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Photo: "Biometric Identity" by Kevan, shared under CC BY-NC 2.0 licence (

The Association for Progressive Communications (APC), Derechos Digitales and Media Matters for Democracy welcome the opportunity to provide this submission on the human rights impacts of the introduction of digital technologies in the implementation of national social protection systems (NSPS).

As a point of departure, we recognise that digital technologies can have a role to play in delivering social protection benefits efficiently. However, caution must be exercised by all stakeholders to ensure that the use of such technologies is cognisant of the existing and potential risks. In practice, these technologies are often presented as a solution to a problem that has not been clearly defined, and this raises concerns of creating new challenges or exacerbating existing ones.

In particular, we focus on selected aspects raised in issues 3 and 4 of the call for submissions. This submission is structured as follows:

  1. The human rights implications and the balancing of competing rights

  2. The practical challenges in accessing digital technologies in NSPS

  3. The potential for exploitation in the use of digital technologies

  4. The potential for bias and exclusion in the use of algorithms

  5. The need for appropriate policy and regulatory frameworks

  6. The need for meaningful engagement, impact assessments and review

  7. The impermissibility of retrogressive measures.