Meta & Children's Online SafetyChat: shouldn't do proactive enforcement unilaterally
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Monday 30 November 2020
15:40Michel John Tristan ProttiAlso, for presentation, is idea shavi does pages 3 and 5, Rob does India overview and Tom does youth?
16:21Robert Michael ShermanWe talked with them a year ago about youth issues, which was when we had the discussion around age verification. One takeaway from that was that we should begin advocating for platform-level/industry-level solutions as opposed to FB "owning" it entirely. We've been advocating for this and have gotten some traction but (1) the feedback has been that FB *also* has to do work on this rather than just advocate to push it off to others, and (2) the next step is to put together a spec with more detail on what this would look like. Probably worth calling out the OS/platform level verification as a piece of the work we are doing centrally.
16:22Robert Michael ShermanThe broader takeaway was that we shouldn't do proactive enforcement unilaterally / without everyone else having to do that, and we should revisit in a year to see where we are. So that's partially what we are doing.
16:22Robert Michael ShermanFine with me
16:24Shavi@Rob Is the YouTube work on age verification in EU worth calling out (in voice over), We dont know about India specific plans from other competitors yet.
16:36Robert Michael ShermanYes, that's a good one. I don't think anyone HAS India plans on this yet - it's literally a line in a law that says you have to verify age, and if you ask them what that means they say that the regulator will figure it out.
16:36Robert Michael ShermanThe point is that we should figure it out before they do, so our approach is the model
16:37Robert Michael ShermanAlso - I shared the deck with Claire and she's going to send you a few specific comments on the youth piece
16:50Michel John Tristan ProttiCan we try and get pre-read out soon-ish? Shavi can you send?
16:52Shavi@Tom we have few blanks on slide 13. Post which I think we can send. I am happy to send.
16:53Thomas JudeI will complete before 6pm. Rob, are ████ comments in there?
16:54Robert Michael ShermanNot sure - shavi, did you connect w/ her yet? If not, do you mind just reaching out?
16:54Robert Michael ShermanShe only had 3-4 small edits
17:01ShaviI havent. @Tom was working on Youth slide. Most of the content is from Claire's slide. I can ping her now.
17:03VladimirAgreed - we have also not done any of the EBDP work and that can easily take a lot of their bandwidht
19:11Thomas JudeEBDP has youth stuff in it :-)
19:54VladimirTrue - I meant other SCD and consent requirements.
[Handwritten exhibit sticker: EXHIBIT / Sherman / 15]
20:06Thomas JudeI know. But to this point, we should present Youth as thematic issue that is common to many forthcoming regulations, either as specific youth regulations or as a fundamental component of general privacy regulations. This has been the case as much previously. essentially, most forthcoming privacy legislation has a youth component.
20:08VladimirYes - the key point we wanted to make with Youth is that we want another team to potentially take point on key parts of it
20:09VladimirCurrently the narrative on why we picked those two issues (youth and india) isn't clear - so we will have to talk to it
20:09Thomas JudeYes. Most of it is in CPP and ABP. There are implications to sharing defaults that are FB app and IG specific.
20:10ShaviTom Nathan and I discussed getting 30 min tomorrow morning to talk through deck together as a team, Vlad Michel and Rob it's hard to align all calendars but I would include you on the invite.
20:10ShaviSince we mostly did this deck async, it will be helpful to find sometime to talk through some of these key points we want to land with the audience tomorrow.
20:11Shavi GoelVlad I agree with your point that why India and Youth isn't coming through clearly. It's in part those are two areas we have clear burning platform and most clarity on what work we need to do.
20:13ShaviThe overall prioritization across all obligations was based on enforcement risk, current compliance gap assessment and opportunity to shape the law. India is high on all three
20:14ShaviYouth is a combination of many different laws which are medium to high enforcement risk, High on mismatch between compliance and current practices and high on policy opportunity to shape upcoming IDPC and ICO guidelines
21:12Michel John Tristan ProttiI can't make the 9am synch tomorrow but critical for us to be aligned on the specific asks of product teams we'll make.
21:12Michel John Tristan ProttiLet me know where you land at 9
21:18ShaviSlide 9 and 13 have our current asks. Michel, Vladimir Fedorov do have any concerns or flags on these? Much of this was Tom, Nathan and I taking our best guesses on which product team should drive this work, we would love your feedback.
21:20ShaviAlso, does the group has any context around the federated leadership and ownership around reg response? This is another area Vlad shared some input about make more crisper in the room.
21:21VladimirI am not sure if we are immediately ready to absorb a person from each PG on India
21:21VladimirShould we make it Jan 1st ask?
21:23VladimirFor slide 13 - the asks are good but I think slide portrays more alignment than there is
21:23VladimirI fully expect Shultz to disagree
21:24ShaviAgree. Also we can clarify that this might be more phased, starting with FOAs and ABP first, before adding Integrity, CCT or other PG reps.