Re: Agenda: Global considerations F2F meeting 11-12 Berlin

Vinay, 

On Wednesday 06 March 2013 06:57:36 Vinay Goel wrote:
> I don't think your statement "So everybody has to behave like a 3rd
> party in DNT" is how it will play out.

If you find a legal way of having first/third party distinction in the 
EU, I'd be interested in your argumentation. If we specify knowingly in 
contradictions to legal imperatives, IMHO we will not achieve what my 
goal here is.
> 
> I don't expect most global companies to modify its web servers,
> analytics practices, and onsite optimization services so that it will
> treat itself as a first party on www.company.com, www.company.ch,
> etc., but treat itself as a third party on www.company.uk.  It will
> not be easy for a company to programmatically treat itself as a 3rd
> party for its EU websites; especially when the site is
> www.company.com/uk.  For global companies that set global policies
> and need consistent systems/approaches/privacy policies across the
> globe, I expect them to treat the DNT signal the same regardless of
> market; and those global companies will do whatever they need to do
> outside of DNT for legal compliance.  

This is interesting. I did not think a company would treat parts of 
itself as a third party. If the company is claiming "safe harbor" we are 
back to the question whether first/third party distinction is legally 
possible in Europe and as "safe harbour". 
> 
> I can't speak for other global companies, but I can speak for how
> Adobe is considering its global compliance obligations.

If Adobe is thinking that it isn't bound by EU compliance or safe 
harbor, Adobe will not benefit from global considerations, as this is 
trying to make EU compliance very easy for the Web - part of data 
processing. 
> 
> I still think a fair discussion at the Global Considerations workshop
> is how companies actually plan to implement this globally.

This is my goal. I want to find a viable easy solution. My benchmark is 
to achieve endorsement by the authorities with something that good faith 
companies consider (rather easily) implementable. 

Of course we will first have to discuss if other people share that goal 
or what the goal should be. I imagined the first session to do this. My 
plan was to present something and have people reflect on it and make 
their own suggestions. (mainly 13:30 - 15:00 on Monday)

What do you think?

 --Rigo

Received on Wednesday, 6 March 2013 16:34:38 UTC