Business needs a life cycle approach to capture emerging and systemic human rights problems. This would allow it to identify, address and eradicate systematic distortions that have negative impacts on human rights in datafied environments. “Data universalism” needs to be replaced with context-specific, robust human rights due diligence processes that keep companies’ local embeddedness in mind.

Civil society may need to develop new methods to hold companies accountable for “digital” human rights violations. This point is closely connected to the public policy debate on the state duty to protect human rights, including digital rights.

Policymakers should take digital rights into account in policy proposals on human rights due diligence for business and revisit whether existing protection can still cover emerging digital issues. Legislators should strengthen digital rights in the coming years and strategically connect them to other legislative debates on human rights due diligence.