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RE: possible 'transient un-analyzed data exception'?

From: Shane Wiley <wileys@yahoo-inc.com>
Date: Wed, 22 Feb 2012 17:42:40 -0800
To: David Singer <singer@apple.com>, "public-tracking@w3.org (public-tracking@w3.org)" <public-tracking@w3.org>
Message-ID: <63294A1959410048A33AEE161379C8023D0CAFF88F@SP2-EX07VS02.ds.corp.yahoo.com>
David,

While some of these are logically reasonable they do not map to real-world data processes.  Have you engaged with anyone on the Apple iAd team to get their thoughts here?

* require that the DNT status be kept with every record (i.e. under what DNT setting was it collected)
[Agreed - or if records are separately contained or managed as a DNT data set this would achieve the same goal.]

* require that the raw data and all copies (if any) of it be erased after the extraction is run
[Depends if that raw data is also used for other permitted operational purposes outside of "aggregate and anonymous" outcomes.  If not, then deletion or anonymization is reasonable.]

* require that the extraction be done in a reasonable time (less than 8 days?)
[As I've stated many times, it isn't appropriate to setup arbitrary timeframes as there are too many business models to possibly review to ensure the timeframe is appropriate.  Again, we should use a "minimization standard" here and force companies to defend why their raw data retention period is necessary for whatever the stated period.]

* that though the raw data contains data not permitted under DNT, the extracted data must comply (though exceptions may be claimed, as usual, alas)
[I've not seen a prohibition on specific data elements within data collection yet - what are you envisioning here?]

* recommend that copies/backups etc. not be made, as that merely makes it harder to ensure deletion has happened
[For some areas this may be acceptable, but for financial records or legal compliance requirements, backups will definitely need to be made.]


-----Original Message-----
From: David Singer [mailto:singer@apple.com] 
Sent: Wednesday, February 22, 2012 5:26 PM
To: public-tracking@w3.org (public-tracking@w3.org)
Subject: possible 'transient un-analyzed data exception'?

Do we need a "transient data" exception?  That basically, raw log data can be kept for a limited period before the 'legitimate' (permitted) long-term data is extracted, and the raw data then discarded?

I would envisage such an exception would:

* require that the DNT status be kept with every record (i.e. under what DNT setting was it collected)
* require that the raw data and all copies (if any) of it be erased after the extraction is run
* require that the extraction be done in a reasonable time (less than 8 days?)
* that though the raw data contains data not permitted under DNT, the extracted data must comply (though exceptions may be claimed, as usual, alas)
* recommend that copies/backups etc. not be made, as that merely makes it harder to ensure deletion has happened


On Feb 9, 2012, at 13:12 , Shane Wiley wrote:

> David,
> 
> You hit the core issue straight away - raw data retention and dissemination to service operational purpose exceptions.  While the end-points I described below do result in aggregate and anonymous outcomes, we need to retain the raw data to build those results (different intervals: real-time, daily, weekly, monthly, quarterly, annual).  In some cases we compound aggregation (build annual aggregations from quarterly aggregations) where we can without compromising the data but there are reporting uses where the raw data is retained for a more accurate result (financial reporting, for example).
> 
> - Shane
> 

David Singer
Multimedia and Software Standards, Apple Inc.
Received on Thursday, 23 February 2012 01:43:29 UTC

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