and sexist attacks online.169 Youth human rights defenders, including children,
are often portrayed as being too young to have an opinion and are denied the right
to express their views. The vilification of human rights defenders for their actual
or perceived sexual orientation, as well as the disclosure to mass media of sensitive personal information or data in violation of the right to privacy, appears to be
another recurring tactic used to discredit human rights defenders.
122. The right to privacy as set out in Article 17 of the ICCPR also includes the protec-
tion against unlawful attacks on one’s reputation and honour.170 States Parties to
the Covenant are therefore under an obligation to protect human rights defenders
from such attacks whether, as the UN Human Rights Committee has pointed out,
they emanate from state authorities or from natural or legal persons.171 However,
as the Committee has also stressed, while it may be legitimate to restrict freedom
of expression in order to protect the right under Article 17, such restrictions must
be applied with care.172 In particular, they must be firmly in line with international standards on freedom of expression to ensure that this right is not unduly
curtailed, and they must not be abused to deprive anyone of the right to defend
human rights.
123. It has been reported that, in a number of participating States, smear campaigns
against human rights defenders are orchestrated directly by state authorities or
officials, or by state-owned media. They are also often driven by non-state actors,
including aggressive nationalist groups, faith leaders and institutions or private
corporations.173 Such attempts to discredit human rights defenders and their work
are sometimes fuelled by derogatory – or even inflammatory – statements made by
state officials or political figures in the media, including at the municipal, regional
or national levels.
124. Human rights defenders who belong to or are associated with groups that face prej-
udice and intolerance in society – such as that based on ethnicity, religion, “race”,
citizenship, gender, disability or any other status – are at particular risk of being
targeted by such abuses. The Internet and social networks are increasingly being
169 See Report of the Working Group on the issue of discrimination against women in law and in practice,
UN Doc. A/HRC/23/50, 19 April 2013, para. 66. The Working Group, for example, reported an anonymous negative campaign calling for the gang rape of a woman human rights defender, with racist abuse posted in her
Wikipedia profile.
170 Unlike the ICCPR, Article 8 of the ECHR does not refer specifically to honour and reputation, but in its
jurisprudence the European Court of Human Rights has stated that under certain circumstances the right to
protection of one’s reputation is covered by Article 8 of the Convention as part of the right to respect for private
life. See section on the Right to private life below.
171 See UN Human Rights Committee General Comment No. 16, Article 17, “Right to Privacy”, 8 April 1988,
paras. and 1 and 11.
172 UN Human Rights Committee General Comment No. 34 on Article 19, “Freedom of Expression”, UN Doc.
CCPR/C/GC/34, 12 September 2011, para. 28.
173 For example, as the UN Special Rapporteur on the situation of human rights defenders has pointed out,
human rights defenders working for the human rights of LGBTI people are often subjected to stigmatization
and attacks by, inter alia, community and faith leaders or groups and the media. See UN Doc. A/HRC/25/55,
23 December 2013, para. 104.
64
Guidelines on the Protection of Human Rights Defenders
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