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Privacy CG telcon - 9 April 2020

  • Chair: Tanvi
  • Scribe: Peter Saint-Andre

Attendees

  • Erik Anderson (co-chair, Microsoft)
  • Tanvi Vyas (co-chair, Mozilla)
  • Theresa O'Connor (co-chair, Apple)
  • Peter Saint-Andre (Mozilla)
  • Pete Snyder (Brave)
  • Christine Runnegar (PING co-chair)
  • Kris Chapman (Salesforce)
  • Martin Meyer (Akamai)
  • David Senecal (Akamai)
  • John Wilander (Apple)
  • Jack Frankland
  • Sam Weiler (W3C/MIT)
  • Wendell Baker (Verizon Media)
  • Pranjal Jund
  • Scott Low (Microsoft)
  • Sam Tingleff (IAB Tech Lab)
  • Ben Savage (Facebook)
  • Andrew Knox (Facebook)
  • Max Gendler (NY Times)
  • Mark Xue (Apple)
  • James Hartig (Admiral)
  • Wendy Seltzer (W3C)
  • Tiago Ferreira (Metomic)
  • Melanie Richards (Microsoft)
  • Brandon Maslen (Microsoft)
  • Aram Zucker-Scharff (Washington Post)
  • Steven Englehardt (Mozilla)
  • Johann Hofmann (Mozilla)
  • Allan Spiegel (Adobe Digital Experience Platform)
  • Baudisch Rene
  • Ketan Deshpande (Amazon)
  • Carlos Bracho
  • Chris Pedigo (Digital Content Next)
  • Michael Smith
  • Shaun Gilmore (Apple)
  • Sebastian Zimmeck (Wesleyan University)
  • Przemyslaw Iwanczak
  • Thomas Bergemann 39 participants on call

Agenda:

New Introductions

  • Chris Pedigo (Digital Content Next)
  • Allan Spiegel (Adobe Experience Platform)
  • Tiago Ferreira (Metomic)
  • Andrew Knox (Facebook)
  • Ben Savage (Facebook)
  • Max Gendler (NY Times)
  • Sebastian Zimmeck (Wesleyan University)
  • Shaun Gilmore (Apple)
  • Tess provides an update
  • Pushed an update a few days ago
  • Charter requires that we announce changes
  • This change consists of bug fixes and clarifications
  • Summary:
    • We now describe what kind of artifact we expect a proposal to produce
    • Clarified rules about when editors make feature additions and removals to work items
    • Clarified need to sign CLA in order to contribute changes
  • May 13-14 15:00-19:00 UTC
  • Wednesday-Thursday
  • This is 8am-11am PDT
  • Evening in Europe
  • Only one respondent from APAC (who works on Pacific Time!)
  • Proposal from Sebastian Zimmeck
  • Follows up on CCPA rights and email thread
  • Background
    • CCPA is privacy law in California
    • Regulations say that browser extensions and similar technologies that use automatic signals to tell services not to sell data must be honored
    • Some people asked for changes but the California Attorney General has not made changes
    • This might have implications for DNT
  • What form could the signal take?
  • Could be a simple binary signal
  • But it could be a more robust/granular communication mechanism
  • Basis for this could include headers, cookies, etc.
  • This topic is beyond just web technology, includes policy aspects
  • Sebastian's goal is to help form a standard for meaningful privacy selections for users but also allow monetization of data under reasonable terms
  • Such a standard would bring together multiple stakeholders
  • Output could be a single standard or multiple standards
  • Sebastian submitted the proposal to start the discussion
  • Sebastian and his students have written code toward this
  • Aram Zucker-Scharff
    • Really interested in this issue
    • The signal isn't specified by CCPA laws and regulations
    • Concerned that there could be many signals
    • IAB Consent String process seems like a good starting place
    • IAB has put their spec up on GitHub to gather comments
    • Headers are interesting, but an active request could be a good fallback
    • IAB uses defined interfaces on window objects
    • ??? proposal uses cookies and that's not future-proof
    • IAB proposal requires a per-case active event (not a generic do-not-sell)
    • One challenge is joining user consent with interaction of content
    • We would like consent to travel with the content (but this is hard if that content moves to a third-party site because origins are different and can't necessarily sync in an active way)
    • Need a way to send consent indication to those other sites
    • Audio is hard (podcasts, Spotify, etc.)
    • Possible to present a personalized ad over audio but difficult to sync the consent
    • Hopefully we can address these concerns during standardization
  • Ben Savage
    • Text about "global privacy goals" are ambitious and have gotten attention
    • It's difficult to follow all the rules in all jurisdictions
    • This is especially a burden on smaller companies
    • A single control would simplify matters
    • There's a lot of potential to do this well
    • Concerned that platforms vendors could move quickly and complicate standardization
    • We need a way to provide input to their thinking
  • Chris Pedigo
    • Agree this is a worthwhile effort
    • We need to avoid a profusion of signals
    • There was a lot of controversy in the DNT effort over policy but not so much over technology
    • Things are different now because CCPA is the policy
    • Just need to figure out what the signal looks like
    • Using Storage Access API would be helpful
  • Pete Snyder
    • There have been efforts in PING and other bodies to indicate user desire for stronger privacy in the context of existing standards
  • Sebastian Zimmeck
    • One way to go about this is to define something simple (e.g., a do-not-sell indication)
    • Another is to design a larger framework
    • Which direction we take depends on how the conversation goes
    • Perhaps look not at specific devices or applications but a more general platform (e.g., to store advertising IDs) that publishers and others can query
    • Input is welcome on how to approach things
  • John Wilander
    • We (Apple) are positive about working in this space
    • Our basic policy on WebKit is privacy by default
    • So we need to look at opt in vs. opt out
    • We need to make sure that things are safe by default
    • For instance, the lack of signal on a shared device shouldn't violate user expectations
    • The signal should not become a tracking vector (as happened with DNT)
  • Wendell Baker
    • Verizon is very interested in this as well
    • W3C ran a workshop in 2018 on permissions and user consent (with Brad Kulick)
    • We submitted a position paper to that workshop
    • Posited that such a mechanism should exist
    • Workshop discussion indicated that compliance and notification mechanisms should move to a panel in the browser
    • Concerns were raised that jurisdictional incursions weren't the same across cultures and might move faster than software
    • Mechanism would be a cookie-jar store beyond cookies
    • Various opinions about default-on vs. default-off
    • For instance, some browsers might default users to one state or the other
    • One concern we had about DNT was that content and media were moving from servers to CDNs (same origin concepts are not as straightforward)
    • IAB project around consent management
    • Various proposals to standardize on a particular vendor in the ad world
    • Neutral platform needs to be operated by someone and that can be a blocker
      • (Scott Low): Queue is closed, but Microsoft authored a proposal for an auditing body a while back. We're supportive of helping unblock this in the industry and fleshing out use cases!
    • This comes up in Google's privacy sandbox proposal - need for a neutral entity
    • When consent is registered, by whom and for what? Need an identity system of some kind to make those associations stick
  • James
    • We have implemented both IAB specs for CCPA and GDPR
    • Whatever spec we develop should address both laws
    • GDPR has more cross-origin requirements
    • We've seen a much higher level of confusion about how to implement GDPR
  • Aram Zucker-Scharff
    • Defaulting changes in different regulatory regimes
    • In GDPR, default opt-out
    • In CCPA, user must explicitly opt out
    • How to handle defaulting when we can't determine it? If we (WaPo) can't determine user's location, we should assume that the user is in California and has previously opted out
    • If user has selected opt out in California, need to honor opt out
    • If the user is unknown to us, we have to assume that the user is in our system and has opted out
    • User identity is key here
    • I'd like to recommend against a centralized identity bank
    • Not just the problem of finding someone to maintain it and single point of failure, but even optimally institutions won't necessarily remain trusted
    • User agent needs provide explicit signals
    • Transaprency and consent model needs authenticated participants
    • There is a CCPA negative signal, IAB spec covers this
  • Johann Hofmann
    • We (Firefox team) are very interested in this too
    • We have looked into it conceptually
    • Very concerned about the different interests that are in play
    • Getting together on a common signal is the least of our worries
    • Designing the UX and getting real consent are extremely difficult
    • The UI can lead the user in one direction or another
    • Don't want to end up where we did with DNT

Storage Access API

  • Jack Frankland
    • A few comments indicated appetite for expanding the scope
    • Currently the API is bound to iframe
    • If scope were to expand, might not make sense to bind it to the document
    • Not suggesting that we change behavior
    • More about making clear what the scope should be
    • Even though Navigator is global, service worker can register to specific scope
    • Thus the behavior doesn't change
    • Opening up to future flexibility
  • Tess
    • Objects: nav, window, doc
    • These are common places on which to hang APIs
    • Sometimes we don't choose the right place to hang things
    • There are two shipping implementations that use Document
    • In the past when we've made similar moves, we've usually regretted it
    • This caused compatibility problems with DNT
    • Future flexibility might not be a good reason to change things
  • Jack
    • Don't think this needs to change unless it's a hinge for some browsers to implement
  • John Wilander
    • Hoping for input here
    • This is the main thing we need to solve
    • Scoping is at the heart of this (per frame, nested frames, frames on page, resources on page)
    • How do we handle restrictions in browser?
    • Blocked vs partitioned could be tricky for IndexedDB
    • Blocked easier - just unblock. But if partitioned, more tricky if you have say open connections to IndexedDB
    • Blocking or partitioning across the board or using a list-based mechanism
    • Harsh behavior for origins on a naughty list minght be more palatable to a browser implementer
    • Whereas across the board policy could lead in a different direction
    • How to handle sibling frames?
  • Steve Englehardt
    • We are still leaning toward all frames on the page
    • Signal to other frames?
  • John Wilander
    • Would like to hear from more developers (e.g., people who deploy with nested iframes)
    • Will things break if we switch for all frames at once? What kind of signal do they need?
  • James Admiral
    • Won't break for us (we have multiple frames but not nested)
    • We're not using IndexedDB
  • John Wilander
    • Send us feedback!

Any other business

Upcoming ad-hoc meeting on Bounce Tracking

  • #5
  • Proposed time: Thursday, April 23rd 10am PDT, after our next teleconference.