April 15, 1997
Secretary
Federal Trade Commission
Room H-159
Sixth Street & Pennsylvania Ave., NW
Washington, DC 20580
Re: Consumer Privacy 1997 -- Comment P954807
and
Re: Consumer Privacy 1997 -- Request to Participate P954807
The Center for Democracy and Technology submits these preliminary
comments and requests the opportunity to participate in Session
two: Consumer Online Privacy and Session three: Children's Online
Privacy of the upcoming Federal Trade Commission's Public Workshop
on Consumer Information Privacy.
CDT is a non-profit, public interest organization working to protect
and advance civil liberties and democratic values on the Internet.
One of our core goals is to develop a privacy framework for the
Internet. Towards this end, CDT is working with a broad public
interest and industry coalition to develop and implement fair
information principles and technical tools that foster individual
control over personal information on the Internet.
The emerging global information infrastructure poses both difficult
challenges and unique opportunities for protecting individual
privacy. CDT believes that new technologies can be designed to
enable citizens to exercise greater control over the collection
and use of personal information. Through the development and implementation
of strong privacy policies, and the design and implementation
of technological mechanisms that facilitate individual choice,
we believe that interactive digital media can empower citizens
to make meaningful decisions about the flow of personal information.
Toward this goal CDT helped to establish the Internet Privacy
Working Group shortly after the Federal Trade Commission's Bureau
of Consumer Protection's June 1996 public workshop on Consumer
Privacy on the Global Information Infrastructure (1996 Workshop).
During the June 1996 Workshop a number of participants expressed
interest in examining the potential for user-controlled applications
to support fair information practices in the online environment.
The recently formed Internet Privacy Working Group is comprised
of a broad cross-section of public interest organizations and
private industry engaged in commerce and communication on the
Internet. Coordinated by the Center for Democracy and Technology,
IPWG's mission is to provide a policy framework addressing privacy
concerns in the online environment. Towards this end IPWG is developing
a language for users to communicate privacy preferences and Web
sites to communicate information practices on the Internet. Staff
members of the MIT-based World Wide Web Consortium (W3C) have
been actively participating in the IPWG effort.1
The work of IPWG will contribute towards W3C's proposed project
-- the Platform for Privacy Preferences (P3) -- that will enable
computer users to make choices about the flow of their personal
information on the Internet. In their capacity as IPWG coordinators
CDT staff filed comments and a request to participate in response
to questions 2.14 and 3.14.
IPWG's submission in response to question 2.14 and 3.14 reflects
CDT's input; therefore, we will not duplicate those comments here.
TECHNOLOGICAL DEVELOPMENTS AND SELF-REGULATION
As the coordinator of IPWG, CDT is aware of both the strengths
and limits of its efforts. Technological developments must be
viewed within the larger context of other efforts to produce cohesive
privacy protections in the online environment. CDT's comments
will focus on: the role technological tools such as the Platform
for Privacy Preferences can play in advancing fair information
practices; the fair information practice principles that are unaddressed
by current and anticipated technological developments and self-regulatory
efforts; and, the benefits and risks of adopting technological
tools to advance privacy. The goal is to compare current efforts
to address privacy concerns with traditional self-regulatory models,
legislative solutions, and other approaches to securing individual
privacy._
2.13 & 3.13 What privacy concerns, if any, are not adequately
addressed by existing guidelines and technological mechanisms?
2.14 & 3.14 Has interactive technology evolved since June
1996 in ways that could address online privacy issues? To what
extent is it currently available and being used by consumers and
commercial Web sites?
It is difficult to predict the ultimate success or failure of
self-regulatory policies or technological mechanisms, either independently
or in tandem, to address privacy concerns in the online environment.
However, it is useful to ask whether current self-regulatory or
technological mechanisms for protecting online privacy address
what have historically been identified as the two primary shortcomings
of industry self-regulation in the privacy area: 1) the lack of
oversight and enforcement; and, 2) the absence of legal redress
to harmed individuals.2
It is equally worthwhile to examine whether they respond to individuals'
information privacy concerns as expressed in the HEW Fair Information
Practice Principles 3.
Finally, it is useful to compare each approach with existing legislative
and regulatory approaches to protecting privacy.
Debate over the capacity of self-regulation and market forces
to adequately address privacy concerns continues to rage in the
privacy and consumer protection arenas. Advocates often take the
position that self-regulation is inadequate due to both a lack
of enforcement and the absence of legal redress to harmed individuals.
Industry tends to strongly favor self-regulation, stating that
it results in workable, market-based solutions that respond directly
to consumer's needs while placing minimal burdens on affected
companies.4 These positions,
while in tension, are not mutually exclusive, and, in the past,
both have accurately described the self-regulatory process.
Guidelines
While industry associations have put forth guidelines to address
a variety of online privacy concerns at this time implementation
seems to be lagging.5
Current guidelines include: Joint Statement on Online Notice and
Opt-Out, presented at the June 1996 Workshop by the Direct Marketing
Association & the Interactive Services Association; the Interactive
Services Associations' Guidelines for Online Services: The Renting
of Subscriber Mailing Lists; and the Coalition for Advertising
Supported Information and Entertainment's Goals for Privacy in
Marketing on Interactive Media -- all presented at the June 1996
Workshop.
The self-regulatory efforts of industry while laudable do not
address the full range of individual privacy concerns.6
The lack of oversight and enforcement, and the lack of meaningful
redress to aggrieved individuals will continue to be sources of
criticism of these industry efforts. Its important to note that
oversight and enforcement on the Internet -- be it of self-regulations
or government regulations or legislation -- is a challenge. At
this juncture, the decentralized, open, and global characteristics
of the Internet may make it resistant to traditional top-down
regulatory regimes.7
Self-help tools
In addition to self-regulatory efforts by industry it is important
to consider a number of other non-regulatory attempts to address
privacy concerns on the Internet. For example a number of tools
for disabling or deleting "cookies" have appeared on
the market. While they represent a technology response to privacy
intrusions enabled by another technological mechanism, they have
provided individuals a means of addressing a decision made about
the flow of personal information without their consent or knowledge.
Similarly, tools such as the Anonymizer continue to be used to
protect privacy during web surfing by limiting the collection
of transactional data . In addition a number of companies have
begun to independently address privacy concerns. The PreferredMail
service offered by America Online allows subscribers to block
junk email from sites that have been the subject of vast numbers
of member complaints about unsolicited email. A number of online
people finder services are offering "opt-outs" in response
to privacy concerns. Lexis-Nexis has begun to offer a suppression
service to individuals who do not want their information available
through the P-Trak service.8
The development of technical tools that allow individuals to respond
to concerns about the flow of personal information are interesting
and worthy of study. While they do not provide traditional legal
remedies, they generally provide a "real" remedy that
is uniquely responsive to the problem at issue. Many of them can
be independently deployed by the individual and require no reliance
on, or agreement with another party. Nor do they require the individual
to engage in a formal adjudicatory process.
Acknowledging the benefits of these technological fixes, it is
fair to say that overall they represent a piecemeal response to
privacy concerns. For example, the Anonymizer is useful if one
wants to engage in secret activities but is not useful if one
wishes to reveal information for a single purpose without losing
all control over it. Similarly, suppression options do not respond
to the initial privacy concern -- the reuse and disclosure of
information for unrelated purposes without individual consent.
Technological mechanisms coupled with policy guidance
In addition to these independent "fixes" deployed in
response to privacy incursions, two collaborative efforts have
emerged to address privacy concerns on the Internet. The Internet
Privacy Working Group (IPWG) and eTRUST. Both of these efforts
attempts to leverage the unique characteristics of the Internet
-- interactivity, real-time communication, and capacity to facilitate
and support end-user decisions about privacy. While distinct in
many notable ways both of these efforts attempt to support privacy
policies in the online environment. IPWG and eTRUST both depart
from traditional aspects of self-regulatory models and non-regulatory
responses.
Internet Privacy Working Group
The Internet Privacy Working Group (IPWG) is attempting to outline
a framework for privacy on the Internet through the implementation
of fair information practice policies and fostering the development
of a technical specification -- the Platform for Privacy Preferences
(P3). IPWG's goal is to craft policies and technical tools that
give users the ability to make choices about the flow of personal
information while supporting seamlessness, the free flow of information,
and the development of global commerce.
While in the early stages, IPWG's efforts will if implemented
promote fair information practices on the Internet by fostering
the development of individual empowerment technologies that facilitate
the communication of service and content providers' information
practices to users, and users' privacy preferences to service
and content providers. In addition, IPWG has indicated a commitment
to the implementation of policies, and the development of practices
and tools to ensure adherence to fair information practices.
When fully implemented the P3 project will embed the core Fair
Information Practice Principles of notice and consent into the
backbone of the Internet. The P3 project is an effort to provide
a simple mechanism for users and providers to communicate about
the handling of personal information. Following the PICS-model,
P3 would be an open standard available to everyone operating on
the Internet. By design it would put individuals in a position
to make real-time decisions about the collection, use and disclosure
of personal information. Individuals would be able to make decisions
about whether and under what conditions to disclose personal information
-- if at all.
While addressing these core concepts of information privacy, the
P3 specification will not address other equally important information
privacy principles such as access to and correction of personal
information.9
Solutions are meaningless unless they are effective. At this point
there is a commitment to ensure adherence to fair information
practices. In addition, the P3 notice and choice model has the
potential to create consumer demand for information policies.
Enforcement is a crucial part of any privacy solution. We believe
the FTC would, in appropriate circumstances, have the ability
to enforce privacy policies that entities put and to enforce entities
agreements to adhere to individual's preferences. Where a deviation
or breach of the terms occurred it could be actionable as a deceptive
and unfair practice. We believe the FTC has full jurisdiction
to ensure that entities operate fairly on the Internet and conform
to their stated information practice policies. This would place
the FTC in the position to oversee and enforce privacy on the
Internet. While the legal redress available through the FTC is
far short of a full private right of action, it is considerably
more than is currently available.10
It is important to note that in sharp contrast to existing legislative
protections for privacy, this model would facilitate individual
decisions about the flow of personal information.11
eTRUST
eTRUST is a labeling and certification program sponsored by the
Electronic Frontier Foundation and CommerceNet. It has set out
three-tiers of information handling guidelines from which entities
operating on the Internet can subscribe too. To participate in
the eTRUST project a company must first execute a contract with
eTRUST. In the contract the company will choose from among the
three eTRUST marks:
No exchange: the site will not capture any personally identifiable information for anything other than billing and transactions;
1-to-1 exchange: the service will not disclose individual or transaction data to third parties. Individual usage and transaction data may be used for direct customer response only;
Third-party exchange: the service may disclose individual
or transaction data to third parties, provided it explains what
personally identifiable information is being gathered, what the
information is used for, and with whom the information is being
shared.
The company must agree to undergo an audit by an eTRUST-approved
auditing firm, and agree to certain other conditions. In exchange
the company will be given an icon -- Trustmark -- to display at
their Web site. By clicking on the icon users will be able to
access the policy to which the site subscribes. At this time it
is unclear how a proprietary system of labeling and auditing will
map on to the Internet. It is unclear how a proprietary system
can work in this decentralized, global, multi-player environment.
For example, will small businesses, non-profits, and government
Web sites be able to use and afford the eTRUST system? Will ISP's
who rent server space to many organizations be capable of complying
with auditing requirements? Does a US based system work in this
global medium?
The eTRUST marks address a narrow subset of the fair information
practice principles. While the marks provide individuals with
notice of a Web sites practices, they are a one way application.
The system does not allow individuals to independently express
privacy concerns. The narrow range of information practice policies
that a Web site can select from may not be flexible enough to
reflect the various policies of Web sites, nor granular enough
to address the specific concerns of individual users.12
While individuals are given notice of a companies practices, their
only options are to play on the Web sites terms or walk away from
sites that do not meet their privacy concerns.
The eTRUST model will build upon the traditional self-regulatory
model by providing auditing and oversight functions. The mandatory
audit directly responds to concerns about a lack of oversight
and adherence to industry and other guidelines.
CONSUMER PERCEPTIONS
2.15 & 3.15 What are the risks and benefits, to both consumers
and commercial Web sites, of employing such technology? What are
consumers' perceptions about the risks and benefits of using such
technology to address online privacy issues?
CDT will be conducting a short online survey to gain insight into
consumers' perceptions about the risks and benefits of technology
to address online privacy issues. We will be gathering information
more generally on Internet users' privacy concerns. We hope to
be able to share this survey information and our opinion as to
the risks and benefits of technology solutions with the Commission
in June. Within the concept of risks and benefits it is important
to look at affordability and availability. Technology solutions
will only assist people in responding to privacy concerns if they
are widely available, easy to use, and inexpensive or free. Solutions
-- whether they be technological, policy or a combination of both
-- are always subject to the law of unintended consequences. It
is likely that technological tools to address privacy concerns
will be constantly revised to address new concerns and fix unintended
problems.
CHILDREN'S PRIVACY
3.9 Do children's information practices in the online context
differ from those implemented in other contexts? If so, describe
the differences. Do the risks, costs, and benefits of these practices
differ depending on the context?
Children are an increasingly large segment of the Internet user
population. The nature of the Internet provides children with
unprecedented opportunities for both receiving and sending information.
The Internet offers children, like adults, a tremendous opportunity
to exchange ideas and participate in a world outside their window.
However, the ease with which children can access ideas, reveal
information about themselves, and participate in a range of activities
without being identified as children, and without parental supervision,
has and will continue to be a subject of concern.
The transactional information generated during a child's visits
to Web sites and participation in other Internet activities, offers
an enormous opportunity to monitor and analyze the child's activities
and behavior. Through games, contests, and other lures online
content providers are requesting -- or requiring -- that children
provide personal information such as name, address, email, information
on likes and dislikes, and information on their families and friends,
as the cost of participating. Through both passive and active
information collection, online content providers are able to create
detailed individual profiles on children which can be used and
disclosed for a variety of purposes.
Parents often allow their children to engage in unsupervised activities
both within the home -- such as reading a book, or surfing the
Internet -- and in the outside world. The interactivity of the
Internet raises a unique challenge to parents who are interested
in mediating their children's experiences with the outside world.
There is a need to provide parents with tools and policies that
respond to their concerns about their children's privacy. Doing
so presents some unique challenges. Parents have different concerns.
Children come in many ages. Policies and technical tools must
address the diversity of values, views, and parenting styles.
In addition, on the Internet it is generally difficult to ascertain
the age -- or anything else -- of the individual with whom you
are interacting. Information providers on the Internet have no
way of distinguishing children from adults -- unless they are
actively requesting age. While Web sites that are actively targeting
children should tailor polices and practices to the heightened
privacy concerns of parents, many entities operating on the Internet
have no reason and frequently no desire to know the age of the
user -- however parents' concerns with their children's activities
at these sites remains constant. There is a concern that efforts
to address children's privacy issues could lead to the imposition
of an unacceptably intrusive national ID system. Imposed identification
procedures applied to the World Wide Web may limit all Internet
users' ability to read, speak, receive information and interact
online under constitutionally-protected conditions of anonymity.
We believe that empowering parents with technological tools to
protect their children's privacy and fostering the adoption of
fair information practices by entities operating on the Internet
is a way to meet the privacy concerns of children and maintain
the open nature of the Internet. For example, software already
on the market such as Cyberpatrol, as well as those under exploration
such as P3 address privacy concerns by restricting access to sites
which practice objectionable marketing and information collection
techniques, and allowing parent's to prevent their children from
revealing personal information such as name, address, and e-mail
address to others.
There are a number of tools -- some are free -- available to help
parents address concerns with children's online privacy. There
is a clear need for additional tools and concerted public education
on this issue. Without market saturation and consumer use technology
solutions will be inadequate to address the privacy of children
in the online environment.
3.10 Do schools, libraries, and other settings in which
children may have access to the Web, have a role to play in protecting
children's privacy? What role do the currently play, and what
role could they play in the future?
Schools, and other institutions often stand in the shoes of parents
when entrusted with a child's care. Schools make decisions about
the curriculum they teach, the field trips they take, and the
speakers they invite based on the age of the school population,
the communities values, and other factors. It is reasonable to
believe that schools will continue to make decisions on behalf
of children -- it is a task they are charged with. It is also
reasonable to expect that at times schools will ask parents to
make decisions about their children's activities -- be they field
trips to the great outdoors or perhaps excursions on the Internet.
Libraries present a more complicated question. Libraries are available
to both children and adults and are charged with the broad obligation
of serving the full community. However, it most be noted that
librarians and library boards make decisions about the books to
stock on their shelves based on a variety of considerations. Many
libraries provide children's areas, children's reading lists and
offer other services directed toward children. In this fashion
libraries assist parents in supervising their children's exposure
to thoughts and ideas. However, unlike schools, libraries are
rarely asked or expected to directly make decisions for children
-- and in fact many librarians are quite resistant to assuming
a monitoring function with respect to children. Because of the
historic mission of libraries, it is unclear how parental empowerment
tools will be deployed in the library setting.
EMAIL
Many of the Commission's questions regarding "unsolicited
commercial email" seek facts or quantitative data. CDT is
unable to provide such information, but encourages the Commission
to consider the results of surveys such as Voter Telecommunications
Watch's survey of users' and ISPs' concerns with "junk email",
and the Privacy & American Business survey on "Commerce,
Communication, and Privacy in Cyberspace," as well as the
comments of ISPs, technologists, associations, and others who
are devising solutions to this problem (as they define it) in
the absence of legislation.
While unable to provide facts and data, CDT has comments which
we believe may provide some useful context and are responsive
to a number of the Commission's questions.
2.16 & 3.16 Are privacy or other consumer interests
implicated by this practice?
2.17 & 3.17 What are the risks and benefits, to both
consumers and commercial entities, of unsolicited commercial email?
Internet users and ISPs (Internet Service Providers) are grappling
with the issue of junk email. The label "junk email"
has loosely been affixed to email that has one or more of the
following characteristics, it is: 1) unsolicited; 2) bulk; and/or,
3) commercial. Users and ISPs complaints about junk email differ
slightly. Users tend to focus on either the unsolicited or commercial
nature of the mail. They object to receiving unsolicited commercial
email about products and services that they have not requested.
ISPs, while sharing their users' concerns, lodge unique complaints
focused on the inconvenience, cost, and damage to their services'
reputation, that is caused specifically by junk email. They are
in the unique position of being blamed at both ends of the problem:
they are often the mechanism through which such mail is sent by
unscrupulous customers and this same mechanism delivers it to
other unhappy customers.
The junk email issue and the solutions that are found to address
it, touch on both First Amendment and privacy concerns. An improper
policy or technical resolution to the issues of junk email could
have a negative impact on individual privacy, online free speech,
and the free flow of information on the Internet.
In addition, a number of proposals to deal with junk email, such
as system operator filtering, may raise liability issues similar
to those faced in both the content and intellectual property areas.
Crafting an appropriate solution to the junk mail issue requires
full consideration of the privacy, free speech and liability ramifications
of alternative proposals.
Free speech concerns
Several of the policy proposals floated thus far have suggested
labeling email based upon content. Mandatory author self-labeling
systems raise important First Amendment concerns. While commercial
speech is given less protection under our constitutional jurisprudence,
mandatory self-labeling systems may reach beyond the commercial
realm and pose a broader threat to free speech.
Currently, most junk email is not sent from well-established businesses
because it is per se reputation damaging. Anecdotal reports and
our observation indicate that fly-by-night and unknown cottage
businesses form the bulk of the today's junk email senders. Unless
junk email loses this stigma it will remain an inherently reputation-damaging
practice performed by small time operators. It is with some irony
that CDT notes that providing Internet users an easy technological
method of dealing with such email is at this point a market imperative
if reputable companies are to make this communication tool useful
for their own marketing strategies. Unless users are able to handle
"junk email" -- however it is they define it -- in a
satisfactory manner, this avenue of advertising will remain unavailable
to businesses.
Privacy concerns
The ability to limit unwanted intrusions into one's private sphere
is a core expression of individual privacy. The right to limit
intrusions into one's home has been recognized both in case law,
and in statutes that craft affirmative rights to privacy by placing
limitations on phone calls and faxes coming into the home or business
(privacy of course is not the only basis for these laws).
The principle of individual control over both the content one
receives and the personal information one reveals is central to
CDT's mission. The issue of junk email presents an opportunity
to explore the development of user based tools to facilitate individualized
control over information coming into the home. Unlike content
on the World Wide Web, email is not, at this time, under the control
of the user. Individuals have limited ability to control the content
that arrives in their inbox-although they may delete information
based on sender or subject line without ever examining the entire
document contents.
Privacy advocates, consumers, Internet service and content providers,
and marketers have all identified this as an issue that must be
addressed. We look forward to a constructive discussion on this
issue and are hopeful that useful solutions will be presented,
discussed, and possibly acted upon.
CONCLUSION
Thank you for the opportunity to share our views on the important
topic of individual privacy online. We hope to have the opportunity
to participate in the upcoming Workshop. Please contact us if
we can provide additional information or assistance.
Sincerely,
Jerry Berman
Executive Director
Deirdre Mulligan
Staff Counsel
NOTES
1 Currently
a W3C proposal for a formal project is under membership review.
(See WIC submission)
2 Its worth
noting that advocates have voiced similar concern with the lack
of effective oversight and enforcement provisions in existing
legislative privacy solutions, which often lack private rights
of action, significant penalties, and/or require the individual
to show actual harm or damages to seek redress.
3 In 1972, then-Secretary of HEW Elliot L. Richardson, appointed an Advisory Committee on Automated Personal Data Systems to explore the impact of computerized record keeping on individuals. In a report published in 1973, the Advisory Committee proposed a Code of Fair Information Practices published in Records, Computers and the Rights of Citizens: Report of the Secretary's Advisory Committee on Automated Personal Data Systems.
The 1973 Code of Fair Information Practices supplied the intellectual
and statutory framework for the Privacy Act of 1974 and served
as a model for privacy legislation in this country and worldwide.
The basic principles of the 1973 Code, as published in the Advisory
Committee's Report, are:
Report of the Secretary's Advisory Committee on Automated Personal
Data Systems, Records, Computers and the Rights of Citizens,
US Dept. of Health, Education & Welfare, July 1973 at xxiii-xxvi.
4 For example,
from the Direct Marketing Association's Personal Information Protection
Guidelines: "These Guidelines are also part of the DMA's
general philosophy that self-regulatory measures are more desirable
than government mandates whenever possible."
5 At the Federal
Trade Commission's (FTC) workshop on Privacy in Cyberspace (June
4-5, 1996) the DMA in conjunction with the Interactive Services
Association, and the Children's Advertising Review Unit of the
Council of Better Businesses released similar policy statements
on the collection of information from children online. Both advocated:
1) providing notice of information collection and the marketing
purpose behind it; 2) limiting the collection of data from children;
and 3) supporting parents ability to limit data collection on
children. Unfortunately few content and service providers operating
on the Internet have heeded these guidelines. As the Center for
Media Education (CME) and the Consumer Federation of America (CFA)
aptly point out in a joint letter to FTC Chairman Pitofsky (November
25, 1996), "five months later. . . companies are continuing
to collect personally identifiable information from children at
their Web sites without disclosing how the information will be
used or who will have access to it. . ." In their letter,
CME and CFA provide a long list of Web sites aimed at children
that fail to meet basic notice standards -- a long standing DMA
principle, and a core component of the draft guidelines DMA and
ISA released at the FTC workshop.
6 Most importantly,
they fail to address a number of the HEW Fair Information Practice
Principles, such as:
There must be a way for an individual to find out what information is in his or her file and how the information is being used;
There must be a way for an individual to correct information in his or her records;
There must be a way for an individual to prevent personal information
obtained for one purpose from being used for another purpose without
his or her consent.
7 As countries
are discovering in the First Amendment area, enacting a law limiting
or criminalizing specific content domestically has little effect
on citizens' ability to access the objectionable material.
8 P-Trak is
a people finding service. It is not available via the Internet.
9 Providing
access and correction rights to transactional data raises some
complex policy, technical and security issues. Developing policies
that address the privacy concerns inherent in the collection of
personally identifiable data -- even transactional data -- but
acknowledges some varying access rights that don't unintentionally
disrupt normal system operations is a complex task.
10 Traditionally
civil liberties and civil rights advocates have pushed for private
rights of action for violations of individual's interests.
11 Large
quantities of personal information are unprotected by privacy
rules and vulnerable to misuse and abuse. Existing US law rarely
gives individuals any direct say in how information about them
is collected, used and disclosed. For example, the Right to Financial
Privacy Act (RFPA) only limits government access to personal bank
records leaving the private sector's use of personal financial
information is unfettered. The Fair Credit Reporting Act, while
establishing some limits on the private sector's use of credit
information, does so by legislating so-called "permissible
purposes" for which industry can use and disclose credit
information rather than crafting a consent mechanism that would
allow the individual to be the arbiter of access to her own information.
Even where there has been an attempt to codify fair information
practices through federal statutes the results have generally
fallen far short of the desired goal of privacy advocates, which
is to have individuals control the collection, use, and disclosure
of personal information.
12 A simple
example, users may be interested in setting different rules or
Web sites may have different practices for handling different
data elements -- for example email address v. billing information.
Posted on April 17, 1997