November 9, 2023
To: Mr. Abdulmajeed Melhem, Chief Executive Officer of Paltel Group
Re: Internet and telecommunications shutdowns and disruptions in Gaza
Dear Mr. Melhem,
We are writing to you on behalf of Human Rights Watch and Access Now with regards to the ongoing disruption of internet and telecommunications services in the Gaza Strip.
Human Rights Watch is an independent, nongovernmental organization that monitors and reports on human rights in over 100 countries around the world, including Israel and Palestine, where we have worked for more than three decades. Access Now is an international, non-governmental organization which works to defend and extend the digital rights of people and communities at risk globally, including in Palestine. Since 2016, Access Now leads the #KeepItOn coalition which comprises more than 300 organizations from 105 countries, including Human Rights Watch, fighting internet shutdowns around the world.
Since October 7, 2023, we have been monitoring and investigating disruptions to telecommunications and internet services in Gaza, including the complete and prolonged shutdowns of the last two weeks.
In order to better understand what transpired, we are seeking your comment on disruptions to telecommunications and internet services (mobile, fixed line, mobile broadband and wifi internet services) on Paltel Group’s networks in Gaza, including Jawwal and Hadara.
We request that you respond to the following questions by end of day November 14, 2023, so that we can incorporate Paltel Group’s response and perspectives in our reporting.
Thanks in advance for your attention to our questions and please feel free to include any other information you consider relevant. We would also be open to discussing these questions in an online meeting, if you prefer.
1. On October 27, both Paltel and Jawwal attributed the complete shutdown of internet and telecommunications services due to “the continuous intensive bombardment that caused cutting off all remaining fiber routes that connect Gaza to the rest of the world.” In an interview with the New York Times, the outlet quoted you as saying, “the company had made no repairs and had no understanding of how or why service had partly returned.” To what does Paltel Group attribute disruptions to telecommunications and internet services on October 27-29, October 30 (in northern Gaza), November 1, and November 5, 2023? If disruptions occurred after November 5, to what do you attribute those disruptions?
2. What parts of Paltel Group’s infrastructure have been damaged to date? Can you share details of infrastructure impacted in the hostilities, with specific location, date, and time information as to the damage, and services disrupted? Do you have any information to indicate what caused the damage in each case?
3. What changes in data and internet traffic patterns, load, types, and destinations of traffic have you observed? Are these correlated to the events in the conflict?
4. What impacted infrastructure has Paltel Group managed to repair to date? What is required for the full restoration and repair of severed or disrupted telecommunications lines and infrastructure?
5. Did you receive any prior notice from Israeli authorities before the telecommunications and internet disruptions? If so, can you provide details about that communication? Have you received any other correspondence from Israeli authorities relating to the shutdowns?
6. On October 13, Israel’s telecommunications minister was quoted in the media as saying that all internet service would be cut off in Gaza from October 14. Did Paltel Group experience any disruptions to its services on October 14 following this announcement?
7. What steps have Paltel Group taken to ensure, to the extent possible, their telecommunications and internet services remain accessible and secure in Gaza?
8. Can you detail what essential or emergency services are operative or inoperative when these disruptions occur?
9. A number of civil society organizations, including Access Now and the Palestinian Digital Rights Coalition, have called on the Egyptian authorities as well as Egyptian telecommunications companies to expand their services to the Gaza Strip.
a. Is Paltel in contact with your Egyptian counterparts to support such potential actions?
b. Should Egyptian telecommunications companies install mobile cell sites near Egypt’s border with Gaza, would Jawwal be able to enable roaming services for its customers in Gaza to connect to Egyptian mobile networks? If not, what hinders Jawwal from doing so?
Deborah Brown, Senior Researcher, Technology and Human Rights Division at Human Rights Watch
Marwa Fatafta, MENA Policy and Advocacy Director at Access Now