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Statement on the Restrictions Envisaged Under Martial Law

January 12, 2023, Yerevan

From December 22, 2022 to January 6, 2023, the draft on making amendments and supplements to the RA Law “On the Legal Regime of Martial Law” was submitted for discussion by the RA Ministry of Justice on, the unified website for publication of legal acts’ drafts. According to the proposed changes, in case of declaration of martial law, points 13-15 of the revised Article 8 of the mentioned law envisage:

  • restriction of freedom to express an opinion, as well as temporary confiscation or detention of printing devices, radio broadcasting, sound amplifying equipment, copiers, establishment of a special procedure for accreditation of journalists, and special rules for using communication means;
  • restriction of content broadcast on television and disseminated via the Internet, ensuring the showing of movies and TV programs, as well as dissemination of information with exclusively military-patriotic content;
  • temporary suspension (blocking) of websites, social networks, Internet applications, as well as partial or complete restriction of Internet access in the territory of the Republic of Armenia.

We, the undersigned organizations, mindful of the need for certain restrictions under martial law, nevertheless, express our conviction that the above-mentioned provisions of the draft law in this form are not based on proper discussions, assessment of apparent risks and analysis of possible highly negative consequences, and therefore should be fully rejected.

From a purely professional standpoint, these provisions are so vulnerable and raise so many questions that we consider it pointless to dwell on them in detail. We also express our deep concern that in a country presenting democracy as a national brand the government has published such a document.

There is no doubt that especially under martial law even greater importance is attached to the fight against fake news, disinformation, hostile propaganda and cyber-attacks. However, the related legal regulations should be reasonable, clearer so that no loopholes are left for arbitrariness. If the authorities are prone to this approach, then they simply must present to the public the problems encountered, the justifications and measures for their urgent solutions, and only after that come up with a legislative initiative.

Considering the above, we demand from the RA government:

  • to refrain from officially circulating the draft law and hold public discussions on the topic from scratch, starting with the analysis of the idea;
  • to form a working group that will clarify the goals and objectives of the proposed amendments and draft a new bill based on that, keeping it free from formulations that would allow for subjective interpretations and arbitrary actions;
  • to submit the new version of the draft law for international examination;

to discuss the possibilities of consulting expert circles when deciding to apply restrictions in the conditions of martial law, as well as to develop mechanisms for exercising public supervision over the execution of these decisions.












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Armenia -- AI Generated image Samvel Martirosyan AI Research, Yerevan, 22Dec2022

Problems of Machine Processing of Personal Data in Armenia

Armenia does not have specific regulations for the use of artificial intelligence, machine learning, or similar technologies, as well as data processing through them. The main tool is the Law “On Protection of Personal Data”, adopted in 2015[i].

According to Article 5 of that Law (“Principle of Proportionality”):

1. The processing of data must pursue a legitimate purpose, and measures to achieve it must be suitable, necessary, and moderate.

2. The processor of personal data shall be obliged to process the minimum volume of personal data, which is necessary to achieve legitimate purposes.

3. The processing of personal data that are not necessary for the purpose of the processing of data or are incompatible with it shall be prohibited.

4. The processing of personal data shall be prohibited where the purpose of data processing is possible to achieve in a depersonalized manner.

5. Personal data must be stored in such a way as to exclude the identification thereof with the data subject for a period longer than is necessary to achieve their predetermined purposes.

The law or other by-laws do not separate the processing of personal data from the use of artificial intelligence, machine learning, large numbers, or other technologies of the kind. It is not taken into consideration that such data processing techniques pose additional risks, both in private and public life.

Thus, in the personal data processing regulations of three mobile operators, which are among the main large-scale processors of personal data, there is absolutely no information on the use of algorithms, and data processing through machine learning[ii].

This topic is not discussed either at the legislative level or during public debates. Meanwhile, regularly there appear programs in Armenia where such processing is either carried out or can be noticed.

Mass processing of personal data and their use in public life

On December 13, 2017, it was reported that Vahan Martirosyan, Minister of Transport, Communication and Information Technologies of Armenia, received the representatives of the Chinese company Huawei Technologies. The meeting participants discussed issues related to the implementation of the “Smart City” project. In the same month, the Ministry and Huawei Technologies signed a memorandum of understanding on the implementation of the Project.

The memorandum was signed by Boris Demirkhanyan, Deputy Minister of Transport, Communications and Information Technologies of Armenia, and Cao Chun, Vice President of Huawei Technologies. The main idea is smart city management (intellectualization), which implies regulating public life in Yerevan through the use of the latest big data processing technologies[iii]. However, after the 2018 change of government in Armenia, the negotiations were suspended. Updates about the program were terminated as well[iv].

Nevertheless, the idea of mass data processing did not cease to exist. Yerevan Deputy Mayor Tigran Avinyan has stated that there are a number of areas where artificial intelligence may be used, and can ensure innovation in those fields. According to Avinyan, artificial intelligence can be used, for example, in education. “There are many areas where artificial intelligence has provided, is providing, and should provide innovation and improvement. We use lots of similar things, such as face recognition or when artificial intelligence tools help improve the lives of city-dwellers.”[v]

In parallel, structures and systems are being formed. In the summer of 2022, the “Police Video and Photo Recording Electronic Systems Management Center” a state non-commercial organization (SNCO) under the Police was established. It is expected to merge with the “Parking City Service” CJSC, which delivers parking services in Yerevan, as well as with the video recording systems of pharmacies, arms sales companies, retail facilities, commercial areas, public catering facilities, domestic service facilities, casinos and gambling halls[vi].

With the proposed new project, the SNCO will track public transport online. The Police propose to equip bus and minibus aisles with a high-quality video surveillance system, with the possibility of recording in the dark and storing the footage for at least 10 days[vii].

Citizen surveillance during the COVID-19 quarantine

During the quarantine implemented due to the COVID-19 pandemic, the Armenian Government declared a state of emergency on March 16, 2020[viii].

A few days later, the National Assembly, in fact, authorized the Government to track all residents of the country using the data collected by mobile operators.

Based on that decision, the Government installed a special software, which, through machine learning and big data, processes the metadata of all phone calls (who called whom, when, how long the conversation lasted), short messages, and geolocation data received from all three mobile operators. On April 7, 2020, the system was already in effect[ix].

In order to find out the circle of contacts of infection carriers, the obtained data were collected and stored on the server of the e-Governance Infrastructure Implementation Agency  (EKENG). The maintenance and security of the special computer program are under the supervision of the National Security Service. The Government did not disclose the developers of the software that runs the surveillance system. In response to the “Hetq” inquiry, on behalf of Commandant Tigran Avinyan, Serge Varag Siseryan, Head of the Deputy Prime Minister’s Office, noted that “the computer program [for tracking people through calls] was created by Armenian volunteer programmers.”[x]

The system operated until September 25, 2020, after which the hard drives containing the data were destroyed in the presence of the representatives of the Government, National Assembly and three mobile operators[xi].

Throughout the operation of the system, no public oversight mechanism was ever created, which would allow to make sure that the data were not used by the NSS for other purposes, and that they were not transferred to a third party (given the fact that the Government never disclosed the information on the company that created the system) or that all possible copies of data were destroyed.


The Armenian legislation does not take into account that massive and algorithmic processing of personal data provides an opportunity to obtain additional data that can be used to impact social developments[xii]. Added to that, there is no consideration of the fact that the incorrect or directed use of algorithms and data processing may become discriminatory[xiii].

The processing and use of personal data by artificial intelligence and algorithms require additional focus and a deeper consideration than there was before the widespread use of new technologies, which process large amounts of data[xiv]. Overall, the problems that may arise in the case of massive machine processing of personal data are outside the public discourse and focus. In fact, no adequate awareness of the problem is provided by the state. No appropriate legal base is formed, and the existing legislation is not updated. The public, in its turn, does not take steps to establish control in the field.

[i] Law “On Protection of Personal Data”,

[ii] Viva-MTS, Privacy policy;

Ucom, Personal data processing policy;

Team Telecom, Privacy policy

[iii] Huawei “Smart City” Pilot Project Will be Implemented in Armenia, 16.03.2107,

[iv] Armenia Freedom On The Net Report, 2019,

[v] Tigran Avinyan emphasized the use of artificial intelligence in several fields, 05.10.2022, 

[vi] The RA Police Chief Decree on the Approval of the Statute of “Police Video and Photo Recording Electronic Systems Management Center” SNCO, 09.08.2022  

[vii] VIDEO, Cameras to be installed on buses and minibuses: a new draft law, 01.12.2022,   

[viii] Armenia Cabinet approves bill on declaring 30-day state of emergency over coronavirus, 16.03.2020,

[ix] Commandant’s Office: the system to track the movement and circle of phone calls of citizens already in effect, 07.04.2020,

[x] Armenia: Security Concerns Raised about the Computer Program Tracking the Movement of Coronavirus Carriers, 07.05.2020,

[xi] Protocol, 25.09.2020,

[xii] The man that killed Cambridge Analytica: ‘We made mistakes, but they aren’t what you think’, 28.08.2019,

[xiii] The Toronto Declaration: Protecting the right to equality and non-discrimination in machine learning systems,

[xiv] #BigData: Discrimination in data-supported decision making,

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wiretapping of phones, sophisticated, digital tools, control over citizens deeper and more comprehensive

Phone call and phone surveillance in the Republic of Armenia

The Armenian legislation quite clearly defines the surveillance of phone and electronic communication. Only a few structures, including the RA National Security Service, the Police, and the Anti-Corruption Committee, have extensive wiretapping capabilities.

On the other hand, there are no clear-cut mechanisms that would allow to make this sector transparent and accountable to the public.

The latest developments suggest that things are changing in the country, and apart from the traditional wiretapping of phones, more sophisticated, digital tools are emerging, making the control over citizens deeper and more comprehensive. This, in turn, raises concerns on whether these tools will be used within the law, in line with the requirements of democracy and civil liberties.

Legislative and institutional regulations

The main legislative regulation is carried out within the framework of the law ON OPERATIONAL INTELLIGENCE ACTIVITIES, which was adopted in 2007 and has been revised and supplemented several times since then[i].

The law determines the state bodies that have the right to monitor phone communication. According to Article 14 of the Law (Types of operational intelligence measures), these are the Police, National Security Bodies, and the Anti-Corruption Committee. Apart from that, the bodies of the penitentiary service have the right to conduct wiretapping, but only in the premises of the penitentiary institutions of the RA Ministry of Justice.

It should be noted that the RA Anti-Corruption Committee is a newly established structure in the law enforcement system: it was established and has been operating since October 23, 2021.

Until January 2020, the Police did not have either the opportunity to conduct wiretapping on their own. They used the capacities of the National Security Service, which made the NSS extremely influential in the field of wiretapping. Moreover, the data collected for the Police actually appeared at the disposal of the NSS as well. The RA National Assembly initiated changes in the Law “On Operational Intelligence Activity”, which turned the Police into an independent structure in this matter, creating some counterbalance to the NSS. However, during the discussions at the National Assembly it became clear that the Government had a completely different approach to this issue – to create a separate independent organization and transfer the right of wiretapping to it[ii].

According to Article 26 of the Law, digital, including telephone communication surveillance embraces the following:

1. in the case of a fixed or mobile telephone network the content of telephone conversation, text, image, audio, video and other messages, the subscriber’s incoming and outgoing calls, the telephone numbers indirectly related to the subscriber, the time of starting and ending the telephone communication, and in case of call forwarding or transferring, the phone number to which the call was transferred;

2. in the case of Internet communication, including telephone communication via Internet and electronic messages transferred via Internet, the content of the communication, incoming and outgoing calls via Internet (each data in such a form that allows or may allow to identify the communicator);

3. when implementing the operational intelligence measures envisaged by this Article, the telecommunication organizations are obliged, upon the request of competent authorities, to provide technical facilities and create other conditions necessary for the conduct of operational intelligence measures.

According to Article 9 of the Law, the implementation of digital, including operational intelligence measure of wiretapping is ensured only by the general operational technical department functioning within the system of the Republican National Security Body of the Republic of Armenia. That body is directly managed by the head of the NSS. And the head of the General Department is appointed and dismissed from the position by the Prime Minister.

The General Department ensures the necessary operational and technical conditions for telecommunication operator.

The surveillance of digital and telephone communication by the police, penitentiary service or the Anti-Corruption Committee is carried out by creating operational and technical conditions, including the provision of channels and resources by the General Department. At the same time, the law requires that the National Security Service excludes the supervision and corroboration of these data, information and reports, if the wiretapping party is not the NSS itself.

Wiretapping can be carried out only in cases where there are apparent grounds to suspect that the person to whom they are to be applied has committed a serious or particularly serious crime, and it is reasonably impossible for the body conducting the operational intelligence measure as assigned by the Law to obtain the necessary information in any other way.

It is noteworthy that the collection of such data is prohibited when the targeted person is communicating with his/her lawyer, representative or legal representative. If such data are obtained for any independent reason, then the information containing legal secret is subject to immediate destruction.

Article 32 of the Law states that wiretapping is carried out on the basis of a court decision. In cases when delay in implementing an operational intelligence measure such as digital, phone communication surveillance,  may result in an act of terrorism or in events or actions threatening the state, military or environmental security of the Republic of Armenia, the General Department ensures the implementation of these measures. However, the body that applies to the General Department must within 48 hours submit to the General Department the excerpt of the decision of the court on permitting or denying permission to undertake those measures.

Article 39 reads that the term for the decision to conduct an operational intelligence measure is calculated starting from the day of its adoption and cannot exceed 2 months. The decision period may be extended. Moreover, each court’s permission can be given for a period not exceeding two months. And the overall term cannot last more than 12 months.

The developments in Armenia

In recent years, along with the increase in the possibilities of digital surveillance, there has also been an increase in cases that may be considered as abuses of law.

In 2020, under the circumstances of the COVID-19 pandemic, the RA government made several attempts to oversee people’s social connections and movement through phones.

On March 31, 2020, the RA National Assembly adopted the proposal to amend the draft laws “On the Legal Regime of the State of Emergency” and “On Electronic Communications.”[iii] According to those amendments, the Government was awarded the right to receive from all mobile operators, collect and process in one place information on all the residents of the country, namely the metadata of phone calls and short messages and the location data collected by mobile operators. Based on those data, a system was created that was supposed to identify the possible circle of people infected with coronavirus. The NSS was appointed as the coordinator of the project, and the technical implementer was an undisclosed private company. On September 25, when the state of emergency was lifted, all collected data were destroyed in the presence of the mobile operators’ representatives.[iv]

A number of issues, however, lacked transparency:

a. No public oversight mechanism was created. No guarantee was given that the system had not been used for other purposes, such as identifying specific people and their connections.

b. It remained unclear who created the system.

c. According to the law, the data collected by the system were to be destroyed at the end of the state of emergency. Since there was no independent supervision over the system, there is no guarantee that the data were indeed fully destroyed, and moreover that the system is any longer functioning.

On November 24, 2021, several dozen people in Armenia received emails from Apple, which alerted that they had been allegedly attacked by a state-sponsored hacking group. CyberHUB-AM is aware of more than twenty such cases in Armenia. This was global in nature: the alert disseminated by Apple did not refer only to Armenia. It is worth reminding that a few hours before receiving the emails, Apple had announced that it was suing the Israeli NSO Group, which creates and sells spyware to government agencies for intelligence operations. The program’s name is Pegasus, and most probably the email was addressed to the potential victims of this program.

Some announced publicly that they had received similar emails. Artur Vanetsyan, former head of the National Security Service, currently one of the leaders of “With Honor” opposition parliamentary bloc, was one of them[v]. The other one was Davit Sanasaryan[vi]. Later, lawyer Anna Karapetyan informed about a similar thing[vii]. The Minister of High-Tech Industry Vahagn Khachatryan (currently the President of Armenia) also told journalists about receiving an email from Apple[viii]. According to cyber security expert Ruben Muradyan, he had discovered Pegasus on Vanetsyan’s and his relatives’ phones 2 months earlier[ix]. It should be noted that before that Armenia had never appeared on the list of countries that use Pegasus at the state level. There is also an assumption that it was used by the special services of a third country. Given the list of possible infected users and the fact that everyone received the email with an alert at the same time, it can be assumed that Apple could have included several waves of attacks in one phase of warning campaign. It is quite possible that we are dealing with several cases where the infections, for example, could be conditioned by external and internal political reasons, since all the users infected with the spyware could hardly be of interest to one party that carried out an attack.

If in the case of Pegasus there were doubts that some of those who received notifications could be a target of a domestic attack, but there were no real clues, the situation changed at the end of the year. On December 16, 2021, for the first time, Armenia as a state directly appeared on the list of countries that use spyware to infect and spy on people’s phones within the country. This was discovered by Facebook[x] and CitizenLab[xi]. The target were politicians and people related to media. Spyware for Android and iPhones produced by Macedonian company Cytrox was used. The virus was disseminated through fake links mimicking real websites, for example, youtu-be[.]net. There were also cases of infection attempts through SMS and messages sent via messengers. Later, Google, referring to this topic, clearly stated that, in their view, this had been carried out by the state structures of the Republic of Armenia: “Consistent with findings from CitizenLab, we assess likely government-backed actors purchasing these exploits are operating (at least) in Egypt, Armenia, Greece, Madagascar, Côte d’Ivoire, Serbia, Spain and Indonesia.”[xii]

Of course, there is no clear evidence on the use of Pegasus by Armenian state structures. The beneficiary of the use of Predator is not clearly known either. On the other hand, according to Point 3 of Article 7 of the Law “On Operational Intelligence Activity”:

“The use of special technical and other means envisaged (developed, planned, adjusted) for obtaining confidential information and implementation of operational intelligence measures by state authorities, subdivisions or natural and legal persons not authorized under this Law shall be prohibited.” This implies that there has been published a report on a crime, on the basis of which a criminal case should have been initiated. Nevertheless, the Police or NSS have not disseminated such information.

It turns out that one of the major problems today is the lack of any mechanism of public oversight in this field. There is no possibility to oversee the activities of power structures, as all the work is basically a state secret. According to the Law ON OPERATIONAL AND INTELLIGENCE ACTIVITIES, during the entire implementation period of operational intelligence measures the information with regard to forces, means and resources, methods, plans, results of those measures, financing thereof, as well as secret staff members of bodies carrying out operational intelligence activity, including persons cooperating or having cooperated, on a confidential basis, is deemed to be a state secret. And Armenia, in fact, has no efficient public oversight mechanisms that would allow to make accountable those structures that operate under the umbrella of state secrecy. Thus, civil society has no toolkit to monitor the situation or influence it.


[ii] The police have been allowed to tap phone conversations,

[iii] Armenia: Parliament Passes Bills to Access Mobile Phone Data to Identify Covid-19 “Contact Circles”,

[iv] “Statement on destruction of information and storage devices [in Armenian],” Government of Armenia, September 25, 2020,

[v] Artur Vanetsyan’s post –

[vi] Davit Sanasaryan’s post –

[vii] Anna Karapetyan’s post –

[viii] The video of Vahagn Khachatryan’s statement –

[ix] Ruben Muradyan’s post –

[x] Threat Report on the Surveillance-for-Hire Industry, December, 2021,

[xi] Pegasus vs. Predator, 16 December, 2021,

[xii] Protecting Android users from 0-Day attacks, May 19, 2022,

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Armenia -- Impact of Azeri shelling of resourt town Jermuk, 13Sep2022

EaP CSF Armenian National Platform statement on Ilham Aliyev’s aggression

Azerbaijani authoritarian regime’s attack on the sovereign territory of Armenia, launched on September 13, is another violent wave of the long-lasting conflict that continues to destroy infrastructures, and harm nature. As a result of this new war, 135 militaries were killed on the Armenian side, and over 20 prisoners of war were taken. 1 civilian was killed and 6 received injuries of various degrees as a result of the shelling of the civilian population. There are reports of continued practice of mutilation of the bodies of the military, including women[1], and other war crimes. The number of people displaced from densely populated towns of Jermuk, Goris, Kapan, Vardenis, etc. is 2750, including 370 children and 55 people with disabilities[2].

The post-44-day war negotiations have illustrated that even though each conflict escalation may have a winning and a losing side, there is no conflict resolution through violence because they are followed by rounds of talks and negotiations that are aimed at finding a common denominator and preventing the conflict from further development. It is also important to understand that each violent phase of the conflict makes the possibility of finding a common solution more and more difficult and sustainable peace in a long-term perspective a vague illusion for the people of the region.

The violence and deaths of soldiers and civilians are direct consequences of a lack of democracy, constant violations of human rights, and illegitimate occupation of power by groups of people who are willing to centralize the resources and the wealth in their hands. These people do not care about the lives of either their neighbors or their compatriots, they exercise all possible measures to manipulate, mislead, fool, silence and frighten their societies and opponents via propaganda and repressions.

This act of aggression against Armenia and Armenians is an extrapolation of the aggression exercised for decades by the Aliyev family regime within the Azerbaijani society, against its own compatriots, against politicians, human rights defenders, journalists, activists who protest against falsified elections, corruption and inequality. This means that if successful, it will pay back and strengthen corruption, repressions, and monopolization of political and economic power and will postpone the possible democratic transition of Azerbaijan and sustainable peace in the region for an unknown period.

The transition from authoritarian regimes to democracy is hard and painful, it requires both consolidated and individual efforts, strength, and understanding that the only way to live in a sustainable and peaceful region is to follow the principles of democracy and respect for human rights. These principles are crucial particularly for communication both within and between societies.

As civil societies, we need to understand that the current escalation is another step back from agreeing to live peacefully in the same region, another rejection of the possibility of coexistence.

The current aggression is a horrific precedent for the modern world when an authoritarian regime exercises violence if peace talks do not result in what it wants. We are currently observing a similar situation and bigger-scale violence in another part of the Eastern Partnership. We welcome French President Emmanuel Macron’s initiative to convene a special meeting of the UN Security Council on this issue, which was executed on 15 September 2022.  

Throughout the past decade of communication and cooperation within the Eastern Partnership Civil Society Forum we have witnessed the struggles of the Azerbaijani civil society and the society at large in their attempts to strengthen democracy in their home country, we have witnessed how the civil society’s space was shrinking resulting in repressions and migration of many civil society activists. Unfortunately, many prominent civil society actors had to conform to the mainstream ideology pushed by Aliyev’s regime. However, we have also witnessed the commitments of many brave activists to the universal values that we shared within the EaP, willingness to live in a better society and region where rights of the people are respected, democratic institutions are effective and political power is delegated and not stolen from the people.

We call on the Azerbaijani society and particularly civil society actors to respond to the current situation with an understanding that we all live in this region and we need to find a way for peaceful coexistence. We should share the knowledge that soldiers and civilians dying during every wave of escalation are our sons and daughters, brothers and sisters, fathers and mothers, friends and neighbors. The lives of people are beyond nationalities, beyond religions, beyond political views.

We call on the European Union:

– to condemn and address the escalation initiated by Aliyev’s anti-democratic regime, with an understanding that this act of aggression is equally directed against Armenia and the Azerbaijani society since it causes losses from both sides, undermines the chances for peace and development in the region and strengthens the dangerous precedents of the arbitrary use of force and human killings at the whim of unjust power;

– to execute stronger efforts to stop the continuing aggression and to continue the peace negotiations started under its aegis;

– condemn in strongest terms the atrocities and other war crimes committed by Azerbaijan in respect of the Armenian military and civilians;

– to demand immediate release of all prisoners of war, including those captured since the start of the 2020 war;

– to organize a high-level EU visit to Armenia to discuss the situation and coordinate actions in international bodies;

– to discuss the imposition of EU sanctions on Azerbaijan for violation of international legal order and for creating and running one of the most terrible dictatorial systems in the world inside the country;

– to initiate discussions with external actors to stop them from selling particularly offensive military equipment to Azerbaijan;

– to make efforts to ensure the deployment of UN peacekeeping forces on the border of Armenia and Azerbaijan.

[1] Briefing of the Chief of the General Staff of the Republic of Armenia Edward Asryan in Jermuk with diplomatic representatives accredited in Armenia, 

[2] Report of Armenia’s Representative to the UN during the UN Security Council Meeting on the issue of Armenia on 15.09.2022,  , 54:51

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Legal Consultant

“EU4LabourRights: Increasing Civic Voice and Action for Labour Rights and Social Protection in Armenia” project

Terms of Reference

Media Diversity Institute – Armenia is looking for a legal consultant to be responsible for providing legal advice and help within “EU4LabourRights: Increasing Civic Voice and Action for Labour Rights and Social Protection in Armenia ” project. Within the project, three innovative tools have been developed to support employees to address labour rights related issues and get legal assistance. Moreover, the tools are used to raise awareness about labour rights violations and provide information about the legal framework in Armenia and how the employees can address the issues by themselves through complete exercise of their rights. The responsibilities of a legal consultant include drafting documents, structuring solutions for issues, and providing answers to the questions received through the helpline and chatbot in a written form.

To be successful as a legal consultant, you should possess excellent analytical, research and writing skills, the ability to make good judgments, and be able to work well within a team.

Ultimately, a top-notch legal advisor should have strong communication skills, be able to manage a large workload with a tight deadline, and remain up-to-date with laws.

Legal Consultant Responsibilities

The general objective of the assignment for the Legal Consultant is to support MDIA in in the activities related to the labour rights with the following key responsibilities:

2.1. Follow up with the labour-rights related questions and complaints received via the anonymous helpline through provision of the legal assistance;

2.2. Create content related to labour-rights violations and legal framework for the project chatbot on the project Facebook page:

2.3. Develop content and engage in production of short videos and infographics covering legal framework and main violations of the labour rights in Armenia for the project’s thematic blog.

2.4.Prepare quarterly reports on the submitted labour rights violation cases;

2.5.Assess the effectiveness of the online tools addressing the labour rights related issues and suggest necessary changes;

2.6. Carry out other tasks assigned by the project manager related to the labour rights and legal framework in Armenia․

Requirements and skills

  • Academic background (at least BA degree) in law or human rights,
  • 3-5 years of proven experience as a Legal Consultant in business environment and in the non-profits,
  • Excellent knowledge and understanding of corporate law and procedures
  • Full comprehension of the influences of the external environment of a corporation
  • High degree of professional ethics and integrity
  • Good judgement and ability to analyse situations and information
  • Outstanding communication skills
  • Good analytical skills,
  • Flexibility and ability to response to challenges proactively in a timely manner;
  • MA or BSc in Business Administration will be considered an advantage.

Background on the project

“EU4LabourRights: Increasing Civic Voice and Action for Labour Rights and Social Protection in Armenia” project is implemented by OxYGen Foundation, Socioscope NGO, “Asparez” Journalists’ Club NGO, Armenian Progressive Youth NGO, Media Diversity Institute – Armenia in cooperation with Protection of Rights without Borders NGO, and Eurasia Partnership Foundation. The Project will facilitate a multi-stakeholder policy Platform – CVA which will lead national consultations on the development and implementation of relevant public policies aimed at addressing the discrimination and violation of labour rights, with the involvement of grassroots organisations and activists’ nonformal groups.

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Armenia -- Police using force against "Iravunk Daily" journalist Hrant Safaryan, Yerevan, 01Jun2022

Statement on Use of Force against “Iravunk” Journalist Hrant Safaryan

On May 30, 2022 during a protest organized by opposition forces near the RA Government Building 3, the police used brute force against “Iravunk” newspaper journalist Hrant Safaryan, hitting and throwing him on the ground. During the clashes, law enforcement officers also used force against “” editor Vahe Sargsyan trying to detain him. Both journalists were there to cover the action and were performing their professional duties.

In spite of the fact that the police do not use batons, stun grenades, water cannons and other special means during the clashes, nevertheless, law enforcement officers do not refrain from using disproportionate force, in particular, violently obstructing the activities of media representatives. Whereas, the police are obliged to ensure safe work environment for journalists performing their professional duties.

Strongly condemning the attacks against media representatives, we, the undersigned journalistic organizations, demand from the RA Police:

  • to carry out an official investigation, identify and hold accountable the police officers that abused their power, and inform the public about it;
  • to take measures to ensure more professional actions by police officers, respect and tolerance for the professional duties of journalists and the safety of media representatives during mass events.


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Armenia -- Director of "Yerkir Media" TV Bagrat Yesayan, Yerevan, 13Jun2022

Statement on Detention of “Yerkir Media” TV Director Bagrat Yesayan

On June 10, 2022 four National Security Service officers, without prior notice, broke into the office of Bagrat Yesayan, Director of “Yerkir Media” TV Company and member of the “ARF-Dashnaktsutyun” party Armenian Supreme Body, and arrested him. According to lawyer Vahe Yeprikyan, Bagrat Yesayan was charged with Article 38-225, Part 2 of the RA Criminal Code (violence, pogroms or arson, destruction or damage to property during a mass disorder) and Article 164, Part 1 (obstruction to the journalist’s legal professional activities or forcing the journalist to disseminate or refuse to disseminate information).

This charge is related to the the attack against the Yerevan Bureau of “Radio Free Europe/Radio Liberty” on the night of November 10, 2020, which resulted in the institution of a criminal case. On the same day, we, the undersigned journalistic organizations, issued a statement expressing our indignation, condemning the harassment against the media and its employees. Nevertheless, taking note of the fact that Bagrat Yesayan, as a participant of the mentioned incident, did not hinder the preliminary investigation and did not avoid providing testimony, his detention and arrest are unacceptable. Especially when it has been carried out demonstratively, without prior notice on the premises of the media headed by Yesayan,.

In this regard, we welcome the June 11, 2022 decision of the Court of General Jurisdiction of Yerevan, which rejected the NSS motion for Bagrat Yesayan’s detention.

While reiterating our position that the attack against the Yerevan Bureau of RFE/RL on the night of November 10, 2020 is a highly reprehensible act with legal consequences, we nevertheless insist that a comprehensive and fully objective investigation of this incident should be conducted. Hence, we demand from the body carrying out the preliminary investigation to act strictly within the law, to steadfastly adhere to its letter and spirit, not giving any reason for political manipulation.


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TV Tower of Yerevan

Statement on Amendments to The Law “On Audiovisual Media”

June 21, 2022 is the deadline for the presentation of the draft law on making amendments and supplements to the Law “On Audiovisual Media” and adjacent laws, published on the official platform. As a matter of fact, this document has not received proper attention. So far, it has got 0 votes for and 0 against. Meanwhile, this legislative initiative authored by the RA Ministry of High-Tech Industry in partnership with the Commission on Television and Radio, the Council of the Public Broadcaster and the “Union of Operators of Armenia” NGO has caused deep concern among more than a dozen specialized journalistic organizations, both in terms of the content of the draft law, and the process of its development and presentation.

First of all, it is at least puzzling that the initiation and discussion of the idea of ​​making such extensive changes and supplements to the RA Law “On Audiovisual Media” and the development of the draft itself were held without the knowledge and active engagement of the profile committee of the National Assembly. This is especially incomprehensible, given the fact that with this initiative changes are envisaged not only in the above-mentioned law, but also in 7 other laws related to the field, including the main law “On Mass Communication”, which regulates the activities of media.

Added to that, the process has not in any way engaged journalistic NGOs, among which there are organizations that have been dealing with broadcasting issues for decades, have conducted numerous researches, have studied international experience, have developed analyses, recommendations and draft laws.

Finally, it is unacceptable, for example, to include provisions related to journalistic ethics in the draft law without consulting the organizations that are the initiators and advocates of the development of the professional code of ethics and introduction of media self-regulation in Armenia. In general, there are so many content-related defects and omissions in the draft law that it is not possible to address them within this statement. Nevertheless, let us mention a few: in particular, it is not clear why part 4 of paragraph 5 of Article 1 is removed from the Law “On Audiovisual Media”, which, in fact, excludes from regulations the TV companies using private multiplex slots. Is it because the authors of the draft law are sure that no private network of terrestrial digital broadcasting will be formed and operate in the country? Or, when there is a compulsion to clearly separate facts from opinions in TV programs, which is primarily a self-regulation issue, will the CTR be able to identify all violations of this requirement from the enormous information flow and hold their authors accountable? Of course not. It opens up wide opportunities for subjectivity, arbitrariness and selective approaches, which is unacceptable. The same can be said about the requirement to publish only reliable facts. Let us once again note that there are a number of such provisions.

The development and presentation of the above-mentioned draft law, along with its content, also contradict a key process initiated by the RA NA Standing Committee on Science, Education, Culture, Diaspora, Youth and Sport, the RA Ministry of Justice and 11 journalistic organizations, according to which joint efforts should be made to prepare a concept of information field development and media legislation reforms, and the fundamental principles included in that document should serve the development and adoption of new laws complying with contemporary international norms. A tripartite Memorandum of Cooperation in this regard was signed on April 19, 2022.

It is apparent that without a comprehensive concept, such extensive legislative changes are pointless and inefficient, moreover, they will continue the vicious practice of patching gaps in media legislation.

Based on the above-mentioned, we call on:

– the HTI Ministry to revoke the package of draft laws submitted on the official platform, to hold professional open discussions with interested state and public organizations aimed at improving the legislative regulations of the broadcasting sector;

– the RA NA Standing Committee on Science, Education, Culture, Diaspora, Youth and Sport and the Ministry of Justice, while sticking to the provisions of the Memorandum of Cooperation with journalistic organizations, to work with the HTI Ministry, so that the implementation of the proposed changes in the Law “On Audiovisual Media” be in compliance with the processes envisaged by the Memorandum, in line with the principles of the concept currently under development.


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Armenia -- Mediahub journalist and cameraman attacked by police representatives in Yerevan, 02May2022

Statement on Hindering The Work of Media Representatives

On May 2, 2022 during the disobedience actions organized by opposition forces in Yerevan the professional activities of a number of media representatives were hindered.

In particular, at the intersection of Proshyan and Baghramyan streets Sargis Hovhannisyan, head of the country’s State Protection Service, first behaved aggressively towards “” correspondent Nare Gnuni by hitting the microphone in her hand, and then kicked the cameraman of the same website Arman Gharajyan and damaged the camera.

As a result of a clash between the police and citizens at the intersection of Sayat-Nova-Abovyan streets, “” correspondent Lia Sargsyan started to feel bad and was given first aid.

On Heratsi street, the police officers punched “” journalist Davit Fidanyan on the shoulder and obstructed his work, while Ishkhan Khosrovyan, another journalist of the same website, was shoved at the intersection of Khanjyan-Sayat-Nova streets.

We, the undersigned journalistic organizations, restate that amid any aggravation of the socio-political situation in the country, the attacks and pressures on journalists and cameramen increase as well. This is also often the result of a lack of professionalism by law enforcement officers and inability to communicate politely with people, including media representatives.

Strongly condemning the law enforcement officers’ attacks against journalists and cameramen performing their professional duties during mass protests, we demand from the government:

– to initiate an official investigation and hold accountable State Protection Service head Sargis Hovhannisyan and his subordinates who exceeded their power;

– to give appropriate instructions to SPS and the police so that the latter do not violate the rights of media representatives through their actions and treat them respectfully.


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Yerevan -- Presentation of “Impact of the Covid 19 Pandemic on the Labour Rights Situation in Armenia” , 17Feb2022

The EU-funded projects on labour rights revealed a number of problems related to the labour rights situation in Armenia

More than 60 attendees – representatives of the RA Government, international community, civil society organizations learnt about the results of the studies on situation of labour rights protection in Armenia, real cases of labour rights violations, the impact of COVID-19 on labour rights in Armenia, the needs related to the labour rights in Armenia, and best practices of establishment of Trade Unions in European Union during an online event. The five studies were carried out by the member CSOs of the consortia of three projects funded by the European Union.

“In its permanent dialogue with the authorities and civil society, the EU stands by Armenia to improve and respect the labour rights. Labour law should not be seen as an obstacle to entrepreneurial freedom, but rather as a tool to facilitate social dialogue,” H.E. Ms. Andrea Wiktorin Ambassador, Head of the EU Delegation to Armenia said in her welcome speech. The event was attended by Ruben Sargsyan, Deputy Minister of Labour and Social Affairs of Armenia, and Hakob Avagyan, Head of Health and Labor Inspection Body of Armenia who also welcomed the participants.

The studies revealed a number of problems related to the labour rights situation in Armenia. In particular, as a common conclusion, three of the studies – the “Research on the Situation of Labour Rights Protection in Armenia” (the full Report) the “Comprehensive Needs Assessment Research” and the “Evidence Collection on the Real Cases of Labour Rights Violations and Court Cases” indicated the problem of lack of awareness of the employees on their labour rights. All three researches include recommendations to act towards raising public awareness regarding benefits and entitlements upon separation, safeguards against arbitrary dismissal as well as available remedies in place, especially in marzes, for those employed in private business as well as among women to empower them to stand for their rights.

Other finding of the studies indicate that:

  • 16․7% of the respondents do not have an employment contract;
  • 6.8% of the respondents mentioned the existence of a high level of exposure to hazard factors in their workplace, and 79.2% of the respondents do not get any compensation if hazard factors exist in their workplace;
  • Only 15.2% of those who have ever expressed their dissatisfaction regarding working conditions to their employer, immediate supervisor or superior body had the relevant issue resolved as a result of expressing dissatisfaction, 45.8% had the issue partly resolved, while 35.6% did not reach any solution;
  • Only 28.3% of the respondents had trade unions in their workplace. The majority of the respondents (85.7%) mentioned that they had never united with colleagues against the employer in order to solve an issue or protect their labour rights;
  • Young people have difficulty in finding a suitable job due to lack of work experience, or they find a job with a very low salary. For 26% of the respondents, young age played a negative role in finding a job, and for about 50% of them, the absence or lack of work experience prevented them from finding the job they wanted;
  • Some women face obstacles while looking for a job or a change/promotion. For 22.7% of female respondents, being female played a decisive role when looking for a job or during a working activity, and for 52% of the latter, that role was negative.
  • The majority of organizations operating in both the public and private sectors in the Republic of Armenia do not yet have the necessary opportunities for the movement of the disabled, which is a big obstacle to hiring such people. Many employers simply avoid hiring people with disabilities, worrying that their health may often lead to absenteeism;
  • In Armenia people have very little information about labour protection and control structures. More than half of the respondents, 54%, do not know where to go in case of violation of labour rights;
  • The overwhelming majority of court cases related to labour rights were brought against the state- and municipality-owned organizations, such as schools, medical centers, universities, as well as ministries and municipalities as such. According to the data challenging the dismissals remain low in the private sector.

The results of the Impact of the Covid 19 Pandemic on the Labour Rights Situation in Armenia” and Best Practices of Establishment of Trade Unions in the EU” studies were also presented during the event.

The CSOs forming the three consortia implementing the projects aimed to improve labour rights situation in Armenia came up with a decision to continue coordinated efforts in the sphere.

The full recording of the event is available HERE. All the studies will be published and shared with the stakeholders after finalization.


The three EU-funded projects on labour rights and social protection in Armenia

“Labour Action: Collaborative Effort for Accountable and Inclusive Employment’’ project is implemented by Union of Employers of ICT, Armavir Development Center and Kiraki Development Foundation.

“Decent work now!” project is implemented by Helsinki Citizens’ Assembly – Vanadzor, Transparency International Anti-Corruption Center, Advanced Public Research Group, Factor Information Center NGO in cooperation with Education and Solidarity Union.

“EU4LabourRights: Increasing Civic Voice and Action for Labour Rights and Social Protection in Armenia” project is implemented by OxYGen Foundation, Socioscope NGO, “Asparez” Journalists’ Club NGO, Armenian Progressive Youth NGO, Media Diversity Institute – Armenia in cooperation with Protection of Rights without Borders NGO, and Eurasia Partnership Foundation.

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