Compendium of Standards, Good Practices and Recommendations In addition, any such restrictions in legislation or under military discipline must not be excessive and unreasonable, and should be appropriate and proportionate to the aim of protecting national security, while also seeking to minimize intrusiveness. Account should be taken of the type of expression at issue, as well as the means of its dissemination. For example, democratic societies place a high value on public debate concerning public and political figures, and restrictions on related activities will be difficult for a state to justify. The precise nature of the threat, and the necessity and proportionality of the action taken to remedy the threat, need to be demonstrated, in particular by establishing a direct and immediate connection between the expression and the threat. Unlike under the ECHR, no margin of appreciation applies to any restrictions. With regard to restrictions on electronic media (including websites, blogs, Internet service providers and search engines), the UN Human Rights Committee has noted that: “Any restrictions […] are only permissible to the extent that they are compatible with paragraph 3. Permissible restrictions generally should be content-specific; generic bans on the operation of certain sites and systems are not compatible with paragraph 3.”181 Limits to freedom of expression: the ECHR approach Article 10 of the ECHR applies to participating States that are members of the Council of Europe. It is of similar scope to Article 19 ICCPR, in that it protects the right to hold opinions and to receive and impart ideas and information and also applies to all forms of expression, including shocking and controversial ideas.182 The European Court of Human Rights has also applied the principles governing freedom of expression via the media under Article 10 to Internet-based communication.183 It has further acknowledged that freedom of expression applies to service personnel,184 stating that “Article 10 does not stop at the gates of army barracks”.185 However, the interests of military discipline and national security are recognized as legitimate reasons for restrictions on freedom of expression under Article 10(2). In the Engel case, the Court stated that: 181 Ibid., para. 43. 182 See: Dominika Bichawska-Siniarski, Protecting the Right to Freedom of Expression under the European Convention on Human Rights: A Guide for Legal Practitioners (Strasbourg: Council of Europe, 2017), https:// rm.coe.int/handbook-freedom-of-expression-eng/1680732814. 183 See: European Court of Human Rights, Times Newspapers Ltd v. the United Kingdom (Application Nos. 3002/03 and 23676/03, judgment of 10 March 2009), para. 27. See generally: European Court of Human Rights Research Division, Internet: case-law of the European Court of Human Rights (Strasbourg: European Court of Human Rights Research Division, 2015), https://www.echr.coe.int/Documents/Research_report_internet_ENG.pdf. 184 See, for example: European Court of Human Rights, Engel and others v. The Netherlands, op. cit., note 45, para. 100; and VDSO and Gubi v. Austria, op. cit., note 142, para. 27. 185 European Court of Human Rights, Grigoriades v. Greece, op. cit., note 42, para. 45. 95