In this inaugural RDR Telco Giants Scorecard, none of the 12 telecommunications companies we evaluated earned a passing grade. Though Big Tech companies have stolen the spotlight in recent discussions of the ills of our information systems, our findings show that, year after year, telcos perpetuate the same digital rights harms while facing far less scrutiny. And yet, despite being less visible than their Big Tech counterparts, telcos wield far more power.This is especially true where telcos are government-owned, in part or whole, and where they operate in authoritarian or authoritarian-trending regimes. To realize a global internet that is more accessible, inclusive, and supportive of human rights, these companies must also be held accountable.

The 2022 RDR Telco Giants Scorecard is part two of the sixth edition of our rankings, formerly known as RDR Corporate Accountability Index. For the first time this year, the RDR Index was divided into two parts; the Big Tech Scorecard was released in April. The Telco Giants Scorecard analyzes 12 of the biggest global telecommunications companies, headquartered in 10 different countries. We look at more than 250 aspects of their company policies that affect people’s human rights, focusing on corporate governance, freedom of expression, and privacy. This marks the first time that we have evaluated telecommunications companies separately from digital platforms.

The 2022 RDR Telco Giants Scorecard

• For the third year running, Spain-based Telefónica came out on top, primarily due to expanded human rights risk assessments as well as disclosures noting that it does not comply with private requests for censorship or user information. This year marked the first time it came out on top across all three categories.
• South African company MTN posted the greatest score improvement this year, gaining 11.42 points, followed by Mexico’s América Móvil, whose score increased by 8.47 points. MTN also joined the multi-stakeholder forum Global Network Initiative (GNI) and implemented other RDR recommendations.
• Qatari company Ooredoo and the UAE’s e& (formerly Etisalat) landed at the bottom again this year, holding onto the last-place positions they’ve occupied since we started evaluating them. These companies continue to disclose very little about their policies and practices related to freedom of expression and privacy.
• The scores for most European telcos—France’s Orange, Norway’s Telenor, and the United Kingdom’s Vodafone—declined slightly.

Did you know: Telcos target us with ads, too?

Telcos are engaging heavily in targeted advertising, via a wide range of seldom-discussed tactics, and they are even less transparent about their involvement in ad targeting than digital platforms.

While many of us have come to associate the growth of targeted advertising with digital platforms like Facebook, the targeted advertising activities of telcos, including most of those we cover in our Telco Giants Scorecard, have slipped under the radar. But when telcos engage in targeted advertising, it raises many of the same human rights concerns that have been extensively documented in the case of digital platforms, including discriminatory or inaccurate content algorithmically boosted to large audiences and an incentive to collect as much user data as possible.Telcos are facing multiple incentives to keep expanding their involvement in targeted ads. For one, their calling, texting, and cable service revenue is being undercut by internet-based alternatives. In addition, telcos’ body of user data tends to be more precise than that of platforms, increasing its value.Due to the incentives telcos face at present, we expect these practices to increase going forward. Read more in our essay on telcos and targeted ads.

To keep up with these trends, we added standards to our methodology in 2020 to draw attention to the underappreciated role of the targeted advertising business in generating digital rights harms. These indicators made clear that the majority of the telcos we rank lacked transparent and comprehensive policies to ensure that they do not contribute to the placement of discriminatory, misleading, or hateful advertisements. Nor did these companies demonstrate the existence of functioning ad-policy enforcement processes or perform human rights impact assessments on their advertising technologies.

Since 2020, we’ve seen marked improvement from only one company: Telefónica. This year, it became the first ranked telco to systematically assess the human rights impact of its targeted advertising activities. Most telcos were stagnant, though MTN lost credit because its disclosures about targeted advertising referred to a shuttered program.

We also began compiling supplemental data describing the specific targeted advertising activities each of our ranked telcos wasinvolved in this year. We found evidence that all of our 12 ranked telcos were involved in targeted advertising in at least one way. These practices included location-based advertising, deployment of addressable TV ads, the use of identity systems, and the operation of ad networks. Airtel, Orange, Ooredoo, Vodafone, and Malaysia’s Axiata were the companies most heavily involved in these activities.

The Good News

The 2022 RDR Telco Giants Scorecard marks the first time all 12 ranked telcos have published a general commitment to both freedom of expression and privacy in their operations. The majority of companies evaluated have also established board-level oversight of these commitments and provided relevant training for staff.

In another first for our ranking, every company we ranked published something about how it responds to network shutdowns. Network shutdowns are among the most severe manifestations of how governments weaponize telcos to curtail free expression, and greater transparency in this domain is vital for safeguarding the fundamental rights of internet users and their communities.

As a group, the companies we evaluateshowed improvements in all three categories in our ranking system: governance, freedom of expression, and privacy. Their scores on freedom of expression still lagged behind their scores in other categories, but showed the greatest rate of improvement.Almost as encouraging is what did not happen: No company’s score declined more than half a point in our ranking.

The order of the top five telcos in our ranking did not change since the 2020 RDR Index. In total, three-quarters of companies made at least minor net improvements to their disclosed policies affecting privacy and freedom of expression.

Top-ranking Telefónica broke new ground by sharing data in several areas where other telcos still disclose no information. This includes the existence of a human rights due diligence process related to its zero-rating programs as well as its use of targeted advertising—a first for the industry in both cases.Six telcos improved on human rights due diligence, leading to score improvements in the governance category. Other notable improvements included:

• South Africa’s MTN boosted its score the most this year, followed by Mexico’s América Móvil. The two companies published their first-ever transparency reports during the evaluation period, the first companies to do so in Africa and Latin America. Thanks to these improvements, both companies surpassed France’s Orange in this year’s ranking for the first time.
• AT&T, the sole U.S.-based company in our ranking, was fully committed to net neutrality and did not provide any zero-rating plans.

• Germany’s Deutsche Telekom earned full credit on our standards for security oversight by disclosing that it limited employee access to user information and conducted regular internal and external security audits.

This year was also the first time that every telco we rank published a report explicitly covering ESG (environmental, social, and governance) issues, putting swaths of new information into the hands of both investors and the public. Read more in our essay: “ESG investors take note: Companies are responding to pressure on digital rights.”

The Bad News

Despite group-wide gains among telcos this year, all but one company still received a failing score. Also concerning was the fact that improvements were driven by just a few companies. The scores of most European telcos—France’s Orange, Norway’s Telenor, and the UK’s Vodafone—declined slightly. And, once again, Ooredoo and e& languished at the bottom of our Scorecard due to an almost complete lack of transparency. Digital rights organizations have used RDR’s methodology to document inconsistencies in policies between parent companies and subsidiaries, with poorer transparency and commitment to human rights in the latter. This is notable since governments may mandate certain practices that companies could not be compelled to take in their home jurisdictions, such as ordering a network shutdown, the release of a user’s information to the authorities, or the blocking of certain URLs.

Telcos have a major freedom-of-expression blind spot

Freedom of expression remains a serious weak spot for all telecoms. Average scores in this category were much lower than in the governance and privacy categories. This is a long-standing trend in our rankings.

Alarmingly, none of the telcos improved their transparency around the enforcement of their own policies, such as detailing the behavior that triggers account suspensions and how prevalent those suspensions were. In fact, this was one of two areas in this year’s Telco Giants Scorecard where we recorded an overall score decline. Additionally, a third of the ranked telcos still failed to disclose how many times governments of the various countries in which they operate demanded data about their users or why.

Despite the threats to freedom of expression that zero rating poses , 10 out of the 12 telecommunications companies we rank offered zero-rating plans as of June 1, 2022. At a minimum, RDR expects companies that make use of zero rating to conduct human rights risk assessments to identify and mitigate harms. Only Telefónica revealed that it conducted human rights risk assessments in this area. And despite making some sort of commitment to net neutrality, América Móvil, Deutsche Telekom, Telenor, and Vodafone still provided zero-rating services in their home markets. Find out more about our findings pertaining to net neutrality and zero-rating practices.

Combined with weak industry-level disclosures in other areas, this year’s results clearly show that freedom of expression remains an enormous blind spot for telcos—one that powerful actors will eagerly exploit. For example: Despite vigorous resistance from civil society and major recent UN reports, network shutdowns remain one of the favorite tools in the authoritarian toolbox. In 2021 alone, Access Now and the #KeepItOn coalition documented 182 shutdowns across 34 countries. Read more in “Transparency improves on shutdowns, but telcos still weakest on free expression.”

Weak privacy scores could signal growth in telco-enabled surveillance

Telcos enable major privacy violations, which may be used to facilitate various forms of commercial and even government surveillance, yet telcos share little about how they protect users from these risks.

Companies we ranked this year showed a systemic disregard for users’ right to know about how their data is handled. They provided few details about how they collect data directly from users or what they share and with whom. They also disclosed very little, or in some cases nothing at all, about how they collect user information via third parties, such as from data brokers or financial institutions. Although telcos engage in targeted advertising, building user profiles based on inferred data, eight companies, including América Móvil, MTN, and Telenor, failed to share any information about what data they infer.

Problematically, the telcos we rank also provided limited options for users to control the use of their personal data. Four companies—Axiata, e&, Ooredoo, and Vodafone—shared no information at all.

The lack of privacy safeguards, combined with close ties between governments and telcos that are essential to the latter’s operations, means that operators sometimes end up aiding government-led violations of human rights. Four companies we rank operating in weak democracies or under authoritarian regimes—Airtel, Axiata, e&, and Ooredoo—shared little or no data about how they handle government demands for user information and revealed nothing about the volume or nature of such requests.

Telcos are even more opaque about how they manage private, as opposed to government, requests for user information. Only América Móvil and Telefónica disclosed clearly that they do not respond to private requests. Read more about telcos' weak record on privacy.

Conclusion

As the primary providers of internet access across the globe, telcos provide the critical infrastructure for the realization of our human rights online. Recent public focus on Big Tech platforms and their hazards has overshadowed the various ways telco companies can also undermine our rights to both freedom of expression and privacy.

In important ways, telcos, whose operations are much more intimately tied with governments, also perpetuate harms that digital platforms do not. From government-mandated shutdowns of internet services to the use of zero-rating programs, among other examples, the effects of telcos’ policies and practices are in desperate need of attention.

Read the full 2022 Telco Giants Scorecard for in-depth examination of these issues, key takeaways about the sector and detailed company analysis.