Re: [w3c/payment-request] Regulatory Compliance Support (#632)

@lknik sorry, but can I turn that on it's head.
Do you expect every business that uses your specification in Europe to have to do a privacy assessment from scratch when looking at your api? Either you can help them out, or they'll have to assess the privacy impact each themselves. All sites will require a privacy impact assessment throughout the EU
https://www.itgovernance.co.uk/blog/gdpr-and-privacy-impact-assessments-why-are-they-required/

In terms of amount of work, it is one large piece of work to allow lots of business to do a small piece of work, or a small piece of work that forces lots of businesses to do a large piece of work.

If this spec fails a privacy impact assessment, then it is illegal to use in various industries and use cases... risking businesses falling foul of breaking the law because they would erroneously believe the spec was okay and worse the human factor of risking privacy.

We've seen the mess of the Referer header and the pain it causes to try to patch on hacks to fix privacy by design flaws, please put the effort in now, because otherwise it'll come back to bite the w3c anyway as people will have their data leaked to organisations that shouldn't have it and businesses will get sued or forced to spend a lot of time refactoring code and complaining to the w3c to patch a fix into the api.

If you want to understand the Referer mess better, have a look at my Youtube feed https://www.youtube.com/channel/UCt0RTPkU-38xn5rUxZsWTig?view_as=subscriber 
The NHS (UK public healthcare) has mismanaged the referer and leaked the browsing habits and reset password links to various companies... that's because of referer: don't make this mistake.

123-reg.co.uk, part of the same company as GoDaddy, has made a similar mistake and replied by email to me:
> We have investigated what has been presented and can confirm that there is no security threat here. It may look confusing due to the XCRF key which is on page loads from the server, which is used to prevent other security risks such as CSS, however we are assured that no risks exist here. 

The internet is currently implemented in a way that is the opposite of privacy by design, please don't make it worse.

This referer mess is a prime example of how important it is, that this spec cares about Privacy.

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