[NFBMT] FW: [tech-vi Announce List] FTC, Commercial Surveillance, and Overlays

d m gina dmgina at mysero.net
Sun Aug 14 20:51:19 UTC 2022


Thanks so much for sharing.
My question is this,
I keep getting calls where folks no my name,
that scares me.
If I understood what I read,
it would be better if I didn't order on line except threw amazon?
Just a question.
Dar
Original message:
> FYI, based on our discussion on Friday.



> Best

> George





> From: tech-vi at groups.io <tech-vi at groups.io> On Behalf Of David Goldfield
> Sent: Sunday, August 14, 2022 1:07 PM
> To: List <tech-vi at groups.io>
> Subject: [tech-vi Announce List] FTC, Commercial Surveillance, and Overlays



> Adrian Roselli - Friday, August 12, 2022 at 3:33 PM


> FTC, Commercial Surveillance, and Overlays


> August 12, 2022; 0 Comments 
> <https://adrianroselli.com/2022/08/ftc-commercial-surveillance-and-overlays.html#Comments> 
> <https://adrianroselli.com/wp-content/uploads/2022/08/FTC-seal.svg>

> The U.S. Federal Trade Commission on August 11, 2022 announced it is 
> exploring rules cracking down on commercial surveillance and lax data 
> security practices 
> <https://www.ftc.gov/news-events/news/press-releases/2022/08/ftc-explores-rules-cracking-down-commercial-surveillance-lax-data-security-practices> 
> . The sub-heading of that press release plainly states it is seeking 
> public comment on harms from the business of collecting, analyzing, and 
> monetizing information about people.

> Major companies have regularly been in the news for gathering and 
> selling user information 
> <https://www.cbsnews.com/news/the-data-brokers-selling-your-personal-information/> 
> , and in more than a few cases data breaches of that user information 
> <https://en.wikipedia.org/wiki/List_of_data_breaches> , never mind 
> unintended consequences 
> <https://www.nytimes.com/2012/02/19/magazine/shopping-habits.html>  of 
> using that information. Sometimes that data gathering is clearly 
> covered by the Terms of Use that its users must agree to in order to 
> use the service. Sometimes not 
> <https://thenextweb.com/news/users-facebook-confusing> .


> Where Accessibility Overlays Come In


> An accessibility overlay refers to technologies meant to improve the 
> accessibility of a web site. This is usually done by referencing code 
> from another site, which the user’s browser retrieves and applies to 
> the current page on each visit. In an ideal scenario, this makes the 
> page more accessible and means a user does not need to ask for help 
> (itself a privacy risk).

> Accessibility overlays are in a unique position because they gather 
> more non-HIPAA health data 
> <https://news.bloomberglaw.com/health-law-and-business/insight-the-top-five-health-care-privacy-issues-to-watch-in-2020#:~:text=Non%2DHIPAA%20Health%20Data> 
> than the typical web site. They are generally marketed to site owners 
> as a legal risk mitigation solution, not a vehicle for users to 
> disclose their disabilities.

>  
> <https://adrianroselli.com/wp-content/uploads/2022/08/FTC-ANPR_accessiBe-profiles.png> 
> An overlay asks the user to disclose their disability.

> Asking users to self-identify is built into accessibility overlay 
> interfaces. They prompt users if they are using a screen reader, have 
> dyslexia, or match pre-defined profiles such as ADHD, vision impaired, 
> prone to seizures, and so on. In some cases, the overlay makes a guess 
> based on how the user interacts with the page.

> Unlike a user of a social media service, who agrees to the platform’s 
> Terms of Service before accessing it, a user who visits a web site with 
> an accessibility overlay has no opportunity to decline the service 
> before it starts to gather information about them. Many users may not 
> even recognize that the overlay has Terms that are distinct from the 
> site they are visiting, governed under laws from a different locality. 
> Assuming the site has its own Terms.

> [W]e find that 99.98% of Americans would be correctly re-identified in 
> any dataset using 15 demographic attributes. Our results suggest that 
> even heavily sampled anonymized datasets are unlikely to satisfy the 
> modern standards for anonymization…

> Estimating the success of re-identifications in incomplete datasets 
> using generative models 
> <https://www.nature.com/articles/s41467-019-10933-3> , 23 July 2019, Nature

> As profiles or settings follow overlay users across sites, more 
> information is gathered about their surfing habits. That information 
> can be paired with the non-HIPAA health data the overlay vendor is 
> capturing, with no clear way to opt out.

> This means accessibility overlay vendors are stewards of a great deal 
> of personal information from users. Users who may not understand they 
> have given up that information. Information that can be valuable to 
> data brokers. Even if the best actors in the space have a good privacy 
> policy, that privacy policy is moot in the face of a data breach.

> Anonymizing this non-HIPAA health data gathered from users is 
> insufficient because de-anonymizing it is trivial — 99.98% of users can 
> be identified with only 15 data points.

> The risk, real or perceived, to users is compounded by the historic 
> behavior of the current overlay vendors. Disabled users have repeatedly 
> raised concerns 
> <https://www.vice.com/en/article/m7az74/people-with-disabilities-say-this-ai-tool-is-making-the-web-worse-for-them> 
> about the validity of overlays 
> <https://www.nbcnews.com/tech/innovation/blind-people-advocates-slam-company-claiming-make-websites-ada-compliant-n1266720> 
> , relationship with the community 
> <https://www.numerama.com/politique/759804-faciliti-la-solution-pour-linclusion-en-ligne-qui-refuse-la-critique.html> 
> , marketing promises 
> <https://www.wired.com/story/company-tapped-ai-website-landed-court/> , 
> and overall effectiveness 
> <https://www.nytimes.com/2022/07/13/technology/ai-web-accessibility.html?unlocked_article_code=AAAAAAAAAAAAAAAACEIPuomT1JKd6J17Vw1cRCfTTMQmqxCdw_PIxftm3iWka3DKDm8ZiPgYCIiG_EPKarskbtp2wDmRAdZKO7I0X_14z-teI10rSxWtptHMvqU5FBgPiND5WHIqjdWKVKok8DTuYy7peepzneO07lfZOzO-RKCJ0yE-d1k18Y9vfA753nwJz_zAE-Rly5Ipi6dac5N5RjgAYyGLuvP6WV4paJjdMEaqukRhUPpZWDrTgdeZ97oBFQ1SAl7MR3p7in0uvJIeYJhEefaicGNzPZb2kr4TCWd3LYa2B5ZXR4Pck7RisLGlugXZjNRJGDCbYdUTTQ5ATpvV&smid=url-share> 
> , to the point the National Federation of the Blind disavowed them 
> <https://www.forbes.com/sites/gusalexiou/2021/06/26/largest-us-blind-advocacy-group-bans-web-accessibility-overlay-giant-accessibe/> 
> . One never responded to a DPIA request under GDPR 
> <https://tink.uk/accessibe-and-data-protection/>  from a British user.

> 700+ digital accessibility practitioners, experts, end users, 
> researchers, and more have signed an open letter 
> <https://overlayfactsheet.com/>  imploring companies not to use 
> overlays. There is a site dedicated to cataloguing the false marketing 
> claims <https://overlayfalseclaims.com/>  of overlay companies.

> Many tech-savvy disabled users genuinely do not trust accessibility 
> overlay vendors. Users who understand them are constantly wary they may 
> visit a site where an overlay is installed, potentially matching up any 
> information on file with browsing patterns, and making their disability 
> status available to anyone willing to pay.


> What to Do


> Read through the Commercial Surveillance and Data Security Rulemaking 
> <https://www.ftc.gov/legal-library/browse/federal-register-notices/commercial-surveillance-data-security-rulemaking> 
> , where fact sheets, a plain text version, and a Spanish language 
> version are also available.

> FTC’s Advance Notice of Proposed Rulemaking (ANPR) will soon open for 
> public comment on the harms stemming from commercial surveillance and 
> whether new rules are needed to protect people’s privacy and information.

> If you want to share comments publicly 
> <https://www.regulations.gov/search?agencyIds=FTC&sortBy=commentEndDate&sortDirection=desc&withinCommentPeriod> 
> , you will have 60 days from the date of publish in the Federal 
> Register (it is not yet posted at the time of this writing).

> You can also share your input during a virtual public form on September 
> 8 
> <https://www.ftc.gov/news-events/events/2022/09/commercial-surveillance-data-security-anpr-public-forum> 
> , 2022 at 2:00pm ET. Sign up by August 31 
> <https://www.ftc.gov/form/anpr-registration> , 2022 at 8:00pm ET.

> The Commercial Surveillance and Data Security Rulemaking sections on 
> “Automated Systems”, “Discrimination”, and “Consumer Consent” offer 
> some sample questions users can answer.

> Here is one from “Automated Systems”:

> Does the weight that companies give to the outputs of automated 
> decision-making systems overstate their reliability? If so, does that 
> have the potential to lead to greater consumer harm when there are 
> algorithmic errors?

> Here a question from “Discrimination” (disability is a protected 
> category, though not listed in the sample question):

> How prevalent is algorithmic discrimination based on protected 
> categories such as race, sex, and age? Is such discrimination more 
> pronounced in some sectors than others? If so, which ones?

> And from “Consumer Consent”:

> Should the Commission require different consent standards for different 
> consumer groups (e.g., parents of teenagers (as opposed to parents of 
> pre-teens), elderly individuals, individuals in crisis or otherwise 
> especially vulnerable to deception)?

> I encourage you to provide your own feedback however you see fit and 
> based on your own experiences.

> While there was some hope proposed bill S.3620 – Health Data Use and 
> Privacy Commission Act 
> <https://www.congress.gov/bill/117th-congress/senate-bill/3620>  might 
> start to offer some protection for users, there has been no movement in 
> months. This FTC effort is the next best bet. If you have been affected 
> by overlays, now is a good opportunity to say so.


> License


> The content is licensed under Creative Commons Attribution-ShareAlike 
> 4.0 International (CC BY-SA 4.0 
> <https://creativecommons.org/licenses/by-sa/4.0/> ). I am doing this in 
> case you want to excerpt it for your own comments.


> Tags


> accessibility <https://adrianroselli.com/tag/accessibility> , law 
> <https://adrianroselli.com/tag/law> , overlay 
> <https://adrianroselli.com/tag/overlay>


> Other Posts


> Earlier post:  
> <https://adrianroselli.com/2022/08/brief-note-on-calendar-tables.html> 
> Brief Note on Calendar Tables

> https://adrianroselli.com/2022/08/ftc-commercial-surveillance-and-overlays.html



>      David Goldfield

> Assistive Technology Specialist



> Feel free to visit my Web site

> WWW.DavidGoldfield.info <http://WWW.DavidGoldfield.info>

> _._,_._,_

>   _____

> Groups.io Links:

> You receive all messages sent to this group.

> View/Reply Online (#2496) <https://groups.io/g/tech-vi/message/2496>  | 
> Reply To Group 
> <mailto:tech-vi at groups.io?subject=Re:%20%5Btech-vi%20Announce%20List%5D%20FTC%2C%20Commercial%20Surveillance%2C%20and%20Overlays> 
> | Reply To Sender 
> <mailto:david.goldfield at outlook.com?subject=Private:%20Re:%20%5Btech-vi%20Announce%20List%5D%20FTC%2C%20Commercial%20Surveillance%2C%20and%20Overlays> 
> | Mute This Topic <https://groups.io/mt/93021881/556400>  | New Topic 
> <https://groups.io/g/tech-vi/post>
> Your Subscription <https://groups.io/g/tech-vi/editsub/556400>  | 
> Contact Group Owner <mailto:tech-vi+owner at groups.io>  | Unsubscribe 
> <https://groups.io/g/tech-vi/leave/11402533/556400/2099672654/xyzzy>  
> [kerscher at montana.com]

> _._,_._,_

> _______________________________________________
> NFBMT mailing list
> NFBMT at nfbnet.org
> http://nfbnet.org/mailman/listinfo/nfbmt_nfbnet.org
> To unsubscribe, change your list options or get your account info for NFBMT:
> http://nfbnet.org/mailman/options/nfbmt_nfbnet.org/dmgina%40mysero.net


More information about the NFBMT mailing list