RECOMMENDATION 2 PRIORITY: MEDIUM Ensure that participants have a process in place for handling government requests. One of the commitments that companies make to participate in the Lantern Program is to challenge external involvement by governments—speci昀椀cally, “never to accept direct contributions to the program by anyone acting on behalf of a government and to challenge efforts by government of昀椀cials to engage with or access the database.” For participants to be able to ful昀椀ll this commitment, the Tech Coalition should require as part of the eligibility requirements that companies have a robust process in place for handling government requests. This includes: › Applying human rights principles (such as the Global Network Initiative Principles and Implementation Guidelines) when responding to government requests for user data or content removals. › Publishing an annual transparency report to inform stakeholders about the company’s approach to handling government requests. Implementing this recommendation: This recommendation would be implemented by the Tech Coalition in collaboration with participating companies. RATIONALE › Principle 19 of the UNGPs states that where a company has leverage to prevent or mitigate adverse impacts, it should exercise it; and where a company lacks leverage, it should seek ways to increase it—for example, by offering capacity-building or other incentives to the related entity, or by collaborating with other actors. › Principle 17 of the UNGPs states that “in order to identify, prevent, mitigate, and account for how they address their adverse human rights impacts, business enterprises should carry out human rights due diligence. The process should include assessing actual and potential human rights impacts, integrating and acting upon the 昀椀ndings, tracking responses, and communicating how impacts are addressed.” RECOMMENDATION 3 PRIORITY: HIGHER Support smaller participants to be able to comply with requirements. Participants of the Lantern Program have different levels of resourcing and capacity for content moderation and trust and safety efforts, and it may be dif昀椀cult for some of the smaller companies to ful昀椀ll the requirements for participation, leading to a higher likelihood of human rights risks. For example, some companies may not be able to manually review all signals before actioning them, or they may not be able to track the signal sharing metrics that the Tech Coalition requires them to report on a regular basis. BSR TECH COALITION HUMAN RIGHTS IMPACT ASSESSMENT 49