[Chapter-delegates] FW: [Internet Policy] ISOC Document - 10 Signs of a Good Privacy Protection Law/Policy

[Richard Hill]

The message below is self-explanatory.

 

I don’t recall seeing a call for comments on the cited document, but perhaps I missed it. If there was not a call for comments, then I think that there should have been, if for no other reason, then at least to make the chapters feel more involved.

 

Best,

Richard

 

From: InternetPolicy [mailto:internetpolicy-bounces at elists.isoc.org] On Behalf Of Ayden Férdeline
Sent: mercredi, 27. février 2019 17:39
To: ISOC INTERNETPOLICY
Subject: [Internet Policy] ISOC Document - 10 Signs of a Good Privacy Protection Law/Policy

 

Hi,

 

On social media I have noticed that ISOC is circulating these privacy principles <https://www.internetsociety.org/wp-content/uploads/2019/02/Factsheet-10-Sign-of-Good-Privacy-Protection-Law_web.pdf> . I am not sure how they were developed and I do not want to sound too critical, but there is new scholarship in the field of privacy and data protection that I do not see reflected within them.

 

That is perhaps besides the point. If these are principles that ISOC has come to believe are important, then I am wondering why ISOC has not adopted them itself? 

 

I made a comment along similar lines about a year ago on this mailing list, and if I may be so indulgent as to repeat myself... ISOC has a terrible privacy policy. 

 

It is confusing. It does not accurately reflect the data processing activities that ISOC engages in. And, while I have not had the time to engage in a detailed empirical analysis of its every sentence, from what I have read, I feel like it would be a pretty safe bet to say it is not compliant with either the letter or spirit of the GDPR - let alone other privacy laws. And let's not talk about the tracking devices on the ISOC website.

 

If ISOC wishes to occupy a leadership role in the privacy space, and I think it has some tough competition there, I think it would send a better message if it had a privacy notice itself which reflected the values it is calling for. 

 

There is a real moment now for the US to adopt a federal privacy law. There are a mixture of strong and weak proposals that are being circulated. But even the weakest proposals seem stronger in some critical areas than what ISOC is calling for. I don't understand why that is. 

 

I have read about 100 proposals over the past month. I have just been reading the Information Technology Industry Council's proposed approach and, for the most part, they are really good. Perhaps their members can afford the compliance costs. However, in addition to being clear and pragmatic, they also sound possible to operationalize and I imagine that they would prevent a lot of the black and white breaches of consumer expectations that we are seeing today.

 

There's also some good in ISOC's principles that others are not calling for, such as the collaborative drafting approach and the importance of global interoperability. I would like to see ISOC amplify these messages because they are very important. These are topics that ISOC can intelligently speak to which others can't.

 

As an ISOC member I often feel very disconnected from ISOC. I don't know why this is, because I am a member of other membership-based organizations whose values or positions might occasionally differ from mine, but I generally feel like I can understand where they are coming from. Maybe they just communicate differently. With ISOC I feel like there are a lot of surprises and not a whole lot of consultation. And there's a lot of irony there, given what ISOC preaches to others.

 

I'd like to see ISOC do better. It has an important mission and significant resources at its disposal, yet doesn't seem to punch above its weight like I'd like to see it do.

 

Thanks for reading,

 

Ayden Férdeline

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