W3C Unofficial Draft, 27th June 2020
Editors:
James Rosewell ([email protected])
Joshua Koran ([email protected])
Contributors:
Alan Chapell ([email protected])
Arnaud Blanchard ([email protected])
Brad Rodriguez ([email protected])
Daniel Sepulveda ([email protected])
Hardeep Bindra ([email protected])
Ian Meyers ([email protected])
Jochen Schlosser ([email protected])
John Sabella ([email protected])
Kristoffer Nelson ([email protected])
Paul Bannister ([email protected])
Paul Chachko ([email protected])
Scott Menzer ([email protected])
Tom Kershaw ([email protected])
Wilfried Schobeiri ([email protected])
The purpose of this document is to help those designing new internet technologies to consider the important individual, social and business impacts of new features or specifications as well as suggest common mitigation strategies of those impacts as we improve web advertising. Thus, this document does not lay down dogma about how any specific internet technology should be designed.
The self-review questions below are meant to be useful when considering the impacts of a new feature or specification on key stakeholders. The mitigation strategies are meant to assist in the design of the feature or specification.
This document is not meant as a "requirements checklist", nor does an editor or group’s use of this document obviate the editor or group’s responsibility to obtain "wide review" of their specification before implementation. Furthermore, the principles below should not be understood as exhaustive, although addressing these during the review process should ensure new technologies improve web advertising.
The W3C has a shared goal of preserving the web as an open platform for diverse and rich experiences provided by multiple parties. Towards this end, our goal is to provide monetization opportunities that support the open web while balancing the needs of publishers and the advertisers that fund them with improvements to protect people from the individual and societal impacts of tracking content consumption over time.
The recommendations in this document refer to the data collection and processing required for continued ad-funding of web content and services, and not to the processes by which it is created, nor to the devices or user agents to which it is delivered.
New features make the web a stronger and livelier platform. Throughout the feature development process there are both foreseeable and unexpected impacts to multiple stakeholders. These risks may arise from the nature of the feature, some of its part(s), or unforeseen interactions with other features. Such risks and impacts may be mitigated through careful design and application of the principles and design patterns described below.
Standardizing web features presents unique challenges. Descriptions, protocols and algorithms need to be considered strictly before they are broadly adopted by vendors with large user bases. If features are found to have undesirable impacts on important stakeholder interests after they are standardized, then, it is better to transparently list these ahead of browser vendors implementations, to give opportunity for broader feedback.
To consider impacts on stakeholders it is convenient to think in terms of their interests, as a way to illuminate the possible risks to people as they interact with ad-funded publishers. While existing documents highlight the risks to individuals this document adds a wider social context of groups of individuals that form communities, businesses, governments, and other organizations. [INTERNET-FOR-END-USERS].
Thus this document provides questions to review the concrete social and competition concerns that should be considered when developing a feature for the web platform in balance with the important security and privacy interests of individuals. The various advertising stakeholders and their interests are documented in the W3C Improving Web Advertising Business Group - Success Criteria [IWA-SUCCESS-CRITERIA]. The use cases that currently support these stakeholders are described in the Advertising Use Cases [USE-CASES] document. These individual and organizational interests can be encapsulated into four key principles:
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Interoperability: Ensuring interoperable standards of communication and ease of data exchanges among individuals and market actors.
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Choice: Ensuring market actors have choices regarding which organizations they can work with, which requires a level playing field for all organizations to compete on their merits.
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Accessibility: Ensuring cost-free access for all, regardless of economic means.
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Accountability: Ensuring people feel trust with the information and digital services they engage with to access it, while ensuring market actors trust the markets are operating fairly.
In the mitigations section, this document outlines a number of techniques that can be applied to mitigate impacts to these important stakeholder interests.
Documenting the various concerns and impacts in web principles sections of a document is a good way to help implementers and web developers understand the risks and impacts that a feature presents, and to ensure that adequate mitigations are in place. Simply adding a section to your specification with yes/no responses to the questions in this document is insufficient.
If it seems like a feature does not have an impact on the improve web advertising principles, then say so inline in the spec section for that feature:
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There are no known social or competitive impacts of this feature. Saying so explicitly in the specification serves several purposes:
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Shows that a spec author/editor has explicitly considered these impacts when designing a feature.
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Provides some sense of confidence that there might be no such impacts.
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Challenges social and competitive minded individuals to think of and find even the potential for such impacts.
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Demonstrates the spec author/editor’s receptivity to feedback about such impacts.
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Demonstrates a desire that the specification should not be introducing social or competitive impacts.
The following section outlines the key principles to balance the benefits and impacts to stakeholders as we seek to improve web advertising.
In answering this question, it often helps to ensure that the use cases your feature and specification enable are made clear in the specification itself to ensure that the reader understands the feature-privacy trade-offs being made. Are the benefits outweighed by the potential risks? If so, how?
Improved Web Advertising should facilitate data exchange between people and among multiple, separate internet services required to support ad-funded publishers. Personal data is often used as an input to provide these internet services.
The end service people enjoy are dependent on data interoperability. By definition, multiple organizations need to work together when operating a robust supply chain.
Given individual’s security and privacy concerns it is necessary to balance those important interests with the interoperability requirements of the organizations people interact with. Data minimization and pseudonymization are important techniques to minimize these risks. Below are some of the questions to help identify how a specification may impact any of these interests.
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IWAR01.1 Does the specification impact a form of identity and data transfer required for data interoperability?
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IWAR01.2 Does the specification facilitate portability of personal data across services and service providers?
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IWAR01.3 Does the specification support secure point-to-point communication?
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IWAR01.4 Does the specification introduce any cross-publisher navigational issues?
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IWAR01.5 Does the specification support providing consistent experiences across publishers?
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IWAR01.6 Does the specification impact people’s choice over how data is shared with whom?
Improved Web Advertising should not impose high barriers to entry for new market entrants. Ensuring a level playing field requires that specifications not biased in favour of vertically-integrated organizations over smaller publishers. Empowering smaller publishers to benefit from the supply chain service providers mitigates against the risk of unfair competition and provides people greater diversity of publisher content to choose from. Ensuring marketers with equal access to budget control and measurement (e.g., frequency capping) across publishers and on a single publisher further mitigates against the risk of unfair competition.
Below are some questions to help identify if the specification may impact publisher or marketer choices on who they can work with.
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IWAR02.1 Does the specification support decentralization or offer sufficient options for centralized alternatives?
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IWAR02.2 Does the specification support open market competition?
Improved Web Advertising should not impose high costs to send or receive internet-enabled data. The primary cost many people are concerned with involves conditioning access upon a direct financial payment, which can discriminate against the economically disadvantaged. This risk can be mitigated by enabling publishers to provide access to their internet content and services in exchange for the information required to fund their website via advertising.
A benefit of reducing financial barriers to access is that a wider diversity of publishers can enable broader expression of viewpoints. Below are some questions to help identify if the specification may reduce the diversity of internet content and services people can access.
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IWAR03.1 Does the specification support frictionless access to a wide diversity of publishers?
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IWAR03.2 Does the specification support people’s access to internet services, regardless of economic means?
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IWAR03.3 Does the specification impact freedom of expression, diversity including access to minority opinions, and freedom of information?
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IWAR03.4 Does the specification support keeping people free from self-censorship?
Improved Web Advertising participants must be responsible for their actions to encourage trustworthy data collection and processing. Below are some questions to help identify if the specification provides additional transparency or accountability around the collection and processing of personal data.
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IWAR04.1 Does the specification support the auditability of data exchanges and processing?
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IWAR04.2 Does the specification support enforceability for violations related to inappropriate actions?
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IWAR04.3 Does the specification support supplying appropriate remedies for harm?
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IWAR04.4 Does the specification impact freedom of the press to investigate and report on wrongdoing?
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IWAR04.5 Does the specification provide people the right to be forgotten?
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IWAR04.6 Does the specification provide people the right to correction or deletion?
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IWAR04.7 Does the specification facilitate an organization’s compliance with privacy regulations?
This questionnaire is not exhaustive. After completing an impact review, it may be that there are additional aspects of your specification that a strict reading, and response to, this questionnaire, would not have revealed. If this is the case, please convey those concerns, and indicate if you can think of improved or new questions that would have covered this aspect.
To mitigate the impact to stakeholders by the changes proposed in your specification, you may want to review how to apply one or more of the mitigations described below to your feature.
The W3C promotes interoperability by designing and promoting open (non-proprietary) computer languages and protocols. Data interoperability provides more opportunity for new services to innovate solutions with the same data. More specifically, data interoperability fosters innovation by reducing access costs by standardizing the protocols and formats used to exchange information. These standards help provide transparency, which is important for creating the accountability that builds trust.
For example, standardized ad creative formats streamline digital advertising marketplaces by reducing creative production costs for marketers thus increasing the number of available publishers that can deliver their message. These same standards reduce publisher operations costs by providing access to increased marketer demand relative to customized ad formats.
Because informed choice requires transparency, organizations should communicate advertising-related metadata with precisely defined standards that enable people to understand which brand sent the ads they receive. This metadata enables all the touchpoints with the people’s internet client to transparently display this information as well as more easily communicate appropriate signals of consent between people and organizations. [IWAR01.1]
Interoperable standards of consent and preference choices facilitate people’s communication with organizations related to this collection and processing of their personal data. People must have choice over how their data is shared and with whom. [IWAR01.6 ] The standardized description and display of data collection and processing purposes further aids the transparent, bi-directional communication between people and organizations. [IWAR01.2]
Securing point-to-point transmission of both organizations’ advertising content and people’s choice signals reduces the risk that an active attacker may alter these messages. [IWAR01.3 ]
Standardization of privacy and security signals also supports the ease of navigation for individuals across different publisher properties and services. [IWAR01.4] To further ease cross-publisher navigation, privacy preferences may be centralized. People’s consent and preference signals should persist across all individual and organization interactions. [IWAR01.5 ]
For example, the W3C’s Proposed Recommendation Process [TEC-DEV] defines several requirements for specification entrance criteria for any Proposed Recommendations, among which is Interoperability. Interoperability is one of the seven core principles [SEVEN-POINTS] behind many of the existing web standards:
Societies today are plagued by fake news and attempts at foreign manipulation of democratic elections. Providing people greater choice over access to news and information, mitigates these risks by increasing the cost for malicious attackers to dominate the information people can access. A free press can provide appropriate counterweight to fake news, while watch-dog reporting on important issues helps uncover the abuse by bad actors.
To mitigate the above risks, organizations must support either decentralization or sufficient options for centralized alternatives. Decentralization is furthered by enabling publishers to offer mixed content from different sources. By reducing the cost of market entry, more publishers can offer their views on important social topics. Making internet content easily shareable also supports freedom of information.
Moreover, organizations should support open market competition that requires a level playing field for all organizations to compete on their merits. Moreover, the choices of publishers and marketers over their supply chain partners requires this competition. [IWAR02.2 ]
To further foster competition and innovation, organizations must ensure people can start new organizations to enter the market and compete against existing incumbents.
For example; the W3C’s Antitrust and Competition Guidance [ANTITRUST] requires the W3C not to restrict competition and by implication choice.
W3C promotes “One Web” that is available on any device. [W3C-MISSION] The web is designed to be accessible for all people regardless of economic means. [W3C-MISSION; CONTRACT-FOR-THE-WEB; IWAR03.2 ] Accordingly, organizations should provide people frictionless access to a wide diversity of publishers. [IWAR03.1]
The web is not a “read-only” network but encourages people’s collaborative interaction with organizations and one another. Accordingly, organizations should support freedom of expression for people to interact with the internet-enabled content and services they engage with. An additional benefit of freedom of expression is that it promotes diversity by enabling minority opinions and views to be better represented by different organizations.[IWAR03.3 ]
Given privacy-preserving requirements that people’s offline, directly identifiable identity not be disclosed by default when people interact with digital content and services, individuals may make different privacy choices on each device or application or instance of an application. For example, incognito or private browsing activities must not persist beyond a temporary session generated during this selected mode. Moreover, the browsing activities generated prior to enabling the private mode must not be made accessible while this mode is enabled. Preserving private mode access to information and communication, helps mitigate the risks to society that can result from repressing minority views. Accordingly, organizations must keep people free from self-censorship that could result from re-identification of people’s content consumption without appropriate notice and choice. [IWAR03.4]
Accountability for appropriate data collection and processing requires both transparency and auditability. Transparency requires that organizations must provide individuals access rights to their personal data as well as how their personal data is used to match advertising content and measure its effectiveness. [IWAR04.1]
To reduce the risk of harm, organizations must provide people the right to correction or deletion of their personal data as well as to provide people the right to be forgotten. [IWAR04.5 ] and [IWAR04.6]
Risk mitigation does not eliminate the possibility of harm. Thus, accountability further means that violations for inappropriate action must supply people with appropriate remedies for harm. [IWAR04.3] To aid in this effort, organizations must keep appropriate policy-aware records or audit logs that can identify non-compliance with regulations. [IWAR04.2] While different jurisdictions have different laws and regulations, organization’s audit records must aid their compliance with privacy regulations. [IWAR04.7]
Independent oversight regarding the collection and processing of personal data is an additional safeguard to ensure organizations are abiding by their duties. While sometimes this oversight is provided by trade organizations or public agencies, the free press also helps provide necessary safeguards. Organizations must support freedom of the press to investigate and report on wrongdoing to hold all organizations accountable to the same standards. [IWAR04.4]
The W3C has created a separate Security and Privacy Questionnaire [SECURITYPRIVACY] to further help developers consider these important individual issues.
Conformance requirements are expressed with a combination of descriptive assertions and RFC 2119 terminology. The key words “MUST”, “MUST NOT”, “REQUIRED”, “SHALL”, “SHALL NOT”, “SHOULD”, “SHOULD NOT”, “RECOMMENDED”, “MAY”, and “OPTIONAL” in the normative parts of this document are to be interpreted as described in RFC 2119. However, for readability, these words do not appear in all uppercase letters in this specification.
All of the text of this specification is normative except sections explicitly marked as non-normative, examples, and notes. [RFC2119]
Examples in this specification are introduced with the words “for example” or are set apart from the normative text with class="example", like this:
This is an example of an informative example.
Informative notes begin with the word “Note” and are set apart from the normative text with class="note", like this:
Note, this is an informative note.
Terms defined by reference
[WCA] defines the following terms:
Client
Cookie
Gateway
Message
Publisher
Server
User
User Session
Web Page
[BIZ-DIC] defines the following terms:
Marketer
[ANTITRUST]
Wendy Seltzer. Antitrust and Competition Guidance 01-March-2017. URL: https://www.w3.org/Consortium/Legal/2017/antitrust-guidance
[RFC2119]
S. Bradner. . March 1997. Best Current Practice. URL: https://tools.ietf.org/html/rfc2119
[SECURITYPRIVACY]
Jason Novak; Lukasz Olejnik; Mike West. Working Group Note, 8 May 2020. URL: https://www.w3.org/TR/2020/NOTE-security-privacy-questionnaire-20200508/
[WCA]
Brian Lavoie; Henrik Frystyk Nielsen. Web Characterization Terminology & Definitions Sheet. 24-May-1999. URL: https://www.w3.org/1999/05/WCA-terms
[BIZ-DIC]
Business Dictionary. URL:
[CONTRACT-FOR-THE-WEB]
Sir Tim Berners-Lee. Contract for the Web. 25 November 2019. URL: https://contractfortheweb.org
Principle 1: Ensure everyone can connect to the internet
Principle 2: Keep all of the internet available, all of the time
Principle 3: Respect and protect people’s fundamental online privacy and data rights
Principle 4: Make the internet affordable and accessible to everyone
Principle 5: Respect and protect people’s privacy and personal data to build online trust
Principle 6: Develop technologies that support the best in humanity and challenge the worst
Principle 7: Be creators and collaborators on the Web
Principle 8: Build strong communities that respect civil discourse and human dignity
Principle 9: Fight for the Web
[INTERNET-FOR-END-USERS]
M. Nottingham.The Internet is for End. 10 March 2020. Users URL: https://intarchboard.github.io/for-the-users/draft-iab-for-the-users.html
[SEVEN-POINTS]
W3C. Seven point summary of W3C. 15th December 2005. URL: https://www.w3.org/Consortium/Points/
[IWA-SUCCESS-CRITERIA]
J. Rosewell. W3C Improving Web Advertising Business Group - Success Criteria. June 2020. URL: https://github.com/w3c/web-advertising/blob/master/success-criteria.md
[TEC-DEV]
Ian Jacobs. World Wide Web Consortium Process Document chapter W3C Technical Report Development Process. 14th October 2005. URL: https://www.w3.org/2005/10/Process-20051014/tr.html
[USE-CASES]
B. Savage. Advertising Use Cases. June 2020. URL: https://github.com/w3c/web-advertising/blob/master/support_for_advertising_use_cases.md
[W3C-MISSION]
W3C Mission. 30 June 2004. URL: https://www.w3.org/Consortium/mission
Original scorecard below with suggested edits for anything we keep:
| Criteria reference | Primary stakeholder interest | Interest category (Functionality / Privacy / Interoperability /etc) | Interest priority (Must / Should) | Interest description |
|---|---|---|---|---|
| IWAR01.1 | Organizations | Interoperability | Should | Organizations should communicate advertising-related data with precisely defined standards |
| IWAR01.2 | Individual | Interoperability | Must | Organizations must enable data portability of personal information across services |
| IWAR01.3 | Individual | Interoperability | Should | Organizations should support secure point-to-point communication |
| IWAR01.4 | Individual | Interoperability | Should | Organizations should support ease of navigation for individuals |
| IWAR01.5 | Individual | Interoperability | Should | An individual’s choices should persist across all individual<>organization interactions |
| IWAR01.6 | Individual | Interoperability | Must | An individual must have choice over how their data is shared and with whom. |
| IWAR02.1 | Organizations | Choice | Must | Organizations must support decentralization or sufficient options for centralized alternatives |
| IWAR02.2 | Organizations | Choice | Should | Organizations should support open market competition |
| IWAR03.1 | Individual | Accessibility | Should | Organizations should provide people frictionless access to a wide diversity of publishers |
| IWAR03.2 | Individual | Accessibility | Must | Web must be accessible for all people regardless of economic means |
| IWAR03.3 | Individual | Accessibility | Should | Organizations should support freedom of expression for people |
| IWAR03.4 | Individual | Accessibility | Must | Organizations must keep people free from self-censorship |
| IWAR04.1 | Individual | Accountability | Must | Organizations must provide Individual data access rights and processing use-cases must be auditable |
| IWAR04.2 | Individual | Accountability | Should | Violations for inappropriate actions should be enforceable |
| IWAR04.3 | Individual | Accountability | Must | Organizations must supply people appropriate remedies for harm |
| IWAR04.4 | Organizations | Accountability | Must | Organizations must support freedom of the press to investigate and report on wrongdoing |
| IWAR04.5 | Individual | Accountability | Must | Organizations must provide people the right to be forgotten |
| IWAR04.6 | Individual | Accountability | Must | Organizations must provide people the right to correction or deletion |
| IWAR04.7 | Organizations | Accountability | Must | Must aid organizations’ compliance with privacy regulations |