[/TR/privacy-principles/] Formal Objection (Proposed Statement review)

From
   https://www.w3.org/wbs/33280/PPrinciplesChanges/results/

<Member> wrote:
[[
1) Confusing the marketplace – the TAG cannot operate outside “W3C 
itself nor its Members” – hence if it is not endorse by either it is 
premature to publish material that may be objectionable to most members

a. “This Group Note is endorsed by the Technical Architecture Group, but 
is not endorsed by W3C itself nor its Members.”

2) Principle 2.2.1-2.2.2 assume ALL data is Personal Data subject to 
unilateral control of visitors to media owner properties – they deserve 
to protect themselves from fraud at the malicious direction of a “user” 
– this explicitly contradicts Principle 2.6 and contrasts with Principle 
2.2.4 that explicitly states not all data is “sensitive”

a. “Principle 2.2.1: Sites, user agents, and other actors should 
restrict the data they transfer to what's either necessary to achieve 
their users' goals or aligns with their users' wishes and interests.”

3) Principle 2.2.1.1 assumes user agent ALONE and paternalistically 
dictate “appropriate choices” than ensure users are “meaningfully 
informed” as to a choice contradicting Principle 2.11.2

a. “…so that user agents can provide appropriate choices for their users.”

4) Principle 2.6 recognizes all data is not Personal and hence such data 
does is explicitly excluded from “privacy” concerns AND most principles 
fail to distinguish when they are talking about an individual’s Personal 
Data and data that is not under their exclusive control (e.g., 
deidentified data is by definition no longer associated with any individual)

a. “Whenever possible, processors should work with data that has been 
de-identified.”

5) Principle 2.8 uses loaded rather than fair, neutral language and 
tacitly assumes all data collection is “surveillance” which might only 
be appropriate for organizations that reidentify individuals rather than 
internet-connected devices

6) Principle 2.12.2 confuses privacy protections with user experience 
choices that media owners’ control – after all there is no right to 
other people’s online property

7) Principle 2.13.1 against uses loaded rather than fair, neutral 
language with “manipulated” without defining what is permissible 
recommendations and information disclosures vs inappropriate ones
]]

Received on Monday, 14 April 2025 14:21:08 UTC