.
The Vodafone Privacy and Law Enforcement Principles
We do not:
- allow any forms of access to any customer data by any agency or authority unless we are legally obliged to do so;
- go beyond what is required under legal due process when responding to demands for access to customer data other than in specific safety of life emergencies (such as assisting the police with an active kidnapping event) or when refusal to comply would put our employees at risk; or
- accept any instruction from an agency or authority acting beyond its jurisdictions or legal mandate
We do:
- insist that all agencies and authorities comply with legal due process;
- scrutinise and, where appropriate, challenge the legal powers used by agencies and authorities in order to minimise the impact of those powers on our customers’ rights to privacy and freedom of expression;
- honour international human rights standards to the fullest extent possible whenever domestic laws conflict with those standards;
- communicate publicly any threats or risks to our employees arising as a consequence of these principles, except where doing so would increase those rights; and
- seek to explain the scope and intent of the legal powers available to agencies and authorities in all countries where it is lawful, to do so.
Our Freedom of Expression Principles
Our Freedom of Expression Principles set out how we seek to uphold our commitment to respecting our customers’ lawful rights to hold and express opinions and share information and ideas without interference when faced with law enforcement demands.
They are informed by international laws, standards and industry principles, including:
- Universal Declaration of Human Rights
- International Covenant on Civil and Political Rights
- International Covenant on Economic, Social and Cultural Rights
- UN Guiding Principles on Business and Human Rights
- UN’s ‘Protect, Respect and Remedy’ Framework
- OECD Guidelines for Multinational Enterprises
- Reports of the UN Special Rapporteur on the promotion and protection of the right to freedom of opinion and expression
- Global Network Initiative Principles
Our related policies
Our Freedom of Expression Principles are upheld in Group Policies, such as:
- Group Code of Conduct – sets out our core business principles, e.g. ‘ We value the trust our customers place in us and safeguard the information provided to us’
- Group Human Rights Policy – confirms our commitment to the rights to privacy and freedom of expression.
- Group Law Enforcement Assistance Policy – creates the governance and necessary safeguard requirements to ensure we appropriately balance respect for our customers’ right to privacy and freedom of expression with other obligations necessary to a free and secure society.
- Group Privacy Management Policy – defines our Privacy Vision and a privacy management framework which is implemented across Vodafone and which ensures conformance with our Risk Tolerance and Principles.
- Artificial Intelligence Framework – sets out our approach to working with AI technologies and outlines how we intend to develop and employ it in a responsible manner.
Our Group Law Enforcement Assistance Policy applies to all Vodafone companies and joint ventures with an interest of 50% or more, or management control, and to their employees, contractors, suppliers, and directors.
