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Fwd: Civil liberties groups ask W3C to reject PICS

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>From: Declan McCullagh <declan@well.com>
>To: fight-censorship@vorlon.mit.edu
>Subject: Civil liberties groups ask W3C to reject PICS
>Message-Id: <v0300780eb0bb6da0b47f@[]>
>Date: Mon, 15 Dec 1997 18:29:46 -0500



GILC Submission on PICS
December 1997

       We, the undersigned members of the Global Internet
       Liberty Campaign (GILC), make the following
       submission in relation to the W3C Proposed
       Recommendation "PICSRules 1.1" dated 4 November
       1997 (http://www.w3.org/TR/PR-PICSRules.htm).

       GILC members are concerned with matters of human
       rights, civil liberty, and personal freedom.

       Noting that:

              Article 19 of the Universal Declaration of
              Human Rights explicitly protects freedom of
              expression for all and specifically the "freedom
              to hold opinions without interference and to
              seek, receive and impart information and ideas
              through any media".

              This principle has been reaffirmed in multiple
              international agreements, including the
              International Covenant on Civil and Political

              W3C's mission is "to realize the full potential of
              the Web: as an elegant machine-to-machine
              system, as a compelling human-to-computer
              interface, and as an efficient human-human
              communications medium".

              PICSRules 1.1 have been developed for, or can
              be used for, the purposes of:

                    preventing individuals from using the
                    Internet to exchange information on
                    topics that may be controversial or

                    enabling the development of country
                    profiles to facilitate a global/universal
                    rating system desired by governments,

                    blocking access to content on entire
                    domains, via the specification of full or
                    partial domain names and/or IP
                    addresses, regardless of the username,
                    port number, or particular file path that
                    is specified in the URL,

                    blocking access to Internet content
                    available at any domain or page which
                    contains a specific key-word or
                    character string in the URL,

                    over-riding self-rating labels provided
                    by content creators and providers.

              PICSRules 1.1 go far beyond the original
              objective of PICS to empower Internet users to
              control what they and those under their care
              access. They further facilitate the
              implementation of server/ proxy-based filtering
              thus providing a more simplified means of
              enabling upstream censorship, beyond the
              control of the end user.

       We draw to W3C's attention that:

              similar techniques that block Internet sites have
              prevented access to innocuous speech, either by
              deliberate intent, through oversight, or as a
              result of ignorance of the infrastructure of the

              repressive governments are desirous of a more
              easily implementable, technological, means of
              restricting information their citizens are able to
              access and inhibiting their communications with

              methods to restrict the ability of citizens to gain
              access to information and to communicate with
              others are contrary to principles of free
              expression and democratic society,

              PICSRules 1.1, in enabling the use of
              wildcards in IP addresses, etc, facilitate
              blocking of not only entire domains, but of the
              majority of content originating from specified

              the rapidly increasing number of people
              accessing the Web discredits the perception, of
              various government and industry
              representatives, that limitations on content
              accessibility are essential to provide a climate of
              confidence for the furtherance of electronic
              commerce. In fact, filtering and rating systems
              intended for the protection of minors have
              proven inefficient and counter-productive,

              the ability of community organisations to
              develop a ratings system applicable to their
              values, a stated original intent of PICS, is not
              enhanced by the complex, albeit sophisticated,
              language of PICSRules 1.1.

       Whilst the W3C media release of 25 November 1997
       states that:

              "PICSRules is a mechanism for
              exchanging user settings, resulting in
              an easy one-click configuration...With
              PICSRules parents can go to a PTA
              site and download initial settings which
              are recommended for primary school

       even a cursory analysis of PICSRules 1.1 indicates that
       the likelihood of community organisations developing
       complex profiles is slim. The necessary expertise is
       more likely to be acquired by governments seeking to
       restrict access to content and inhibit freedom of

       PICSRules 1.1 are clearly intended to serve the purpose
       of enabling the empowered to restrict the ability of the
       unempowered to communicate.

       It seems apparent that PICSRules have been developed
       in response to calls from governments who seek a more
       efficient and effective technological means of restricting
       human-to-human communications. European and
       Australian governments, at the least, are involved in the
       development of a global rating system which will be
       enabled by PICSRules 1.1. Mandatory labelling of
       content has already been proposed in the UK, Australia,
       USA. The ability of governments to restrict access and
       freedom of expression through the use of firewalls
       /proxies will be enhanced by the adoption of PICSRules

       In view of the above, we oppose the proposed adoption
       of PICSRules 1.1 on the grounds that they will provide
       a tool for widespread global censorship, which will
       conflict with W3C's mission to "realize the full potential
       of the Web...as an efficient human-human
       communications medium".

       We call on W3C to reject the proposals of the
       PICSRules Working Group and direct resources
       towards working on genuine metadata systems which
       will facilitate easier and faster access to desired classes
       of information by all Internet users, rather than solely
       supporting denial of access.


       American Civil Liberties Union (ACLU) (USA):
       "Fahrenheit 451.2: Is Cyberspace Burning? -- How
       Rating and Blocking Proposals May Torch Free Speech
       on the Internet"

       Computer Professionals for Social Responsibility
       (CPSR) (USA):
       "Filtering FAQ"

       Cyber-Rights & Cyber-Liberties (UK):
       "Who watches the Watchmen: Internet Content Rating
       Systems, and Privatised Censorship"

       Electronic Privacy Information Center (USA):
       "Faulty Filters: How Content Filters Block Access to
       Kid-Friendly Information on the Internet"

       Imaginons un Reseau Internet Solidaire (IRIS) (F):
       "Labeling and Filtering: Possibilities, Dangers, and

       This submission is made by the following organisations:

              Associazione per la LibertÓ nella
              Comunicazione Elettronica Interattiva

              American Civil Liberties Union

              Bulgarian Institute for Legal

              CommUnity - The Computer
              Communicators Association

              Computer Professionals for Social

              Cyber-Rights & Cyber-Liberties (UK)

              Derechos Human Rights

              Electronic Frontiers Australia

              Electronic Privacy Information Center

              Fronteras Electrˇnicas Espa˝a (FrEE)

              Human Rights Watch

              Imaginons un Reseau Internet Solidaire



              Privacy International


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