Re: [meetings] Agenda Request - Review Working Group Charter Changes (#52)

James’ post raises some important issues that might be useful for this smaller group to resolve so as to avoid issues we’ve seen with DID and other topics when the larger W3C community reviews the output of such groups.

Criteo agrees that “advertising is a core component of the web now, and if we want to evolve the web that means we need to acknowledge advertising, its use cases, and build specific APIs towards its needs.”

The question arises which “needs” we are addressing. The Charter seems to incorporate two assumptions that if left unaddressed could restrict competition for improved digital advertising as we try to improve privacy outcomes for individuals. 

Digital advertising is paid by a marketer to a media owner, and hence is primarily a business-to-business process. Of course the goals of both marketer and media owners are to attract, engage and achieve positive responses from consumers who are exposed to such paid content. However, if we are to support the needs of responsible advertising, then we might benefit from clarifying some specific principles: 


1. The Charter could be improved by ensuring not all B2B processing for digital advertising must be exclusively bundled within user agent consumer software
a. Charter: “Ways in which new features might enable inappropriate processing include (but are not limited to) enabling of [cross-site or cross context recognition](https://w3ctag.github.io/privacy-principles/#hl-recognition-cross-site) of users or enabling [same-site or same-context recognition](https://w3ctag.github.io/privacy-principles/#hl-recognition-same-site) of users across the clearing of state.”
b. “Inappropriate” processing should indeed be the focus, rather than which organization is doing such inappropriate processing, as the above quote implies. So long as the recipient system that appropriately processes data (such as this data poses low privacy risks to individuals), there should be alternate mechanisms for web authors and media owners to work with partners of their choice, rather than relying exclusively on user agents for such processing.  

2. If a user agent (or operating system) is to responsibly process cross-site or cross context information for digital advertising (such as frequency capping and attribution), it would be useful to ensure how such processing is improving end user privacy 
a. Charter: “Ways in which new features might enable inappropriate processing include (but are not limited to) enabling of cross-site or cross context recognition of users….  The Working Group may consider designs that allow user agents for the same user — including non-browser agents, like Operating Systems — to collaborate in providing advertising features.”
b. Many OS and browser manufacturers offer individuals the ability to register an account that discloses their identity to this consumer software. There must be some technical or organizational measures to ensure such organizations can collect and process this data, but not mingle it in ways that would increase risks to specific individual’s privacy, such as when processing cross-site or cross-context information is linked to individual’s identity versus when it is associated with random identifier. For example, https://www.apple.com/privacy/: “Many news sources keep track of your identity and create a profile of you. Apple News delivers personalized content without knowing who you are. The content you read is associated with a random identifier, not your Apple ID.”).  
c. The Charter could be improved by clarifying how other entities can rely on similar mechanisms as contemplated by user agents or operating systems to reduce the risk to specific individuals associated with the collection and processing of personal data. 

I would hope we can revise the Charter to focus on improving privacy, while also ensuring we do not inadvertently restrict greater competition in digital markets.

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Received on Wednesday, 22 June 2022 22:12:24 UTC