Archive for the 'censorship' Category

9 Reasons Why a ‘Right to be Forgotten’ is Really Wrong

Thursday, December 8th, 2011

The European Commission concept proposal for a data protection regulation contains the so-called right to be forgotten in Article 15. This is not a surprise but the way it has been drafted is quite terrible as I will try to explain below.

Commissioner Viviane Reding made a right to be forgotten into one of the central themes of the privacy directive‘s review of the last two years and her plans to modernize the existing legal framework for the processing of personal data in the EU. While there are some valuable improvements to the existing data protection rules in the EC’s concept proposal, this right to be forgotten is amongst the worst legal inventions I have ever encountered. Below I first shortly discuss the proposal and give 9 reasons why it is really wrong and why it should be abolished.

The basic principle of the ‘right to be forgotten’ is that data subjects can ask for deletion of personal data. This right to be forgotten is an extension of the existing right of erasure with regard to personal data processing in Article 12 of the Privacy Directive, and specifically targets personal data which have been made public, such as the name or picture of a natural person on a discussion forum. It also extends to links to publications containing personal data, for instance in search engines. The proposed right in Article 15 reads as follows:

Article 15  Right to be forgotten and to erasure

1. The data subject shall have the right to obtain from the controller the erasure of personal data relating to them and the abstention from further dissemination of such data where:

(a) the data are no longer necessary in relation to the purposes for which the data are collected or otherwise processed; or

(b) the data subject withdraws consent on which the processing is based according to Article 5(1)(a), or when the storage period consented to has expired; or

(c) the data subject objects to the processing of personal data pursuant to Article 17; or

(d) their processing otherwise does not comply with this Regulation.

This right shall apply especially in relation to personal data which are made available by the data subject while he or she was a child.

2. Where the controller referred to in paragraph 1 has made the data public, it shall in particular ensure the erasure of any public Internet link to, copy of, or replication of the personal data relating to the data subject contained in any publicly available communication service which allows or facilitates the search of or access to this personal data.

3. The controller shall carry out the erasure without delay, except to the extent that the retention of the personal data is necessary:

(a) for exercising the right of freedom of expression in accordance with Article 79; or

(b) for historical, statistical and scientific research purposes in accordance with Article 83; or

(c) for compliance with a legal obligation to retain the data by Union or Member State law to which the controller is subject; this law shall meet an objective of public interest, respect the essence of the right to the protection of personal data and be proportionate to the legitimate aim pursued; or

(d) in the cases referred to in paragraph 4.

4. Instead of erasure, the controller shall restrict processing of personal data where:

(a) their accuracy is contested by the data subject, for a period enabling the controller to verify the accuracy of the data

(b) the controller no longer needs them for the accomplishment of its task but they have to be maintained for purposes of proof;

(c) the processing is unlawful and the data subject opposes their erasure and requests the restriction of their use instead;

(d) the data subject requests to transmit the personal data into another automated processing system in accordance with Article 16(2).

5. Personal data referred to in paragraph 4 may, with the exception of storage, only be processed for purposes of proof, or with the data subject’s consent, or for the protection of the rights of another natural or legal person or for an objective of public interest.

6. Where processing of personal data is restricted pursuant to paragraph 4, the controller shall inform the data subject before lifting the restriction on processing.

7. The controller shall implement mechanisms to ensure that the time limits established for the erasure of personal data and for a periodic review of the need for the storage of the data are observed.

8. Where the erasure is carried out, the controller shall not otherwise process such personal data.

9. The Commission shall be empowered to adopt delegated acts in accordance with Article 86 for the purpose of further specifying:

(a) the criteria and requirements for the application of paragraph 1 for specific sectors and in specific data processing situations;

(b) the criteria for deleting public Internet links, copies or replications of personal data from publicly available communication service as referred to in paragraph 2;

(c) the criteria and conditions as regards personal data identified for the purpose of restricting its processing as referred to in paragraph 4.

In case that some party does not comply with the right to be forgotten, Article 79 provides for a possibly hefty fine by Data Protection Authorities:

Article 79 Administrative sanctions


3. The supervisory authority shall impose a fine between 500 EUR and 600 000 EUR, or in case of an enterprise up to 3 % of its annual worldwide turnover, to anyone who, intentionally or negligently


(c) does not comply with the right to be forgotten  or to erasure, or fails to put mechanisms in place to ensure that the time limits  are observed or does not erase any public Internet link to, copy of, or replication of the personal data relating to the data subject contained in a publicly available communication service pursuant Article 15.

So what is wrong about this right to be forgotten ( if that isn’t already clear from reading the text of the proposal)? Let me list 9 reasons why this proposal looks like a terrible idea:

1. A right to be forgotten with regard to public information is anti-historical. The idea is that the further dissemination of publications of personal data becomes problematic because they have merely historical value. In very specific cases this can arguably make sense. In some European jurisdictions, Germany for instance, there is what could be called a ‘interest to be forgotten’ for criminals that have had their share of punishment and need to reintegrate into society. But careful balancing needs to take place in such contexts as well. The regulation contains a reference to processing for historical purposes, for instance in recital 46, but this reference is way too vague.

2. A right to be forgotten actually doesn’t exist. The existing right to erasure was never absolute in the first place. It is merely the expression of the general principle of purpose limitation that underlies many of the data protection rules. If a company of government agency processes personal data about you, it needs a legitimate reason to do that. If they no longer have that reason it follows they need to stop processing the data and the ‘right to erasure’ gives you a specific legal provision to ask them to do so. To call this a right is an overstatement and gives the wrong impression to those that want information deleted as well as those that would like to keep it public. To improve data protection law through the addition of welcome overstatements is quite generally misguided. There are arange of other provisions in the proposal and exieting rules that suffer the same deficit, such as the prohibition of automated decision making.

3. A right to be forgotten wrongly treats freedom of expression as an exception in relation to the right to privacy. Article 15 states the right to be forgotten as the rule. The interest of communicating about others publicly, which notably includes public figures, celebrities, etc…, is tailored as an exception. Under the proposal, the burden of proof is placed on the one that publishes information and one needs to defend engaging in such communications on the basis that they are necessary to exercise one’s right to free speech, instead of justified. From a European perspective, this does not respect the need to provide for a balance between the competing interests that are typically at stake. (Notably, from a U.S. perspective and the First Amendment, the proposal is even more problematic.) Relatedly, it strengthens the idea that there is a right to control one’s image and reputation in public and the idea that conflicts over making information about others public should be legally resolved through a system of granting rights to control over information flows. This is clearly a short-cut that oversimplifies the values that are at stake in the context of publicity of and about natural persons.

4. A right to be be forgotten will be a tool for censorship. It will strengthen those that want to censor the Web instead of helping those with justified claims to have their personal information removed. The right that is being created is a stick to hit with, the strength of which will heavily depend on the financial means to enter into a legal fight about prolonged publicity of personal information on the Internet. It will be used most effectively by those that have the strongest interest in cleaning up their reputation online.

5. A right to be forgotten strengthens the questionable role of data protection law in the context of public information and networked media. Notably, what is new in the proposal, in comparison with the existing right of erasure of personal data, is that it specifically targets public information. While data protection law has developed in reaction to the use of automated personal data processing systems for government, administrative, and business decision making, it has slowly but steadily extended into the realm of public information and the media, due to the open ended nature of its definitions and the lack of a proper restriction for the public information environment. Unfortunately, the new proposal does nothing to stop this extension of a priori legal regulation of making information about others public. The exception for the media and freedom of expression in Article 81 remains narrow and many of the rules still apply. It also leaves a problematic amount of space to the Member States to interpret the scope of the exception. It is unclear to what extent search engines, social networks, internet archives and non-professional Web publishers such as bloggers or social network users fall under the exception. Data protection law includes a range of rules and principles that apply to any processing of personal data. To apply this legal framework to the media and other contributors to the public information environment is like making journalistic ethics into actual legal rules. This legal prescription of fair treatment of others in public communications violates the principle of free speech.

6. A right to be forgotten as proposed is a frontal attack on linking, search and archiving. Article 15, second paragraph contains the heart of the attack on publicity that is being proposed in the new regulation. The idea is that data subjects should have a right to claim the removal of all sorts of links to ‘their’ personal data on the Internet. It is no surprise that linking and search are being targeted specifically. These services are fundamental to establishing robust publicity in an information environment characterized by abundance. While the provision does not explicitly establish obligations for third parties (not the source of the publication) such as search engines to remove links to personal information, it is important to realize that the regulation does not resolve whether these third parties can be considered controllers themselves.

7. The proposal includes the threat of a fine, which can go up to millions and millions of Euros. While a right to be forgotten does not actually exist and would be legally problematic due to competing fundamental legal principles, the threat of a hefty fine may help to bring it into existence in practice. The chilling effects of fining those that do not comply with the ‘right to be forgotten’ or can be considered negligent in this respect are predictable. Imagine running a blog in a way that extends what is traditionally considered as journalism. Or consider running an association, which tends to publish its proceedings of the yearly general assembly online in view of the value it attributes to transparency. Or consider running a music fan-site with a forum with discussions about concerts and related matters. Clearly, such publications will sometimes contain information related to others. Now consider receiving a letter of an attorney of a now public figure that wants to see information removed and points out you can be fined between 500 and 600.000 EURO if you would fail to defend the prolonged publication of the now historical information in question.

8. A right to be forgotten will chill publishers into restricting access to potentially controversial material. The provision, and the threat of a fine, will incentivize web publishers to limit access to controversial information for search engines. Web publishers can prevent running into claims of a right to be forgotten by restricting access for search engines to publications containing personal data, for instance by using robots.txt. Can this sometimes be a good idea? Perhaps, but clearly the information remains accessible for Web users, even though they may not find it so easily. Can this be a bad idea? Of course, it will incentivize Web publishers that would like to open up their offering as widely as possible to restrict its findability elsewhere, thereby producing a bias towards uncontroversial information in search engines and related services.

9. It is reactionary and fashionable. A right to be forgotten alligns with reactionary sentiments about new forms of publicty made possible by the Internet. If there is any support to be found for this right to be forgotten, it must be amongst those who consider the relative uncontrolled nature of such communications as a threat perse. In addition, European politicians may be charmed by the idea of showing their teeth and passing a provision that they understand as actually protecting people’s privacy online. Finally, a right to be forgotten! Hopefully, they will in time start to understand the highly problematic nature of this proposal.

Preparing for Hacking at Random 2009

Monday, August 10th, 2009

Yesterday I borrowed a tent and I just started to finalize the slides for my presentation at HAR 2009, the Dutch Hacker Camp. I will speak about censorship in the search engine context, coming Thursday, August 13th, 20:00, Dutch time. Everybody who managed to get a ticket (the event was sold out in one day), please feel free to join me after dinner in the Monty Hall!

Global Network Initiative Fails to Find Qualified Staff

Wednesday, August 5th, 2009

Rosalie Marshall reports for that the Global Network Initiative, which was launched in the end of 2008, still did not find qualified staff. The result is that the initiative is failing to really take off. What could stand in the way of finding a qualified director, if the network of participating companies, non- profits and research institutions includes some of the biggest names in their fields?

As the principles that have been adopted by the initiative could probably help to bring this global discussion about freedom of expression and privacy in a global environment to a higher level, this is quite a pity.

German Parliament About to Vote on Internet Censorship

Tuesday, June 16th, 2009

Our German neighbors are about to vote about a controversial legislative package introducing mandatory internet censorship at the network level. Netzpolitik has an excellent overview of the political debate until now. AK-Zensur, the Working Group on Internet Filtering and Censorship, has a comprehensive overview of arguments against the proposals. Germany would be the first EU country to adopt mandatory Internet filtering for Internet access providers. Some ISPs in some other European countries already filter on the basis of black lists provided to them by government agencies and/or private organizations. Here is part of Markus Beckedahl’s account of the action against the proposed censorship:

The net community did not only oppose the governments plans, but also made constructive suggestions how to deal with the problem of child pornography without introducing a censorship architecture and circumcising constitutional freedoms. The working group on censorship demonstrated the alternatives for instance by actually removing over 60 websites containing child pornographic content in 12 hours, simply by emailing the international providers who then removed this content from the net. The sites were identified through the black lists of other countries documented on Wikileaks. This demonstration underlines the protesters main arguments: instead of effectively investing time and efforts to have illegal content removed from the internet, the German government is choosing censorship and blocking – an easy and dangerous way out. The greatest fear of the protesters is that once in place, the infrastructure will be used to censor other forms of unwanted content, not only child pornography. German politicians already seem to be lining up with their wish-list of content to be censored in future – the suggestions ranging form gambling sites, Muslim web pages, “killer games”, and the music industry cheering up with the thought of finally banning pirate bay and p2p.

You can find a detailed linklist of the zensursula-debate here (in german).

French Constitutional Court Strikes Down Core Elements of Hadopi

Thursday, June 11th, 2009

In an important decision the French Constitutional Court has declared the core elements of the proposed three strikes law in France (Hadopi) unconstitutional, considering the freedom of expression and communication, the presumption of innocence, the right to privacy and confidentiality of communications.

This puts further pressure on the Council of Ministers to respect the EP’s adoption of amendment 138, requiring member states to respect the fundamental rights of internet end-users in the context of internet access. The Dutch minister of economic affairs recently wrote a letter to the Dutch parliament, stating the Dutch government did not consider the three strikes strategy to be acceptable. The letter also refers to the new (constitutonally problematic) Dutch notice and takedown code of conduct (my translation):

In the Dutch context, a procedure to deal with end-users with bad intentions is also not necessary, because, partly at the government’s urging, we have adopted a code of conduct on the basis of which internet providers, at the initiative of law enforcement authorities, take action themselves against criminal activity such as child pornography (notice and takedown code of conduct). It will have to be clear that the amendment does not interfere with this code of conduct. The Netherlands wants further clarification of the amendment before it can take a definitive point of view. In particular, it will have to become clear in which cases there should be a prior judicial decision and ion which cases not.

The Dutch government expects the Council to reject the Telecom package as adopted by the EP and the negotiations in third reading to be restricted to amendment 138.

Julie Cohen on the Changing Meaning of `Unauthorized Access`

Monday, June 8th, 2009

This is a really great lecture! Julie Cohen manages to touch upon almost everything I am interested in, in about half an hour.

Website Liable For ‘Wrong’ Suggestions In Google Result nr. II

Thursday, May 28th, 2009

The motivation (in Dutch) of the preliminary judgment of the Court in Amsterdam about the liability of a website for a wrong suggestion in a Google search result snippet has been published. The problem was that a combination of two sentences ‘suggested’ that defendant Zwartepoorte, a car salesman, was bankrupt.

As was to be expected, the judge concludes that its judgment is very case specific. It clarifies that it involves a balancing act between the freedom of expression of websites and the damages suffered by the plaintiff.  According to the Court, the duty of care to remove or restructure the content that caused a combination of snippets to appear in a Google search result existed because:

1. plaintiff had suffered damages because of the wrong suggestion;

2. defendant used the services of Google, had optimized the ranking of its website in Google, and profited from this (through advertisements);

3. Plaintiff had requested to do something about it a number of time, with reference to the damage it was suffering;

4. It was easy for defendant to make a simple change to the website that would have caused the snippet to change;


Ar these circumstances that case specific? I very much doubt it. And are they convincing?

Let us first consider the aspect of damage. There was proof that some people thought that plaintiff was bankrupt. They were calling and writing the company and even asking the regional newspaper in Zeeland, the PZC. There was no proof that this caused plaintiff to suffer material damage. It’s unclear whether the Court assumes there was any. From the lack of material damages in the verdict, it seems there was insufficient proof for this. The damage therefore consists of people thinking that defendant was bankrupt.

I wonder what is meant by the statement that defendant used the services of Google under 2. Normally, the inclusion of one’s website in Google does not imply the use of any service. It could mean that defendant used Google’s webmaster tools to optimize the site, so the webmaster should have been aware of Google and the importance of Google’s search results. The other arguments under 2 fit into this reasoning. Not only had plaintiff knowledge of Google’s search service, it optimized it and profited from a prominent listing because it attracted visitors, which in turn increased advertising revenues.

The argument under 3 increases the knowledge of defendant that something could be causing damages to plaintiff. Argument 4 relates to the costs and difficulty of avoidance to cause damage. Defendant did not control the combination of sentences in the search result but by restructuring its website or removing the word bankrupt from the particular page, it could cause the combination to disappear, according to the Court.

In other words, the Court puts itself in the website editor’s shoes. I find this highly problematic from a free speech perspective. And implicitly, the court assumes that there is not a lot of value in the website and the combination of information it contained.

Legal Cause

The other basic problem with the Court’s reasoning is in the aspect of assigning the damage to the conduct (negligence) of defendant. This assignment of damages, i.e. ‘legal cause’, is a substantive legal test in (Dutch) tort law, which relies on the foreseeability or the remoteness of damages. It is with regard to this test that the court’s reasoning breaks down. Again, the damage consisted of people thinking that plaintiff was bankrupt. For legal cause to be fulfilled, these thoughts should be somehow reasonable. And freedom of expression makes the test of legal cause particularly important. One can not be liable for a completely wrong conclusion that is drawn from one’s statement. Google search results are search results, they are not an independent sources of information. In particular, Google’s snippets are not an authoritative source of information about bankruptcy. If one wants to check whether a company is bankrupt, there are specific sources where this information can be found. And people that search for [defendant bankrupt] were probably acting on a rumor already. They in particular should be expected to check the underlying information. It also follows that the conclusion that defendant could easily prevent the damage is a little too easy. In principle, it’s a company’s own responsibility to address unreasonable conclusions about its business, by its own statements or conduct.

Who’s responsible?

Of course, the judge had to clarify why defendant, a website, could be held responsible for a combination of (perfectly legal) sentences in a search result which it did not control. The Court argues that it might be true that the website had no control over the functioning of Google but suggests that these questions about the opacity of Google’s functioning should be addressed in a broader context. With reference to the arguments under 2 above, it then concludes that defendant had its own responsibility. The Court evades the question whether Google would have been liable as well, i.e. if it would have refused to take down the result after a request to do so. I doubt it. First, Google would have hired better lawyers, that would have made a better case against it. And second, the judgment fits well into the paradigm to address ‘problems’ in search engines by addressing the sources of information. But seriously, to make websites liable for the impact of legal publications in search engines on unreasonable end-users is a step too far.

It will be interesting to see whether there will be an appeal. Even if there isn’t, I think we can safely assume that this judgment will remain ‘unique’. UPDATE: Defendant appealed, this time with a lawyer.

Via Arnoud Engelfriet.

Website Liable For ‘Wrong’ Suggestions In Google Result

Friday, May 15th, 2009

A Dutch judge has concluded (in a preliminary judgment) that a website is liable for a wrong suggestion in the snippet text of ‘its’ Google search result. The judge has ordered the webmaster to change its website in a way that will stop the wrong suggestion from showing up in Google. Note that the text on the website itself was not unlawful. The problem was that a search for [zwartepoorte failliet] (= CompanyName bankrupt] resulted in the following snippet text:

Volledige naam: Zwartepoorte Specialiteit: BMW … Dit bedrijf is failliet verklaard, het is overgenomen door het motorhuis Ik heb bij Boot Rialto gewerkt …

My translation:

Complete name: Zwartepoorte Specialiteit: BMW … This company has been declared bankrupt, it has been acquired by the motordealer I have worked for Boat Rialto …

One way to do as the judge ordered is to take down the complete page with information about the company Zwartepoorte. That is what seems to have happened now. Another solution would be to use code language such as is common with the word pr0n.

Clearly the combination of words and the quote in question will show up all over the Web so I don’t see any benefits for the company in question to have won this case. And of course, the judgment (the reasoning of the Court will be published on 27 May 2009) does not make any sense, from a tort law or from a technology perspective. A reason could be that the defendant appeared in person.

I am fascinated by the idea that the existence of search engines, and Google in particular, gives websites some kind of qualified responsibility with regard to the content on their website. I see more and more examples of this, for instance the idea that personal data should be prevented from being indexed through the use of robots.txt instructions.

Libraries React to the Google Books Settlement

Tuesday, May 5th, 2009

The American Library Associations have filed their amicus brief to the Google Books Settlement approval procedure. They call for strong judicial oversight, stronger guarantees against possible abuse of market power, and more emphasis on intellectual freedom and privacy protection.

I have been following the settlement proceedings, mostly through James Grimmelmann’s efforts, and was looking forward to the libraries’ position on privacy and intellectual freedom. I have to admit that I am a little disappointed.

On privacy, the brief concludes:

In response to concerns raised by libraries and others, Google has stated that it will take appropriate measures to protect user privacy. The Library Associations expect Google, in consultation with the Library Associations and other representatives of user interests, to meet this commitment. Google and the Registry should develop strong policies to protect personally identifiable information, and provide users with clear notice describing those policies.

In other words the brief does not call for limitations on the registration of individual reading habits or the further use of such information. And the problem that the brief does not address is the lack of protection against government access under US law. Without legislative action, the reading records that would be collected by Google are accessible with a simple subpoena. Google and the Registry can settle what they want, and the court can approve what it wants, they cannot offer additional protection under US law against access by law enforcement and national security agencies.

On intellectual freedom, a library term for freedom of expression and information, the brief discusses Google’s discretion to exclude books for editorial and non-editorial reasons. A recent debate over library censorship shows how real these concerns are in the United States. The brief notes:

While Google on its own might not choose to exclude books, it probably will find itself under pressure from state and local governments or interest groups to censor books that discuss topics such as alternative lifestyles or evolution. After all, the Library Project will allow minors to access up to 20% of the text of millions of books from the computers in their bedrooms and to read the full text of these books from the public access terminals in their libraries. Although public libraries have often contended with demands to eliminate or restrict access to specific books, any collection management decision by a particular librarian affected only that community.

What the brief fails to notice, is that the books in the Google Books Program are already available somewhere in a United States library. One would expect this to mean that the material is legal and suitable for American readers, from a librarian’s perspective at least. Why would libraries agree to an extra round of editorial discretion with regard to material that has been carefully selected already?

The remedy proposed in the brief is accountability through transparency. The Court, overseeing the settlement, should be able to direct Google to provide a list of excluded books with a motivation for these exclusions. This will probably be enough for Google to think twice about excluding books for bad reasons, but I would have expected libraries to take a stronger stand on (private) censorship and simply oppose the removal of books from Google Books because they would be unsuitable for children.

ECtHR 10 March 2009, Times v U.K.

Tuesday, April 28th, 2009

About a month ago, the European Court of Justice decided an important internet and freedom of expression case. I just posted a link to a commentary I have written for Mediaforum (in dutch). I do recommend reading the case.

One conclusion I drew from it, is that increased publicity and findability can end up having a negative impact on the integrity of online archives.

I point to the Court’s first general, explicit (and lukewarm) consideration of the importance of the Internet:

In light of its accessibility and its capacity to store and communicate vast amounts of information, the Internet plays an important role in enhancing the public’s access to news and facilitating the dissemination of information generally. The maintenance of Internet archives is a critical aspect of this role and the Court therefore considers that such archives fall within the ambit of the protection afforded by Article 10.

I criticize the Court for its distinction between the protection of online archives of publications and new publications. It is great that the electronic environment incentivizes newspapers not to make such a distinction and not to remove their historical publications. It means that the electronic environment can add to the value of the newspaper for itself, for other information providers (they can link to them) and for users (they can inform themselves by navigating a networked hyperlinked environment).

And to conclude these short pointers, I wonder why the Court uses the word ‘likely’ in some of its crucial considerations with regard to the implications of Article 10 ECHR:

The Court therefore considers that, while the primary function of the press in a democracy is to act as a “public watchdog”, it has a valuable secondary role in maintaining and making available to the public archives containing news which has previously been reported. However, the margin of appreciation afforded to States in striking the balance between the competing rights is likely to be greater where news archives of past events, rather than news reporting of current affairs, are concerned. In particular, the duty of the press to act in accordance with the principles of responsible journalism by ensuring the accuracy of historical, rather than perishable, information published is likely to be more stringent in the absence of any urgency in publishing the material.

This is a Court that stops being the highest Court to address these questions. I have looked for a similar weak statement about the implications of Article 10 ECHR but did not find it. Please send me a note if you know another!

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