Submission by the Association for Progressive Communications (APC) on the issue of right to privacy in the digital age

This submission aims to provide input for the drafting of the report to be prepared by the Office of the High Commissioner for Human Rights (OHCHR) and presented to the 60th session of the Human Rights Council in September 2025 on the issue of challenges and risks with regard to discrimination and unequal enjoyment of the right to privacy associated with the collection and processing of data, including those addressed in the resolution, to identify and clarify related human rights principles, safeguards and best practices, as requested by the Human Rights Council in its resolution 54/21. It addresses the “key questions and types of input/comments sought”’ as per the call for inputs made available by the OHCHR.

Key questions and types of input/comments sought

1. Scenarios and concrete examples of instances where the collection and processing of data by public and private entities, including in the context of the development and use of artificial intelligence, is associated with discrimination and unequal enjoyment of the right to privacy across the range of its dimensions;
2. Main factors that cause or contribute to such outcomes, including
   • Technological factors,
   • Specific forms of data collection and data processing,
   • Economic, political and social factors,
   • Legal, policy and institutional factors.
3. Resulting impacts on rights holders, including intersectional forms of discrimination;
4. Safeguards and best practices to address and prevent such adverse 
   impacts, including
   • legislative and regulatory frameworks,
   • institutional frameworks, oversight and accountability/remedy mechanisms,
   • self-governance approaches by business enterprises,
   • human rights due diligence methodologies, and
   • data governance approaches and models, including approaches to prevent or mitigate data biases.

Note: Mentions to “our research” refer to the collective research developed and published by APC, partner organisations and coalitions. We acknowledge the corresponding collaborations in the cited sources.

Read the full submission here