6m ago
6.24 MB
66 Pages
Last View : 3d ago
Last Download : 3m ago
Upload by : Kaydence Vann

EUROPEAN DIGITAL RIGHTSTargetedOnlineAn industry broken by design and by default

2Targeted Online: An industry broken by design and by defaultDistributed under a Creative CommonsAttribution 4.0 International (CC BY 4.0)license.Booklet written by Laureline Lemoine,Ella Jakubowska, Andreea Belu andDiego Naranjo.Reviewed and edited by SarahChander, Chloé Berthelemy, FrederikeKaltheuner, Jan Penfrat and Gail Rego.This booklet was drafted based onthe work of European Digital Rights’members and other partners, and itwould have been impossible withouttheir thorough revisions, commentsand edits:Access Now EuropeOpen Rights GroupPanoptykon Foundation & Karolina Iwanska,Mozilla Fellow 2019-2020Privacy InternationalNorwegian Consumer CouncilRigo WenningVrijschrift

EDRi/European Digital Rights“We don’t need to owneverything. Using the data wealready have, there is a goodchance that we know you aremoving, changing jobs, havinga baby, getting married, etc.— and we can really helpyou with the queries that youshould have asked but didn’t.We have a value propositionthat nobody else has.”Internal email from Google, 201213

4Targeted Online: An industry broken by design and by default‘Ad tech’ is a catchall term usedto describe theindustry of buyingand selling theattention of internetusers via targetedadvertising orpromoted ntitrust/googles-early-datastrategy-revealed

EDRiIntroduction/European Digital RightsThis handbook is intended forcurious internet users who want tounderstand the internet’s dominantbusiness model, how tech companiesuse (and abuse) data, why someads are eerily creepy and othersso foolishly wrong. This handbookexplains how online advertisingworks, and why a reform of the entireTargeted online ads can be confusing.Sometimes it can seem as ifadvertisers know us intimately. Othertimes, advertising is so wrong as tobecome annoying. What all targetedads have in common is that it is oftenimpossible to understand why we arebeing targeted. How much of your datais being collected and how it is beingshared? In short, why are you reallyseeing this ad?online advertising industry is urgentlyneeded.‘Ad tech’3 is a catch-all term used todescribe the industry of buying andselling the attention of internet usersvia targeted advertising or promotedcontent.In the earlier years of the web, adswere mostly contextual, meaning theywere geared towards the context inWhen the CEO of Netflix, ReedHastings, was asked about hisbusiness’s main competitor, he2replied: “We’re competing withSleep’ (The Guardian, 18 April 2017) https://www.sleep.”2 Likewise, Facebook, or ad-supported platform, is competingAlex Hern, ‘Netflix’s biggest competitor?competitor-sleep-uber-facebookfor your free time. These platforms3do whatever they can to occupy aas ad tech, online advertising industry and onlinemaximum amount of your attention.Throughout this handbook we use terms suchtracking industry to refer to the different actorsfrom the same industry. However, companies mayWhy? Because having your attentionplay different roles and follow different practicesmeans making money.that vary in their impact on privacy, their power overcitizens and their role (or not) as gatekeepers.5

6Targeted Online: An industry broken by design and by defaultwhich they appeared, similar to thepurchases that have occurred in retailways in which printed newspapersshops offline. The narrative, which isor magazines sell advertising spaceoften used to justify the collection ofnext to their articles, opinion pieces orall this personal data is that it helpsfashion shoots.advertising to be more “relevant” and“engaging” to internet users.Contextual ads were typically sold bywebsite owners directly to advertisers.However, the amount of data that isAds on a website about vintage cars,collected, shared and processed tofor instance, would typically appealtarget ads at this level of granularityto vintage car enthusiasts. Placing– as well as the invasiveness ofsuch an ad does not require specificthe techniques used to target adsknowledge about the people who areand promote content – come withviewing the ad. Everyone who visitssignificant risks and harms, forthat website sees the same ads –individuals and societies alike.much like billboards next to a highway,or car ads in a motor magazine.From targeted political ads, tofilter bubbles and radicalisation,Much has changed since then. Thebehavioural advertising andvast majority of ads or promotedpersonalised online spaces morecontent that appear on apps,broadly have a profound impact onwebsites, online news sites, on videosocieties and are thus under scrutinyplatforms or social media are heavilyin this booklet.personalised and targeted.The opacity and unaccountability ofBehavioural advertising or behaviouralthe online advertising industry and thetargeting is an online marketingdisproportionate power held by somepractice used to target individualsof the world’s largest tech companiesbased on large, and growing, troveswithin this industry are at the core ofof data, which can include anythingthe most pressing tech policy issuesfrom a person’s web browsing history, online searches, product searches,someone’s location history and even

EDRi/European Digital RightsIn the following pages we will outlineChapter 3 outlines the societal impactkey problems and possible solutionsof both. Finally, in Chapter 4 we willto some of the biggest concernsoutline our suggestions for systemicaround the techniques used in onlinechange using existing or upcomingadvertising, as well as by the industrylegislation, or enabling alternatives via,as a whole.for example, public funding or othermeasures.Combined, these two are oftenreferred to as “surveillancecapitalism” – an economic systemcentred around the commodificationof personal data with the purpose ofmaking profit.4The first short chapter of the bookletwill look at digital advertising asan industry and explain the role ofplatforms and the lesser known adtech companies, and how the logic ofsurveillance capitalism has become adominant paradigm in many industriesaround the world.The second chapter will explainthe workings of some commontechniques used in targetedadvertising and personalisation.4The term “surveillance capitalism” waspopularised by Harvard professor Shoshana Zuboff.7

8Targeted Online: An industry broken by design and by defaultIntroduction0501. Power dynamics and imbalancesin the digital advertising industry101.1 An offer you cannot refuse –consent and cookies in onlinetargeted advertising1602: When the web watches you back:20how most online advertising works2.1 Step 1: Tracking212.2 Step 2: Profiling232.3 Step 3: Targeting2603. Harms to fundamental rights323.1 Consequences for society333.2 Consequences for people38

EDRi04. The changes we want to see/9European Digital Rights42Step 1: End current exploitativepractices44Step 2: Put humans at the centre46Step 3: Breaking the digital StockholmSyndrome: enable alternativesSources:5256News articles56Blog posts and websites58Reports61Academic articles62Others63

10Targeted Online: An industry broken by design and by default01Power dynamics &imbalances in the digitaladvertising industryBefore we explain how online ads are targeted andwhere all the data that is used in targeting comes from,let us take a step back. First, we will look at the digitaladvertising market, and the different companies thatmake up what can only be described as the dominantbusiness model of the web as we know it today.

EDRi/European Digital RightsThe online advertising ecosystemThe ad tech industry has twois made up of a large number ofmajor entities: the advertiser (thecompanies that each fulfil variousdemand-side) and the publisherfunctions. This is where power(the supply side).imbalances first enter the picture.Most ad tech companies are notMost users of the internet do not – andhousehold names, even though theyoften cannot possibly – understandplay a crucial role in the industryhow content is monetised and howand perform a variety of tasks. Theyads are served to them, simplyserve ads, collect data from appsbecause the techniques used and theand websites, merge and aggregatesheer number of companies involveddata from different devices, combineare so complex.offline and online data, and are alsothe marketplaces where ads areA first step to reducing this to understand the roles of thedifferent actors involved. Ad techData is also enriched using profilingis an umbrella term for advertisingtechniques that place users in varioustechnology and is typically used tocategories, from the seeminglyrefer to the software and tools used byinnocuous (like what brand of caradvertisers, ad agencies, publishers,they like), to sensitive or conjecturedand other companies in the industry.categories (like their personality).11

12Targeted Online: An industry broken by design and by defaultWhat ad tech companies have inThis is either derived from theircommon is that they seek to createbehaviour while on these platforms,a picture of an individual user thator the things they do online wheneveris as comprehensive and completethey are logged into their accountsas possible.(for example, searches and websitesvisited when logged into a GoogleEven though this is the declaredaccount fall into this category).goal, it does not mean that thedata that is collected, aggregatedIt is impossible to overstate theand inferred through profiling isnumber of websites and apps fromnecessarily accurate.which major tech companies are alsoable to collect additional data aboutAnother key – if not the key – group ofthe people who use their services –players in the industry are the largeand about people who do companies. While it is common torefer to them as platforms, companiesA 2018 study has shown that Facebooklike Google, Amazon and Facebooktrackers are embedded in almost halfoperate at nearly all levels of theof all free apps for Android.5advertising industry.Trackers from Google’s parentcompany Alphabet are embedded inFor instance, they allow advertisersnearly 90 percent of all free Androidto purchase and display ads on theirapps, followed by trackers fromapps and websites, within videosTwitter (almost 34 percent), Verizonand social media stories, but theyand its companies (26 percent),also display ads on other apps andMicrosoft (almost 23 percent) andwebsites, and track users on theseAmazon (almost 18 percent).apps and websites.Major tech companies already haveaccess to troves of user data,simply because of the amount ofinformation they can directly collectfrom their users.5Reuben Binns, Ulrik Lyngs, Max Van Kleek, JunZhao, Timothy Libert, Nigel Shadbolt, ‘Third PartyTracking in the Mobile Ecosystem’ (2018)

EDRi/13European Digital RightsThird Party Tracking in the Mobile EcosystemRoot parent% appsSubsidiary% appsCountry88.44Google87.57USGoogle APIs67.51USDoubleClick60.85USGoogle Analytics39.42USGoogle Tag Manager 3USLifestreet .11USAOL0.06USIntowow 0.01US 0.01USBrightroll 0.01US n26.27YahooMillennialmediaOne By AOLGravity Insights

14Targeted Online: An industry broken by design and by defaultRoot parent% appsSubsidiary% appsCountry22.75Microsoft22.11US7.72USAmazon MarketingServices1.73USBing0.12USAlexa SOpera3.20Adcolony3.12USAdmarvel0.09USLesser-known ad tech companies alsoIt also allows businesses that havetrack users on millions of apps andincluded Facebook, Google or Amazonwebsites, but generally speaking, thetrackers on their apps and websitesmost common trackers belong to theto target people who have previouslymajor tech companies.visited their site or app on the platform(depending on the user’s privacyHaving so much access to user datasettings).gives large tech companies manyadvantages. It allows them to targetTypically, advertisers can also uploadpeople at a level of granularity thattheir own data to target people on afew competitors can match.platform like Facebook.

EDRi/European Digital RightsThis can include data that has beenLarge publishers usually have theirpurchased from data brokers orown troves of data, even thoughcollected through subscriptions,they do not match those of largelocality cards or mailing platforms. Smaller blogs andwebsites typically rely on advertisingFinally, tech platforms allownetworks, for instance Google ads, toadvertisers to automatically findautomatically display ads.audiences that match the peoplethey already know. Once an ad runsDepending on the invasiveness of theon a platform, often the targeting isadvertising techniques allowed oncontinuously optimised, so that it istheir sites, this means that smallershown to the people who are mostsites are allowing third parties (fromlikely to engage with it.larger tech companies, to smaller,lesser-known ad tech companies) toAnother group of important playerstrack users on their sites and the online advertising industry arepublishers and content creators whoAs you can see, the online advertisingoften rely on advertising to monetiseindustry is complex and made up oftheir content. Some of them usea large number of companies, manyplatforms like YouTube and TikTokof which are not household names.for this.All of this results in a system that isincredibly opaque.Most publishers and content creatorsalso depend heavily on social mediaAs a result, merely using an app orplatforms to get views and reachvisiting a websites can mean thataudiences outside of their own appsuser data is shared with hundreds ofand homepages. Publishers like newscompanies.sites and smaller blogs display ads tosupport their business – positioningads can be done at various levels ofgranularity.15

16Targeted Online: An industry broken by design and by default1.1 An offer you cannot refuse – consent and cookiesin online targeted advertisingWhether you are visiting a website,services without accepting theirusing an app on your phone or signingprivacy policies that include intensiveinto a social media account, privacytracking. Some websites placeand data protection laws in thetracking cookies even after usersEuropean Union mandate that users’clearly object.8consent is needed to process personaldata and install tracking technologiesMost cookie banners do not mentionlike cookies on devices. But throughthe specific purpose of grabbing andnudges and dark patterns,6 “consent”using users’ personal information oris often falsely extracted from userswho can access it.who do not have a real option toreject the “deal” that publishers andLikewise, privacy policies areplatforms offer.dauntingly long and written in legalese,yet do not go into the detail needed toMost cookie banners, for instance, doactually understand the purposes fornot clearly offer users the option towhich user data is being used.refuse, or will nudge users towardsconsenting (it often takes moreThe consent a user “gives” whenthan three clicks to refuse cookiesagreeing to the privacy policies orwhen only one is enough to acceptterms and conditions of apps andthem).7 Similarly, it is not possibleonline platforms is often equallyto use Google and Facebook’sproblematic.

EDRi/European Digital Rights“Some websitesplace trackingcookies evenafter usersclearly object.”Chapter 01 - Power dynamics & imbalancesin the digital adversiting industry17

18Targeted Online: An industry broken by design and by defaultThis is either because users do notfully understand how data is usedand collected, or because they do nothave the option of using the serviceswithout giving consent. This is notvalid under current European dataprotection laws.9The incorrect implementation of dataprotection and privacy legislation hasled to a plague of pop-ups on websites6that “ask” visitors to “accept” cookies,interface design meant to manipulate users withbecause otherwise they are preventedDark patterns are techniques and features ofthe aim of nudging users towards privacy intrusiveoptions. See the report on dark patterns by thefrom using the site’s services. EDRiNorwegian Consumer Council:has long advocated against xistence of these “cookie walls”.7Christine Utz, Martin Degeling, Sascha Fahl,Florian Schaub, and Thorsten Holz, ‘(Un)informedThe official group of data regulators inEurope, the European Data ProtectionBoard (EDPB), also confirmed that this“does not constitute valid consent”.11Consent: Studying GDPR Consent Notices in theField’ (ACM SIGSAC Conference on Computer andCommunications Security, 2019)., ‘Say “NO” to cookies – yet see your privacycrumble?’ (NOYB, 10 December 2019).Consent is one of the key legal basesthat allow data processors to yourprivacy-crumblecollect and process personal data,9and it is the main legal basis for theonline tracking here: of “sensitive data” suchSee our one-pager on consent in the context ofe-privacy-onepager consent.pdfas actual or inferred data about race,10political opinion, religious lhealth, sex life, sexual orientation,11and genetic and biometric data.Guidelines 05/2020 on consent under RegulationEDRi, ‘Tear Down the Tracking Wall’ (2017)European Data Protection Board (EDPB),2016/679 (2020), p.12. file1/edpb guidelines 202005 consent en.pdf

EDRi/19European Digital RightsYet, the opacity and complexity ofThe business practices of dominantthe online advertising system makesonline platforms and the ad techit difficult for users to enjoy theirindustry are complex and opaque byfundamental right to data protectiondesign, because the industry benefitsand privacy. Users cannot identify allfrom the fact that most peoplethe companies that will receive anddon’t fully understand and cannotprocess personal data, which makesmeaningfully control how their data isinformed consent impossible.used and collected.However, individuals are shownThe lack of strong enforcement of“options” to accept or deny (in someexisting laws and a lack of interestcases granularly, in some cases not)in (if not deliberate blocking of)tracking of their behaviour whichadditional regulatory initiativeslends a feeling of powerlessness andcreates the ideal conditions for“consent fatigue” (or rather “cookieharmful and illegal activities.banner fatigue”).12The industry is seldom held toaccount. This affects both individuals12and society as a whole.(Un)informed Consent: Studying GDPRConsent Notices in the Field. of a cookie banner that gives no real choiceAccept cookies from Instagram on this browser?We use cookies to help personalize content, serve relavant ads andprovide a safer experience. Learn more about cookie uses and controls inour Cookie Policy. You can review your controls at any time.AcceptLearn More.

20Targeted Online: An industry broken by design and by default02When the webwatches you back:how most onlineadvertising worksBefore diving further into the different roles andfunctions of each actor involved, let us explore whatyou do and don’t see on your screen when you visit awebsite, and what techniques are used to collect andprocess data about you to deliver targeted ads.

EDRi/European Digital Rights2.1 TrackingTo target users and predict behaviour with detail, ad tech companies and techplatforms want to know as much about each individual user as possible.What are tracking tools and howThis can mean knowing the screendo they work?size of a particular user’s device andWe have already discussed above howthe software installed on it (which canwebsites and apps contain trackersin some cases be enough to identifythat collect data about users.individuals).These tracking tools (which includeIt can also mean a user’s physicalcookies, beacons and browserlocation, the apps installed on theirfingerprinting among others) aredevice, browser settings, IP addresses,used to collect and, more importantly,their topics of interest (politics,combine data about people fromhobbies, sexual preferences, cultureacross the web, different apps andetc), how much time they spend oneven different devices. These arethe website or platforms, the way theythen used to make guesses aboutmove their mouse, who they hang outindividuals’ interests and preferences.with offline, the state of their mentalTrackers constantly observe usershealth and much more.13and their behaviour online.21

22Targeted Online: An industry broken by design and by defaultWhat is more, websites andOther techniques, like beacons, canapp developers integrate thosetrack everything a user does on atechnologies from “third parties” inweb page including what they type ortheir website or mobile applicationswhere their mouse moves. 15source code, often for convenienceand to increase commercial profit.Since online tracking has becomeubiquitous, data about a large portionThird party tracking is particularlyof users’ online experience (searches,problematic, because people aren’tlikes, lists, subscriptions, time spentaware of it and have little control overon each piece of content, etc.) ishow their interactions with an app orused to profile them for advertisinga website are shared with those thirdpurposes. This is then used to directparties. In particular, third partiesmore of the same content that theywhose code is embedded in a largemay be interested in, according to thenumber of different apps and websitesdata users have handed over and datareceive data about users that can bethat has been inferred. This createslinked and combined into an incrediblya feedback loop of micro-targeteddetailed profile.content and ads.This results in companies havingSo what? Next, we’ll look at why thisaccess to a large share of individualis harmful.14users’ browsing history.While users can delete some of thesetrackers, such as cookies, from theirbrowser, other tracking tools havebeen developed that are less easily13controlled. Fingerprinting, for example,impacts fundamental rights at:uses information about a user’s owser, or IP address to uniquely14identify and recognise their devicecompany for all of my data and here’s what I found’without the need to place a cookie.Find more information about how trackingPrivacy International, ‘I asked an online tracking(7 November 2018): -what-i-found

EDRi/European Digital Rights2.2 ProfilingWe know that content on a website can change, according to who is visiting.Social media feeds and recommendations look radically different, not just basedon who individuals follow. The same is true for the ads that we see.What makes a user unique forUnique identifiers16 such as deviceadvertisers?or browser fingerprints17 or a mobileThe data and information gatheredphone’s unique Advertising ID makethrough tracking can end up inprofiling possible and further turn adetailed user profiles. For example,user’s profile into a unique personwhen a user is using their phone toidentifier. The techniques used to dovisit a website online, that websitethat are far from perfect, for instanceautomatically places cookies andwhen several people share the sameembeds beacons and/or otherdevice, but they are good enough totracking software.provide deep insights into people’smost intimate personal lives.Trackers don’t necessarily knowan individual’s legal name, but theyInferred data: guessing stuff aboutare able to uniquely identify a user’susers and enriching datadevice or browser, and merge dataThe more data companies collectthat has been collected on differentabout individual users, the morebrowsers and on different devicesadditional insights they can infer andinto a single profile.derive from that information.23

24Targeted Online: An industry broken by design and by defaultInferred data means ad techcompanies can know things aboutpeople that those people neveractually shared with anybody.That can range from gender, age orgeneral interests to highly intimateinformation such as predicted sexualorientation, psychometric profile,IQ level, family situation, addictions,18illnesses or the menstrual cycle.Often apps will have access to evenmore sensitive information such, ‘Online Tracking and BehaviouralProfiling’: 6For more details on the different types oftrackers see: Bennett Cyphers, ‘Behind the OneWay Mirror: A Deep Dive Into the Technology oflocation data, personal calendars,Corporate Surveillance’ (2 December 2019):the camera, personal contact lists more.mirror17A study at the Universities ofCambridge and Stanford found that,by analysing clicks on Facebook “like”buttons, it was possible to guess anFor more information on browser fingerprinting,see: inting18Privacy International, ‘No Body’s Business ButMine: How Menstruation Apps Are Sharing YourData’ (2019):’s personality better thanlong-read/3196/no-bodys-business-mine-how-a work colleague (based on just 10menstruations-apps-are-sharing-your-dataclicks), better than a parent or sibling19(based on 150 clicks) and betterYou’ve given the security services a key to yourthan a spouse (based on 300 clicks).soul’ (The Guardian, 13 January 2015): https://www.Researchers indicated that Facebookhas records of 100 billion “likes”.19Andrew Brown, ‘Ever liked a film on file-facebook-research20The Facebook-Cambridge Analytica scandalconcerned the obtaining of the personal data ofmillions of Facebook users without their consentby British consulting firm Cambridge Analytica,predominantly to be used for influencing theoutcome of political elections.

EDRi/European Digital Rights“By analysing clickson Facebook “like”buttons, it was possibleto guess an individual’spersonality betterthan a work colleague,better than a parent orsibling and better thana spouse.”Chapter 02 - When the web watchesyou back: how most of online advertising works25

26Targeted Online: An industry broken by design and by default2.3 TargetingThere are a variety of ways in which online ads can be targeted.Broadly speaking, these fall into four categories.Targeting based on categoriesas the ways in which users haveprovided by online platformsinteracted with content.The easiest way to target ads isto buy advertising space on socialDepending on the privacy settingsmedia platforms or through their adchosen by users, ads on platformsnetworks. These allow advertisers tocan also be targeted based on datatarget ads based on relatively broadthat has been collected outside thecategories, demographic information,platform, meaning ads on social mediasuch as age, location, and interests.platforms can be targeted based onthe websites a user has visited and theThese options suggest that targetingapps installed on their relatively broad, but in reality, thesecategories are based on all the dataUntil the Facebook-Cambridgethat tech platforms have aggregated.Analytica scandal20 caused someplatforms to change their practices,This includes users’ declared interests,advertisers could also target peoplethe content they have shared, ason platforms based on data providedwell as who they are connected with,by data brokers and credit referencingbut also a platform’s own data, suchagencies.

EDRi/European Digital RightsTargeting based on custom dataadvertisers to automatically findAdvertisers can also target usersaudiences that “look” similar tobased on the data they have collectedusers they have already identifieddirectly, for instance throughand targeted.trackers on their websites, apps,or online shops, or through emailReal time bidding (RTB)lists, shop data, location data andRTB is an automated auction processphone numbers they have eitherthat enables advertisers to target verycollected themselves or purchasedspecific groups of people on differentelsewhere. That includes personalwebsites, videos and apps withoutinformation collected through so-having to negotiate prices directly.called loyalty cards, email newslettersfor customers, and other types ofImagine auctions, stock exchange,promotional activity.traders, big screens, noise, graphs,percentages. RTB systems similarlyAutomated targetingfacilitate the auction of advertisingMost targeted ads are continuouslyspace to the highest biddingoptimised for engagement, meaningadvertiser. This technique is oftenthat no matter how an advertiser hasused on websites and by publishers.chosen to target an ad, the ad deliveryPlatforms like Facebook also use adsystem constantly tests which kindsauctions to determine the best adof users are most likely to click onto show to a person at a given pointan time.Whenever a user clicks on an ad,How does it work? A website rents itssimilar users are more likely to beadvertising space to one (or many) adshown the same ad.exchanges. The moment a user visitsthe website, during the millisecondsAdvertisers can also leave thein which it loads, the ad exchangetargeting of ads entirely to thesecreates a “bid request” that in

apps and websites, within videos and social media stories, but they also display ads on other apps and websites, and track users on these apps and websites. Major tech companies already have access to troves of user data, simply because of the amount of information they can directly collect from their users. This is either derived from their

Related Documents:

Rights and gendeR in Uganda · 3 Rights & Human Rights Background Rights The law is based on the notion of rights. Community rights workers need to understand what rights are, where rights come from, and their own role in protecting and promoting rights. Community rights worker

European Digital Rights (EDRi) is a network of 36 civil and human rights organisations from 21 European countries. Our goal is to promote, protect and uphold fundamental . access to works in public libraries, access for people with disabilities, use of the works in schools, etc. These exceptions are necessary to uphold the right to .

The Court of Justice of the European Union has, of course, gone to great lengths to ensure that fundamental rights are fully respected in the scope of applying European Union law. It has done so, however, on the basis of the European Union Charter of Fundamental Rights and a range of fundamental rights included in the general

Part 2 - 22 Basic Appraisal Principles Appraisal Institute / American Society of Farm Managers and Rural Appraisers / American Society of Appraisers II. Fundamental Land Rights Certain rights accompany land such as air rights, water rights, mineral rights, and oil and gas rights. These land rights together with all the other rights in real .

A Human Rights Perspective by David Shiman Raising Children with Roots, Rights and Responsibilities: Celebrating the UN Convention on the Rights of the Child by Lori DuPont, Joanne Foley, and Annette Gagliardi Lesbian, Gay, Bisexual, and Transgender Rights: A Human Rights Perspective by David M. Donahue The Human Rights Education Handbook:

Digital inclusion is defined in various ways and is often used interchangeably with terms such as digital skills, digital participation, digital competence, digital capability, digital engagement and digital literacy (Gann, 2019a). In their guide to digital inclusion for health and social care, NHS Digital (2019) describe digital

Rosamond Ben. (2000) Theories of European Integration. The European Union Series. Palgrave; Pierson P. The Path to European Integration: A Historical Institutional Analysis (1996). The European Union. Readings on the Theory and Practice of European Integration, Nelsen B.F. and Alexander C – G. Stubb (eds.), Palgrave, 1998; Marks G., Hooge L., Blank K. European Integration from .

- common aspects of European cultures, heritage and history as well as European integration and current European themes European artists and transnational cooperation with operators from different countries, including other ECOCs. A strategy to attract the interest of a broad European public. Culture European dimension