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RE: ACTION-110: Write proposal text for what it means to "not track" (ISSUE-119)

From: Shane Wiley <wileys@yahoo-inc.com>
Date: Mon, 13 Feb 2012 08:44:09 -0800
To: Ninja Marnau <nmarnau@datenschutzzentrum.de>, "<public-tracking@w3.org> (public-tracking@w3.org)" <public-tracking@w3.org>, Tom Lowenthal <tom@mozilla.com>
Message-ID: <63294A1959410048A33AEE161379C8023D0CAFE9A7@SP2-EX07VS02.ds.corp.yahoo.com>
Ninja,

I agree with the sentiment (and that this should continue to be a response option) but want to call out that most small publishers do not have the ability to manage data collection at this level as they typically purchase hosting services from a 3rd party provider (often from their domain mgmt vendor).  It will take time for 3rd party providers to update their environments (if they even feel compelled) to allow for a strict "no collection" position so we shouldn't expect that this option will be used very often outside of highly technical, privacy sensitive, small web site publishers.

- Shane

-----Original Message-----
From: Ninja Marnau [mailto:nmarnau@datenschutzzentrum.de] 
Sent: Monday, February 13, 2012 9:10 AM
To: <public-tracking@w3.org> (public-tracking@w3.org); Tom Lowenthal
Subject: ACTION-110: Write proposal text for what it means to "not track" (ISSUE-119)

Here is my proposal for a definition of "absolutely not tracking":

A party may claim that it is not tracking, if it
1) only collects identifying data which is strictly necessary to answer 
the user's HTTP request and to fulfil it's contractual obligation 
towards the user
2) does not send, collect or check for unique identifiers
3) does not correlate the data of a DNT HTTP request with any other data
4) deletes the identifying data as soon as the original purpose is fulfilled


Motivation:
This should be a starting point fo discussing a possible response header 
(This site does not track at all) fo very small websites that do no 
profiling or customisation at all. Currently, these websites have only 
the option to state within the response header that they comply with DNT 
and may use all the exceptions of the standard. This should not 
necessarily indicate that sites which do not adhere to the points above 
are tracking their users.

-Ninja

-- 

Ninja Marnau
mail: NMarnau@datenschutzzentrum.de - http://www.datenschutzzentrum.de
Telefon: +49 431/988-1285, Fax +49 431/988-1223
Unabhaengiges Landeszentrum fuer Datenschutz Schleswig-Holstein
Independent Centre for Privacy Protection Schleswig-Holstein
Received on Monday, 13 February 2012 16:45:10 UTC

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