COMMENTS OF INTERNET PRIVACY WORKING GROUP CONCERNING CONSUMER ON-LINE PRIVACY-P954807

INTERNET PRIVACY WORKING GROUP
for information contact:
Jerry Berman or Deirdre Mulligan
Center for Democracy and Technology
1634 Eye Street, NW
Suite 1100
Washington, DC 20006

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

Question 2.14 & 3.14 regarding Technological Developments

The Internet Privacy Working Group (IPWG) submits these comments and requests to participate in "Session Two: Consumer Online Privacy" and "Session Three: Children's Online Privacy" of the Federal Trade Commission's upcoming Workshop on Consumer Information Privacy. In collaboration with the MIT-based World Wide Web Consortium (W3C), IPWG requests to present a demonstration and discussion of the Platform for Privacy Preferences (P3).

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. IPWG participants include: America Online; AT&T; Business Software Alliance; Center for Media Education; Citicorp; Coalition for Advertising Supported Information and Entertainment; Consumer Federation of America; Direct Marketing Association, Inc.; Disney; The Dun & Bradstreet; Electronic Frontier Foundation; eTRUST; IBM Corp.; Interactive Services Association; MCI Communication Corp.; Microsoft Corp.; National Consumers League; and, the World Wide Web Consortium (W3C).

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 IEPWG effort. Currently a W3C proposal for a formal project is under membership review. 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.

Privacy is an important consideration for people participating in online activities. Like all important decisions, individuals' decisions to divulge personal information should be informed and meaningful. IPWG members hope that the P3 platform will enable Internet users to make meaningful choices about the flow of personal information.

The P3 platform will incorporate a language for Internet users and Web site operators to negotiate privacy considerations. By setting preferences on their Web browsers, or through other software programs, users will be able to express privacy preferences and set rules that control the flow of their personal information. Parents will also be able to set rules that govern their children's activities online. Web site operators will be able to use the P3 language to explain their privacy practices to visitors. The P3 platform will facilitate automated discussions between individuals and Web sites about the flow of personal information. Once preferences and practices are easily communicated Internet users will be able to interact with Web sites that address their privacy concerns.

The P3 project is based on IPWG's belief that fostering the development of a common platform for addressing privacy concerns is critical to the development of the Internet as a social, political and commercial medium. IPWG seeks to apply the "user empowerment model," currently used to allow parents and individuals to block or filter information based on content, to the protection of privacy on the Internet. We believe that by giving individuals the ability to make up-front decisions regarding the use and disclosure of personal information, the Platform for Privacy Preferences offers a policy option that simultaneously supports stronger privacy policy, more secure communications and transactions, and vigorous commerce.

We look forward to the opportunity to participate in the upcoming Workshop. Please contact us at (202)637-9800 if we can be of additional assistance.

Sincerely,

Jerry Berman
Jerry Berman
jberman@cdt.org
IPWG Coordinator

Deirdre K. Mulligan
Deidre K. Mulligan
deirdre@cdt.org
IPWG Coordinator