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Re: [Issue-5] [Action-77] Defining Tunnel-Vision 'Do Not (Cross-Site) Track'

From: John Simpson <john@consumerwatchdog.org>
Date: Wed, 1 Feb 2012 13:37:42 -0800
Message-Id: <4685ADED-0002-42D6-B163-BB9A282473B1@consumerwatchdog.org>
Cc: "public-tracking@w3.org (public-tracking@w3.org)" <public-tracking@w3.org>
To: David Singer <singer@apple.com>
How does this approach work in light of the way referrers work?


On Jan 29, 2012, at 8:15 AM, David Singer wrote:

> This is a revision of my previous email, and a response to Action-77, which is one of 6 (?) actions related to Issue-5.  Please ask questions as needed to clarify, and I will write a composite revised definition, so we can close Action-77, and (once that's been done for the other formulations) Issue-5.
> 
> This is an alternative to restricting tracking via a 1st/3rd party distinction. I want to emphasize, I am doing this to explore and learn, not to 'promote' any particular direction.  I hope people find it helpful.
> 
> (All these definitions etc. rely on being able to define "site" or "party", by the way.  I don't see how to escape that, as many have pointed out, since it's within a 'party' that information flows, and so on.)
> 
> 
> RULE
> 
> Informally, we allow sites only to record what they do and learn *directly* about the interaction between themselves and the user. 
> 
> The formal rule is this:
> 
> When DNT is on (1):
> Data records that both identify or could identify, a single USER, and also identify, or could identify, a single SITE (that is part of a Party),
> * MUST identify or be capable of identifying no other Party, or site that is part of any other Party;
> * MUST be derived only from transactions directly between the identified Party and the user, possibly combined with publicly available data, 
> * MUST be available/accessible only to/by the identified Party,
> * MUST NOT contain user-specific non-public information derived or passed, directly or indirectly, from any other Party, 
> 
> If the data is held by another party on behalf of the identified party, that holding party MUST have no rights to use the data.
> 
> Records derived when DNT is on (1), MUST be held separately from other data derived when DNT is not on (1).
> 
> EXCEPTIONS
> 
> not needed:
> 
> Outsourcing exception: not needed, it's part of the rule in the first place.
> 1st-party exception: not needed: all sites/parties are allowed to remember the user's interactions with them.
> Unidentifiable data exception: not needed, as the definition here only concerns user-identifiable data in the first place (which can probably be true for all rule sets)
> Operational exceptions:
>  frequency capping, story-boarding: not needed; the ad site is permitted to remember what IT served YOU, just not a lot of why (which 1st party you were on, etc.)
>  financial logging: separate un-identified records can be kept on the number of impressions on a 1st-party site (why is this not true for all proposals?)
>  3rd party auditing: again, is it necessary to keep a record that identifies a specific user?
> 
> potentially needed:
> 
> Operational exceptions:
>  security/fraud: an exception may be needed here, especially if cross-site fraud is to be detected
>  research/market-analytics: we don't have a current formulation, and the title is broad enough to allow almost anything, so I can't tell
>  product improvement: this is an issue, again with a serious risk of slippery slope
>  debugging: yes, an exception may be needed for debugging
> Legal exception: tracking to the extent required by law
> 
> Comments on TUNNEL-VISION 
> 
> If a user runs sometimes with DNT:0 and sometimes DNT:1, they will end up with two records at sites, one with a lot of other-site data, and the second record with tunnel-vision.  Correlation by the site would enable merging these; this is the weakest aspect of this strawman, IMHO.  Under the alternative 'cross-site' formulation, I think each site would keep N+1 records (1 for when DNT is off, and N for the number of 1st party sites 'seen' by this 3rd party for this user).
> 
> Frequency capping and storyboarding by advertisers are now permitted; you ARE allowed to remember what ad you showed this (anonymous) user, since that was *your* transaction.  You're limited in remembering only site-generic 'why' -- you cannot remember 'they visited Sears and so I showed a dishwasher advert'.  
> 
> If the user starts interacting with *you*, you can remember that also; we don't need language to make this an exception, or 'promotion' from 3rd to 1st party.
> 
> Redirection services can remember basically only that the user was active on the web, since everything else they know (the original URL, the re-direct) either identify or could be used to identify another site.
> 
> The attraction of this rule is that many fewer exceptions are needed.  The downside of this formulation is that it relies on sites not to re-correlate the records, though there is still a lot of data that cannot be recorded.
> 
> David Singer
> Multimedia and Software Standards, Apple Inc.
> 
> 

----------
John M. Simpson
Consumer Advocate
Consumer Watchdog
1750 Ocean Park Blvd. ,Suite 200
Santa Monica, CA,90405
Tel: 310-392-7041
Cell: 310-292-1902
www.ConsumerWatchdog.org
john@consumerwatchdog.org
Received on Wednesday, 1 February 2012 21:37:57 UTC

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