Re: [patwg-charter] Charter scope and guaranteeing availability of input data (#16)

@benjaminsavage Thank you for summarising. With a few important amendments you're correct. 

Amendments follow.

> You've noted the general trend across user-agents to limit access to data which can be used to link user identity across domains...

There is a trend to remove data that can be used for many purposes other than user identity as well. For example; IP addresses, information about user agents, third party cookies for data transfer that does not include user identity. If we consider harms to be a) big impact for a small number of people; or b) a small impact on a large number of people; then I've not seen any evidence to support such far reaching changes.

> You would like to see user-agents continue to provide access to data which can be used to link user identity across domains.

Change the sentence to the following so that users are included, that the data use is consented to, and domains as a privacy boundary are removed.

"You would like to see user-agents provide access to data between multiple data controllers and processors where user's have provided consent for the use."

> You believe that with continued access to such data, there can be a variety of different approaches to supporting ads use-cases.

Data collected in the manner envisaged is not generally available today as it is highly "siloed". So the pedant in me would drop the word "continued".

> and that this belongs under the umbrella of "private advertising technology" because such approaches can employ approaches like "notice and choice" to protect user privacy.

"Notice and choice" alone would not be enough. A mechanism to ensure fairness and transparency would also be needed. SWAN requires an audit feature that extends beyond the browser and across the B2B supply chain providing people evidence of harm. BTW Had SWAN been available in the Lloyd vs Google case Lloyd would likely have won because Lloyd would have had evidence of actual harm rather than theoretical harm.

In relation to the modular building blocks I have provided a [suggestion to alter First Party Sets](https://github.com/privacycg/first-party-sets/pull/86) to achieve a modular building block that would support the direction outlined.

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Received on Thursday, 7 April 2022 15:57:08 UTC