Secure Web Addressability Network

For publishers to be able to use a signal there must be a clear definition concerning the legal meaning of the signal and their obligation to comply with it. SWAN provides this clarity, and a cryptographic audit trail to confirm compliance via the Model Terms. SWAN enables the GPC vision.

A global privacy regulation does not yet exist for the web. However, many regional regulations share many of the same privacy-protecting principles. Among many of these common principles to safeguard people’s privacy are:

1. The right to have notice and choice about how personal data will be used in clear, concise language. 
2. Relying on pseudonymous identifiers, rather than a person’s directly-identifiable identity, reduces privacy risks. 
3. Data minimization to further reduce privacy risks.
4. Provide people the right to be forgotten.

Under Europe’s GDPR, an organization is required to have a legal basis to collect and process personal data. A common legal basis for GDPR is for an organization (“data controller”) to request consent from the person associated with the personal data. GDPR also has further requirements about being appropriately informed about the future uses of the data. 

Notice and Choice. The SWAN preference dialog clearly explains to users that the SWID will be used to provide them ad-funded access across the websites they visit. This dialog also allows them to opt into personalized marketing.  By simplifying the notice and choice, people can signal their default preferences in a consistent fashion. Of course, people can provide specific organizations additional data outside of the SWAN framework, which publishers and marketers can use to further augment SWID. This opt-in approach to sharing data helps ensure fairness and proportionality, especially when there is robust competition to offer people even greater choice.

European ePrivacy legislation (which applies in tandem with the GDPR) recognizes that consent is not required for strictly necessary cookies that are required for web properties to operate. While this does not extend to personalized marketing, it does cover cookies that remember privacy preferences and many security-related purposes.

Pseudonymization and Data minimization. SWAN’s pseudonymous identifiers minimize how directly identifiable the data is and automatically resets to minimize the length of time it will be useful.  SWAN further minimizes risks by restricting the use of sensitive information associated with SWAN data. 

Right to be Forgotten. This SWAN dialog also allows people to exercise their Right to Be Forgotten.

No (unless the browser wipes cookies). The SWID has a standard lifespan that persists across browsing sessions, but people can reset it at any time.  Additionally, people can receive a temporary SWID by relying on the existing in-private/incognito function of their favourite browser.

The SWID is stored in a browser cookie file and thus works only for a single browser. People can choose to provide an optional email that can persist their preferences across additional browsers and devices they use. Receivers of this hashed email are restricted from re-identifying the individual associated with this pseudonymous identifier.

No technology can be built such that a motivated bad actor could not use it to harm others. For this reason, SWAN improves transparency and enables the creation of an accountable audit trail to provide non-repudiable evidence to hold bad actors accountable while ensuring we follow the rules of due process.

The entire supply chain, and a browser with permission to access the audit log, would know the parties involved. A browser with sufficient volume and opted in users who share the supply chain would also know the popularity of market participants. In order for a breach to have occurred a party will have to have committed a harm.

There is a strong incentive for them not to do so. Innocent breach due to an operational mistake will be quickly rectified and the eco-system informed. Deliberate breach will almost certainly result in the party going out of business as all other parties will cease to work with them. There is a big risk associated with deliberate breach. Given the availability of the SWAN audit data it is likely that with machine learning web browser vendors or other auditors could perform an audit function and show signs of possible breach.

Specifically, those conducting personalised marketing without permission.  SWAN will provide data to enable many new use cases which we find exciting. SWAN does not take anything away.

As long as there is free will in the world there will be bad actors doing bad things. SWAN.community’s approach is to help identify them rather than prohibit all acts. SWAN.community places equal emphasis on laws, economics, engineering and maths.

The user only provides their email and the four icon code to the User Interface Provider (UIP) commonly a CMP. The SWAN Operator will then return the hash of the email address using the four icons as the salt for the hash. SWAN.commnuity only ever provides pseudo anonymous identifiers. If a UIP used the email address for another purpose they would need to get separate permission for that.

No. SWAN.community requires minimum standards of audit, enforced by contract.

There might be different Model Terms for different jurisdictions or even different networks. That will be for the ecosystem to decide. At the moment we think it’s possible to combine most major laws into a general contract governed by contract law with the courts and laws of England and Wales as the fall back.

Yes. The vision behind General Privacy Control (GPC), of a simple privacy signal from people to organizations, was recently supported by the California Attorney General (https://twitter.com/AGBecerra/status/1354850321692934144?s=20). (https://theccpa.org/#1798.135(a)(6)

However, one of the challenges of GPC (and its forerunner Do Not Track) is that it does not mandate a clear definition as to what people are signalling and how they should expect to continue to interact with web properties that rely on interoperable data to provide them their online experience. In contrast, SWAN maintains this same simplicity of design, but adds plain language associated with the signal to ensure both people can signal a legal preference with clear meaning and that receivers have contractual obligations to comply with these signals. SWAN provides this clarity, and a cryptographic audit trail to confirm compliance via the Model Terms. SWAN enables the GPC vision.