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Re: Examples of successful opt-in implementations

From: Dobbs, Brooks <brooks.dobbs@kbmg.com>
Date: Wed, 13 Jun 2012 17:18:28 -0500
To: <ifette@google.com>, "public-tracking@w3.org Group WG" <public-tracking@w3.org>
Message-ID: <CBFE7BE4.187B%brooks.dobbs@kbmg.com>
Ian,

I would say that I have seen some sites that are arguably one step closer,
though not truly opt-in.

If you look at http://www.nectar.com/ you’ll see a similar disclosure to
that on the FT, but with a Cookie Consent link that takes you to a cookie
inventory with a place for the status of each cookie and the purpose of each
cookie.  Now while they get points for making a greater effort, I would say
that the final result seems fairly problematic as: 1) though the site lists
52 cookie issuers, my personal packet sniff showed both that they included
cookies that I didn’t come across (no problem - I didn’t actually read every
page) AND missed cookies that I did come across (problem) and 2) a number of
the 52 cookies issuers where listed as having “undisclosed” purposes with a
specific inability to offer choice.

So even if they took the particularly consumer annoying step of making the
user go through 52 pop-up, opt-in screens, they still would not be opt-in
compliant.

Not trying to pick on them, just pointing out that, as you seem to suggest,
we aren’t seeing a lot of (any?) real opt-in compliant websites in the wild,
and that the closer they get, the more troubles they seem to make for
themselves.   

-Brooks


On 6/13/12 3:26 PM, "Ian Fette   (イアンフェッティ)" <ifette@google.com>
wrote:

> Out of curiosity, on today's call two examples of "successful" opt-in
> implementations were given.
> 
> 1. was the financial times - http://www.ft.com/home/us. This shows a popup
> saying the following: "FT Cookie Policy
> We have published a new cookie policy. It explains what cookies are and how we
> use them on our site. To learn more about cookies and their benefits, please
> view our cookie policy.
> 
> If you'd like to disable cookies on this device, please view our information
> pages on 'How to manage cookies'. Please be aware that parts of the site will
> not function correctly if you disable cookies.
> 
> By closing this message, you consent to our use of cookies on this device in
> accordance with our cookie policy unless you have disabled them."
> 
> Before you even accept anything, I counted 40 cookies being set, including 18
> from Financial Times. FT itself used HTML5 local storage in addition to the 18
> cookies.
> 
> 2. The other was the UK CIO's site -- this seems to be down at the moment.
> www.cio.gov.uk <http://www.cio.gov.uk>  redirects to some archive page. Taking
> another government site as an example, I see 7 cookies including GUIDs
> from http://www.cabinetoffice.gov.uk/content/privacy-policy
> 
> So, I'd like to re-raise my question of whether anyone has actually
> successfully managed to deploy an opt-in compliant website in the wild...
> 
> -Ian
> 

-- 

Brooks Dobbs, CIPP | Chief Privacy Officer | KBM Group | Part of the
Wunderman Network
(Tel) 678 580 2683 | (Mob) 678 492 1662 | kbmg.com
brooks.dobbs@kbmg.com



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Received on Wednesday, 13 June 2012 21:19:02 UTC

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