Human rights

Extreme-risk country sale of standard mobile network equipment to a communications service provider.

Mandatory questionnaire in sales workflow covering country context, customer type, and intended use/technical features triggered review

Whether non-standard interception or surveillance functionality, or other indicators of elevated misuse risk, were present.

Proceeded following initial screening, which confirmed that no higher-risk triggers were present and no further escalation was required

Elevated country risk was acknowledged, but the decision turned on whether the requested technical capabilities increased misuse potential beyond standard functionality.

Government-use private network request in extreme risk country including an enhanced surveillance feature for private closed government network.

Escalated early in pre-sales and later captured through the mandatory questionnaire in the sales workflow.

Whether the network could connect to public networks and whether the requested feature could be repurposed beyond the stated scope.

Approved with conditions, including contractual scope limitations and mandatory re-review if there were material changes.

Combined technical feasibility checks with contractual restrictions and a defined trigger to reopen HRDD if scope creep emerged.

Emergency caller location solution in high-risk country for a public authority control point during emergency calls.

Mandatory questionnaire in sales workflow triggered review because location data would be shared with authorities.

Data governance, storage, access controls, legal authorization, and whether location data was linked to subscriber identity or anonymised.

Approved as go with conditions, including contractual definitions of scope of use and additional requirements to reduce misuse risk.

The review reused learning from an earlier similar project to validate technical safeguards and governance measures.

Product design change to ensure a higher risk capability was not included in the standard configuration.

Raised proactively during development and reviewed with human rights, legal, and compliance stakeholders.

Whether the design could reduce unintended or higher-risk use while preserving the ability to apply additional review before enabling the capability.

The product was redesigned so the more sensitive capability was separated from the standard offering.

Shows a safeguard-by-design approach that reduces baseline risk and creates a clearer control point for higher-risk functionality.

Responsible exit from an extreme risk jurisdiction after deterioration in the political and human rights environment.

Escalated outside the normal transaction cycle based on ongoing country monitoring, stakeholder input, and customer operational changes.

Whether continued activity remained consistent with human rights commitments, how misuse risks were evolving, and how to reduce harm to end users and personnel.

Senior leadership approved a responsible exit plan with phased wind-down measures and support for affected personnel.

Shows how HRDD can guide strategic withdrawal decisions through monitoring, escalation, phased implementation, and attention to both user impacts and staff safety.