Recommendations: The report concludes with recommendations to: Tech companies: a.Conduct thorough Human Rights Impact Assessments (HRIA) before launching data centers in new markets and make the findings of these assessments public. b.Delineate the users’ or companies’ legal liability for human rights violations. c.Disclose the process for handling government demands for users’ data. d.Publicize data on numbers and types of government demands. Civil society: a.Research, document, and publicize the implications of data centers in the Gulf on human rights. Conduct extensive research on: i) possible implications of technologies that will be transferred to GCC dcdcountries through the construction of these data centers; ii) the impact of the construction of these data centers on data flows dcd around the wider WANA region. b.Pressure Big Tech companies operating in the Gulf to ensure transparency and respect for human rights through public campaigns. US Policymakers: a.US policymakers should create a law that requires US-based companies to manage human rights risks related to their activities. i) The law should regulate the activities of subsidiaries, suppliers, and xxssubcontractors connected to the company, especially when they have waaccess to data. ii) The law should state that companies must: -Establish, implement, and publish their own HRIA. -Include risk mapping, a risk mitigation plan, periodic compliance assassessments, and an efficiency monitoring scheme in their HRIA. b.Finalize the National Action Plan on Responsible Business Conduct.

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