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[marksjc]

In addition to the anti-competitive nature in the current web advertising mechanism it is natural to be concerned about any change, no matter how well intentioned, from within the industry without committed involvement by recognized NGOs championing online privacy. If there is a genuine commitment to improving privacy rather than for example, devaluing the gaming and backend use of advertising targeting then assuring privscy by design requires stakes by outside advocates and quarterly published reviews of privacy goals, needed fixes and improvement plans. No doubt such reports, goals and plans exists to verify and improve claims of existing methods efficacy, which might be proprietary to specific evaluators and be important to marketing and sales functions and remain restricted to proprietary use. But privacy reports must be web-based, available to all, and subject to yearly audit, verification and correction. A mechanism to resolve privacy breeches, inadvertant and intentional lapses, disclosures, transfers and sales (as defined by current CA law) is required. The intent of my comments overall is to strengthen and verify any privacy claim, ensure any web user has full access to all topics and any other existing or new data based directly or indirectly on personal data.
To be direct, the stated issues listed in some way as "to be determined" are critical to a new regime of privacy centered interest tracking. All topics, sensitive or not, must be available for review to any user, as well as the topics associated with them. There must be no secret, hidden, or proprietary topics that are not visible without additional steps or authorization by the user. The user must have the ability to directly remove any topic, or opt out of the use of topics alltogether permanently or temporarily. The ability to add existing topics to their own account within guidelines should be considered as well as allowing users the ability to add to a blacklist any available topic they do not wish association with at any time. The default for acceptance of any use of topics must be "off" and enabled only by multi-factored authorization of an adult user. Existing users must be given one step ability to edit topics and turn off all topics. The selection of users excluded topics should not be stored in any user device or browser but centrally managed by the topics mechanism owner, whether one company or consortium and protected as it is indicative of personal and private decisions and as valuable to fraudulent users and advertizers as is HIPPA, protected financial or other data. Exposure of compliant advertizers and sellers to false topics information however generated would be available by exclusion of out-of-spec data and notification to authenticated users of the exclusion. This would assure only valid topic data is used and allow users to understand that their data may be compromised with specific steps they can take to ensure their inclusion with valid data. Finally, an important self-assessment function is needed to show all topics attributed to them, as well as past attributes, and provide instructors for changes and correction by users. Additionalky the same report covering the previous year must be sent to users annually that also allows for reporting on previous years.
While these attributes and features may not be considered Inductry priorities they are for consumers and for those who believe privacy is a human right necessary to representative government, functional bl societies and fair and open business end corporate dealing. Given the history around advertising and tracking and the fractured and piecemeal approach to advertising and privacy in today's highly concentrated oligopoly market it is likely regulators will demand a comparison of old and new advertising regimes impact on privacy and open, competitive markets. Full disclosures of past practices and intents of the new regime must be honest and clear. I suggest that in time all tech hubris will fall to focused regulators and the best way to avoid costly fines and public rebuke is to adopt humility while retaining pride in breakthrough industry and public serving technologies.