[HN Gopher] France latest to slap Clearview AI with order to del...
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       France latest to slap Clearview AI with order to delete data
        
       Author : arkadiyt
       Score  : 52 points
       Date   : 2021-12-19 19:26 UTC (3 hours ago)
        
 (HTM) web link (techcrunch.com)
 (TXT) w3m dump (techcrunch.com)
        
       | jackjeff wrote:
       | How is France (or the EU) going to enforce their extra
       | territorial law on a US company with no business interests in the
       | EU?
       | 
       | > Enforcing fines on companies without an EU base does present a
       | regulatory challenge, however.
       | 
       | Understatement of the year.
        
       | dmortin wrote:
       | Let's say Clearview says they are deleting the data. How could
       | France make sure the data is actually deleted? Is it possible
       | without perusing Clearview's source code and accessing its
       | servers?
        
         | hlbjhblbljib wrote:
         | They'd also have to be able to identify pictures of French
         | people. Perhaps a large US-based corporation could help them
         | developing a tool to do it? They'd need lots of examples first.
        
       | [deleted]
        
       | kmlx wrote:
       | > Clearview sought to suggest the company is not subject to the
       | GDPR -- although the regulation is extraterritorial in scope,
       | meaning it is applicable and (at least in theory) enforceable
       | outside the EU's borders in instances when EU people's data has
       | been processed in violation of the rules.
       | 
       | GDPR applies also outside of the EU? who exactly thought this one
       | up? how can the EU possibly think it can enforce this and does
       | the EU think europeans should be subject some special rules when
       | in a foreign country?
        
       | downWidOutaFite wrote:
       | Clearview AI is one of the main arguments I have used to convince
       | many friends and family to stop posting face pictures to the web,
       | especially of children who cannot consent.
       | 
       | The social web is definetly a poorer experience without pictures,
       | but this is the way our capitalist masters have decided to
       | destroy our commons.
        
       | throwaway277432 wrote:
       | I requested my data back in March 2020 when they were on HN,
       | never got an answer.
       | 
       | They wanted me to upload a photo ID to verify my identity and I
       | was stupid enough to comply.
       | 
       | One commenter said:                 This is a case of 'never
       | click "opt-out" on spam'. Clearview is not to be trusted. One
       | should not go through their process. They are not likely to
       | delete the data, and if they have none, they are likely to create
       | a profile for you.
       | 
       | I should have listened, lesson learned.
        
         | csdvrx wrote:
         | Your comment is extremely point on, yet was dead, so I vouched
         | for it.
         | 
         | I think you perfectly highlight the difficulty of the current
         | opt-out process.
         | 
         | I do not know how it should be done without revealing more
         | information, except maybe by using an attorney that would have
         | the legal power to act in your name while only revealing his
         | information, and not yours.
        
       | shakna wrote:
       | > Clearview AI does not have a place of business in France or the
       | EU, it does not have any customers in France or the EU, and does
       | not undertake any activities that would otherwise mean it is
       | subject to the GDPR.
       | 
       | > To be clear, Clearview AI has not violated any law nor has it
       | interfered with the privacy of Australians. Clearview AI does not
       | do business in Australia, does not have any Australian users.
       | 
       | > The UK ICO Commissioner's assertions are factually and legally
       | incorrect. The company is considering an appeal and further
       | action. Clearview AI provides publicly available information from
       | the internet to law enforcement agencies. To be clear, Clearview
       | AI does not do business in the UK, and does not have any UK
       | customers at this time.
       | 
       | > Clearview AI's technology is not available in Canada and it
       | does not operate in Canada.
       | 
       | This time, and the last three times, Clearview have made the same
       | legal argument. That because they have no physical basis in a
       | country, and because their customers aren't in that country
       | (though several times that has occurred post-breach), they cannot
       | possibly have breached that country's laws.
       | 
       | Despite the privacy laws of every nation being around the
       | _citizen_, not their physical location. All four places have
       | extraterritoriality baked into their privacy laws, and all four
       | have trade agreements with the US in place that could mean that
       | they could ask the US to enforce compliance and make it into a
       | diplomatic issue.
       | 
       | How many more times do their lawyers have to be told the same
       | thing before they try and come up with a new argument?
        
         | hlbjhblbljib wrote:
         | Sure, their laws affect their citizens. Clearview AI isn't a
         | French citizen. French laws don't apply.
         | 
         | How many more times does France need to be told to fuck off
         | before it stops trying to legislate in other countries?
        
           | Youden wrote:
           | I'm curious, do you also think it's wrong when the US applies
           | its own laws worldwide where they concern its citizens (e.g.
           | FATCA, Hague Invasion Act.)?
        
           | prmoustache wrote:
           | What about Julian Assage? US laws shouldn't apply to him yet
           | they want to extradite and trial him for things done outside
           | US juridiction.
        
         | tempnow987 wrote:
         | Wishing something is true doesn't make it true.
         | 
         | How many more times do these bodies need to pass "orders" that
         | don't result in any action before they come up with a new
         | approach?
         | 
         | The US does not have GDPR. Period. Flat out. Full stop. Once
         | you understand that, things will make a lot more sense.
         | 
         | And no, extraterritoriality means absolute zero here. That
         | french citizen traveling in America? Heads up, US Customs does
         | not have to respect to GDPR. Neither does the walmart he shops
         | at. Neither does Amazon if he orders something online.
         | 
         | Claiming they do is weird, that's not how it works.
         | 
         | Before we are snarking about clearview having to come up with
         | new arguments, let's evaluate how well their current arguments
         | are working?
         | 
         | Pretty darn well.
         | 
         | And my guess is the US government, rather than shutting them
         | down, will PAY them to do their stuff, ESPECIALLY on overseas
         | nationals. This is exactly the type of big government "anti
         | terrorism" surveillance style databases govts love.
        
           | curryst wrote:
           | > Heads up, US Customs does not have to respect to GDPR.
           | 
           | Customs is part of a sovereign nation. What customs can and
           | can't do has precious little bearing on what companies can
           | and can't do. It's basically irrelevant.
           | 
           | > Neither does the walmart he shops at. Neither does Amazon
           | if he orders something online.
           | 
           | Sure, if both are OK with not being able to operate in the EU
           | _and_ believe the US government will take the political heat
           | for refusing to enforce the EUs laws.
           | 
           | We also don't strictly _have_ to extradite criminals to other
           | countries. But we usually do.
           | 
           | International law functions nothing like domestic law,
           | because there is no higher power to say "no, you can't do
           | that". If the EU can get the US to punish US companies
           | through diplomacy, force or trades, then that's how things
           | work. If they can't, then it's not how things work.
           | 
           | My guess is that the US won't shield them. It's not critical
           | for US defense, largely redundant with data available from
           | Facebook, and we're already fighting to keep our existing
           | tech giants abroad. Clearview is more useful as a sacrificial
           | pawn than trying to get it crowned a queen.
        
         | kayodelycaon wrote:
         | Trying to apply law to a company in another country using your
         | country's laws is a bit difficult unless your country is the
         | United States.
        
           | ajsnigrutin wrote:
           | I'm guessing EU has enough power to pull such a minor thing
           | through without issues.
           | 
           | Just raising tarrifs on some US made stuff, until this is
           | resolved, will make many larger and stronger companies phone
           | the US administration directly and make a deal.
        
         | dataking wrote:
         | It comes down to jurisdiction. EU can only enforce its GDPR
         | within its member countries.
        
           | pulse7 wrote:
           | ...and within trade agreements with other countries, which
           | are many...
        
             | hlbjhblbljib wrote:
             | I warned people about this garbage when GDPR came out and
             | was shouted down for it. It's the same as the fucking
             | copyright laws we're all burdened with.
        
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       (page generated 2021-12-19 23:01 UTC)