3 Level of automation involved: Some SaaS services incorporate machine learning (ML) and AI systems to analyze data and generate insights. The degree to which a SaaS service involves automation may lead to different kinds of human rights impacts, or it may exacerbate the severity or likelihood of certain risks. 4 Level of interoperability: The SaaS service model increases opportunities to integrate different software services. For some SaaS services, interoperability with other apps is an important feature that may surface new risks. 5 Cloud versus on-premises deployment: Although the definition of software-as- a-service suggests a cloud-based service model, some SaaS providers provide the option of deploying their software on-premises as well. Whether a service is cloud-hosted or on-premises surfaces different issues and offers different degrees of leverage to address them. 6 Sales model: SaaS providers employ a variety of sales models depending on the size of the customer, the geographical location, and the level of customization needed for the product or service. A crucial differentiating factor for determining risk is the degree to which providers interface with their customers before and after sales. 7 Level of customizability: SaaS providers provide varying levels of customiz- ability—some software is ready made, whereas some allows the customer to change the code. A SaaS service’s customizability may have implications for its connection to harm. 8 Level of substitutability: Some SaaS services are more difficult to substitute than others due to their unique functionality, their “stickiness,” or their switching costs. Typically, the level of substitutability correlates with the SaaS provider’s market power. The degree to which SaaS services are interchangeable may affect how 22 much leverage the SaaS provider has to address potential human rights harms. In the following section, we discuss how these characteristics influence the severity, likelihood, and management of human rights impacts. 17 Human Rights Assessment of the Software-as-a-Service Sector

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