Preliminary Comments for Senate Commerce Committee Hearing on DNT

This Thursday, the US Senate Committee on Commerce, Science and Transportation is holding a hearing entitled “The Need for Privacy Protections: Is Self-Regulation Adequate?” Mozilla along with several others have been asked to comment at the hearing on the current state of: i) industry self-regulation; ii) Mozilla’s Do Not Track feature; and iii) the industry’s ability to provide consumers with adequate tools to protect their personal information online.

We’re planning to participate and provide comments based on our experience and perspective. We also posted the questions to governance for input.

In addition to core Mozilla messages about user choice, control, and transparency, the comments will include the following key key points:

  • Industry self-regulation can work when it’s a multi-stakeholder process that reflects the views of all of the relevant parties involved in data transactions including users, developers, service providers, publishers, and the ad networks.
  • Non-voluntary regulatory measures are a last resort. They can introduce unintended consequences that can be harmful to a fragile web ecosystem. As a result we should be cautious in this regard and give voluntary industry efforts every chance to succeed before interceding with regulation.
  • The desire to predict and deliver content that appeals to users is a core driver behind efforts to collect and analyze data about us. This will only increase particularly with the inclusion of the mobile data graph. This is not inherently bad, and delivering content that users want, when they want it, is a good thing if it’s done transparently and in harmony with user intent.
  • Commerce is a vital and beneficial Internet activity. Enabling and maintaining economic ecosystems on the web is essential to a robust and healthy Internet. Commercial imperatives and user choice/control are not mutually exclusive. They can and must coexist through a combination of technical capabilities and user-centric business and data practices.
  • DNT requires cooperative efforts of services providers, ad networks, browsers, and other parts of the web ecosystem. We’re optimistic that the multi-stakeholder process ongoing at the W3C will result in a consensus on both the meaning of DNT and how websites should respond.
  • DNT is one method to give users a voice in how third parties collect, use, and track information about them. It’s not the only method, nor the be all and end all of the data and privacy relationship that exists between users and service providers.

We’re in the process of completing the comments now and will submit them in advance of the hearing on Wednesday.

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