GILC Submission on
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
GILC members are concerned with matters of human rights,
civil liberty, and personal freedom.
- 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 Rights.
- 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 unpopular,
- enabling the development of country profiles to
facilitate a global/universal rating system desired by
- 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
- 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 Web,
- 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 others,
- 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
- 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
- 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
- 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
"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 children..."
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 expression.
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 1.1.
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
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)
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 Libertà nella Comunicazione
Elettronica Interattiva (ALCEI)
American Civil Liberties Union
Bulgarian Institute for Legal Development
CommUnity - The Computer Communicators Association
Computer Professionals for Social Responsibility
Cyber-Rights & Cyber-Liberties (UK)
Derechos Human Rights
Electronic Frontiers Australia
Electronic Frontier Foundation
Electronic Privacy Information Center
FITUG e.V. Foerderkreis Informationstechnik und
Fronteras Electrónicas España (FrEE)
Human Rights Watch
Imaginons un Reseau Internet Solidaire