Mozilla responds to the UK CMA consultation on Google’s commitments on the Chrome Privacy Sandbox
Regulators and technology companies together have an unique opportunity to improve the privacy properties of online advertising. Improving privacy for everyone must remain the north star of efforts surrounding privacy preserving advertising and we welcome the recent moves by the UK’s Competition Markets Authority to invite public comments on the recent voluntary commitments proposed by Google for its Chrome Privacy Sandbox initiative.
Google’s commitments are a positive step forward and a sign of tangible progress in creating a higher baseline for privacy protections on the open web. Yet, there remain ways in which the commitments can be made even stronger to promote competition and protect user privacy. In our submission, we focus on three specific points of feedback.
First, the CMA should work towards creating a high baseline of privacy protections and an even playing field for the open web. We strongly support binding commitments that would prohibit Google from self-preferencing when using the Chrome Privacy Sandbox technologies and from combining user data from certain sources for targeting or measuring digital ads on first and third party inventory. This approach provides a model for how regulators might protect both competition and privacy while allowing for innovation in the technology sector, and we hope to see this followed by other dominant technology platforms as well.
Second, Google should not be restricted from deploying limitations on the use of third-party cookies for pervasive web tracking, which should be made independent of the development of its Privacy Sandbox proposals. We encourage the CMA to reconsider requirements that will hinder efforts to build a more privacy respecting internet. Given the widespread harms resulting from web tracking, we believe restrictions on the use of third party cookies should be decoupled from the development of other Chrome Privacy Sandbox proposals and that Google should have the flexibility to protect its users from cross-site tracking on an unconditional timeframe. By doing so, agencies such as the CMA and ICO would publicly acknowledge the importance expeditiously limiting the role of third party cookies in pervasive web tracking.
And third, relevant Chrome Privacy Sandbox proposals should be developed and deployed via formal processes at open standard bodies. It is critical for new functionality introduced by the Chrome Privacy Sandbox proposals to be thoroughly vetted to understand its implications for privacy and competition by all relevant stakeholders in a public and transparent manner. For this reason,we encourage the CMA to require an explicit commitment that relevant proposals are developed via formal processes and oversight at open standard development organizations (SDOs) and deployed pursuant to the final specifications.
We look forward to engaging with the CMA and other stakeholders in the coming months with our work on privacy preserving advertising, including but not limited to proposals within the Chrome Privacy Sandbox.
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