Hello everyone,
We would like to share with you comments
<https://www.ntia.doc.gov/files/ntia/publications/wikimedia_foundation_comments_on_ntia_privacy_rfc.pdf>
we submitted last month in response to one of the first open consultation
processes discussing a framework for a federal privacy regulation in the
U.S. The request for comments
<https://ntia.doc.gov/files/ntia/publications/fr-rfc-consumer-privacy-09262018.pdf>
was issued by the National Telecommunications and Information
Administration, an agency of the United States Department of Commerce that
advises on telecommunications policies, in this case: on consumer privacy.
You may read all of the comments submitted at the NTIA’s website
<https://www.ntia.doc.gov/other-publication/2018/comments-developing-administration-s-approach-consumer-privacy>.
We felt it was important to give input here based on the Wikimedia
Foundation’s unique perspective on privacy and data protection.
Privacy is an important policy priority at the Wikimedia Foundation. When,
in 2013, revelations revealed the depth of the NSA’s surveillance into
online activity, Wikipedia usage changed demonstrably
<https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2769645>. Research has
shown that people act differently when they worry their actions or
communications aren’t private, and that is the heart of why privacy is so
important to the Wikimedia movement. This is why we made the switch to HTTPS
in 2015
<https://blog.wikimedia.org/2015/06/12/securing-wikimedia-sites-with-https/>,
and why we are currently engaged in a lawsuit
<https://policy.wikimedia.org/stopsurveillance/> challenging those very
same “Upstream” surveillance practices.
Privacy does not only mean protection from government eyes, and
increasingly, the topic of platforms collecting and selling data has been
the center of conversations about privacy in the U.S. In our comments, we
highlight how we are one of the few large internet platforms that does not
rely on the tracking or sale of user data to generate revenue, and we
incorporate this aspirational perspective when discussing the NTIA’s
proposed framework. Our comments welcome a much-needed harmonization of
privacy laws in the United States if done right, and suggest that the NTIA
needs greater clarity and a more clear focus on user-impact in order to do
so.
We invite you to think about privacy as a priority for the future of free
knowledge, and what that means for the Wikimedia movement as privacy rules
and regulations become more prevalent in the U.S. and abroad.
Best,
Allison
--
Allison Davenport
Technology Law and Policy Fellow
Wikimedia Foundation
1 Montgomery Street, Suite 1600
San Francisco, CA 94104
adavenport(a)wikimedia.org