DRF held a number of consultations with its Network of Women Journalists for Digital Rights (NWJDR) as well as other journalists to discuss the Journalists Safety, Welfare and Protection Bill and propose recommendations to the Ministry of Information. The recommendations are as follows:

1. Impartiality and transparency

   1. If contributions to the safety fund can be made by any entity, there must be mechanisms in place to ensure that donors cannot assert their will as to where/how the funds are utilised.
   2. Some journalists believe that the funding sources ought to be regulated as it will be impossible for the council, prosecutor, fund etc to stay impartial if majority of the funding comes from a single source.
   3. Mechanisms must be in place to ensure that the council remains independent in fulfilling its duties.
   4. Mechanisms must be in place to ensure that the Special Prosecutor under the bill, who will make major decisions under the bill, including who to prosecute, is able to make these decisions without being swayed. This is especially important as some cases may be against state agencies.

2. Scope and Definitions

   1. Although the bill is fairly inclusive, it should be more explicit in recognising freelance / independent journalists in order to ensure that key stakeholders, who are sometimes the most vulnerable, are not left out.
   2. Protections to apply to print, electronic and social media equally so that the right to freedom of expression is extended to all forms of media.
   3. Protection against criminal and civil action for defamation and reporting on issues of public importance.

3. Enforcement

   1. The bill should include provisions that make it mandatory for media houses to maintain certain workplace standards including separate bathrooms for men and women, maternity leave, reporting mechanisms for harassment, regular training for journalists’ physical security
   2. The bill should directly penalise media houses that do not maintain these standards.

4. Digital Safety

   1. Seeing as digital spaces have created large scale expansion of the mediums of expression used by journalists, the bill ought to include digital safety and security of journalists (as online violence can lead to physical violence).
   2. Journalists should not be barred from using VPNs.
   3. Reporting of online harassment cases should be streamlined through the National Response Center for Cyber Crime (NR3C), FIA taking up cases with urgency.
   4. Withdraw notification on regulating encryption-based communication.
   5. Guidelines and regulations for media houses to implement digital security and safety of their employees.

5. Accessibility

   1. This Bill should be applied to the peripheral regions of Pakistan, such as Gilgit-Baltistan.