W3C home > Mailing lists > Public > public-tracking@w3.org > February 2012

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

From: Lauren Gelman <gelman@blurryedge.com>
Date: Mon, 6 Feb 2012 21:17:58 -0800
Cc: David Singer <singer@apple.com>, John Simpson <john@consumerwatchdog.org>, "public-tracking@w3.org (public-tracking@w3.org)" <public-tracking@w3.org>
Message-Id: <F554E7FD-8CC8-4CB4-BEC1-1FDBBFDD9171@blurryedge.com>
To: Roy T. Fielding <fielding@gbiv.com>

Can you give me an example of a 3rd party site that needs referer info for billing/audit/fraud?  

Referrer data is used to tell me where a user is coming from.  If I'm Macys and a DNT:1 user arrives on my site because they clicked on an ad on NYT.com then I am a first party.  I get to know referrer info and can credit NYT with the click.

What is the use case where I'm a third party and I need to know where a user is coming from.  If I'm a Macys ad just sitting on NYT, and a DNT:1 user visits the site, why would referrer info [where the person was prior to arriving at NYT] be passed to me?  If I am an ad server, why do I need that info to do an audit?  They can't sell an ad into that spot based on where the user came from for a DNT:1 user, right?

> We are already limiting data collection to the site operator
> and data processors contracted by that site, but "site" in
> that case includes third-party services.

I am not sure what this means.  I thought "the site" and "third party services" were distinct entities (however they end up being defined).


On Feb 2, 2012, at 7:16 PM, Roy T. Fielding wrote:

> On Feb 2, 2012, at 4:24 PM, Lauren Gelman wrote:
> 
>> Can you limit the sites who would be required to keep it for audit purposes to only first parties or their service providers?
> 
> I don't think we can anticipate what sites are required to
> keep data for auditing purposes, especially since many of
> the third-party sites are auditors.  Why does it matter,
> assuming they aren't allowed to share the data or use it
> operationally (to target or modify responses)?
> 
> I think it is more effective to place limits on retention
> in user-identifiable form, since auditors generally do not
> want to retain the raw data anyway unless it has been detected
> as likely fraudulent.  Another possibility is to only
> allow pair-wise retention of referral data, meaning that any
> user-identifiable data in the record is hashed with something
> unique to the referring site, or stored separately per site,
> such that it is difficult to correlate them.  And note that
> this would only be for sites that *need* to retain this
> information for billing/auditing/fraud control -- it is not
> a general exception.
> 
> We are already limiting data collection to the site operator
> and data processors contracted by that site, but "site" in
> that case includes third-party services.  I am assuming that
> companies like
> 
>  http://www.linkshare.com/
> 
> are at least capable of siloing data per contract (destination site).
> I do not know if they do so already.  I doubt that a first party
> would ever willingly share referral data with anyone else, aside
> from aggregate forms (like in marketing reports).
> 
> ....Roy
> 

Lauren Gelman
BlurryEdge Strategies
415-627-8512
gelman@blurryedge.com
http://blurryedge.com
Received on Wednesday, 8 February 2012 19:05:52 UTC

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