the victims for their work in human rights, they also result in violations of the right to freedom of thought and expression guaranteed in Article 13 of the Convention. In some cases, they may also constitute violations of the right to association and freedom of assembly, established in Articles 15 and 16 of the Convention.8 35. The Commission also noted its concern that criminal proceedings had been used as a means of harassment and intimidation of human rights workers.9 In that connection, the IACHR added: State agents are responsible for conducting these proceedings. The State's prosecutors necessarily initiate such proceedings. As noted above, they often also act in coordination with members of the State's security forces. These proceedings appear to be arbitrary and inconsistent with the requirements of due process. As such, the State may well incur international responsibility for violation of Articles 8 and 25 of the American Convention. (…) In addition, these proceedings may rise to the level of an assault on the personal integrity of the victims, in violation of Article 5 of the Convention. Criminal proceedings are converted into a tool of harassment directed at human rights workers. As a result, the victims' right to mental and moral integrity is compromised, in violation of Article 5 of the Convention. The Commission also understands that the proceedings are sometimes used to publicly identify human rights workers considered by the State's security forces as "enemies of the State.” Certain members of the State's security forces and/or members of paramilitary groups then treat these individuals as military targets. The criminal proceedings thus sometimes place in danger the physical integrity and the life of those accused, in violation of the rights set forth in Articles 4 and 5 of the Convention.10 36. The Commission also noted the intelligence activities conducted by the State’s security forces into the activities human rights organizations and members.11 In that regard, the IACHR said: (…) it is now unquestionable that [members of the State’s security] forces have targeted human rights organizations and their members for intelligence-gathering activities. As noted above, military intelligence reports regarding members of human rights organizations have been introduced in various criminal proceedings. [...] [T]he Commission is again concerned that the State security forces direct intelligence activities against human rights organizations and their members based solely on their status as such. The State security forces appear to assume automatically that human rights organizations and their members present a danger to the public order. [...] [T]he Commission has received complaints regarding the manner in which intelligence information about human rights workers and their organizations is gathered. This information indicates that members of the State's security forces obtain financial and other private documents without proper authorization. The Commission has received information indicating that the State's security forces have also engaged in telephone line intervention, secretly taping conversations, without judicial orders (…) When State security forces carry out these types of secret and intrusive intelligence activities without proper authority, they violate Colombian domestic law as well as the right to privacy set forth in the American Convention.12 IACHR, Third Report on the Situation of Human Rights http://www.cidh.org/countryrep/Colom99en/table%20of%20contents.htm 9 IACHR, Third Report on the Situation of Human Rights http://www.cidh.org/countryrep/Colom99en/table%20of%20contents.htm 10 IACHR, Third Report on the Situation of Human Rights http://www.cidh.org/countryrep/Colom99en/table%20of%20contents.htm 11 IACHR, Third Report on the Situation of Human Rights http://www.cidh.org/countryrep/Colom99en/table%20of%20contents.htm 12 IACHR, Third Report on the Situation of Human Rights http://www.cidh.org/countryrep/Colom99en/table%20of%20contents.htm 8 6 in Colombia, February 26, 1999. Available at in Colombia, February 26, 1999. Available at in Colombia, February 26, 1999. Available at in Colombia, February 26, 1999. Available at in Colombia, February 26, 1999. Available at