Re: Do Not Track EFF/Mozilla/Stanford Compromise Proposal re market research

Dear Jonathan
 
Many thanks for your draft proposal.
 
Firstly we are pleased that the W3C standard will apply an ³out-of-band²
exception for online panel research firms that obtain panel members¹
explicit consent to track their exposure to ads and other online content
across the web, which will permit the overriding of a user¹s DNT preference.
It is key for online research that when a panel research firm receives a DNT
signal from a panel member, the firm would be able to continue tracking the
user by claiming an out-of-band exception.
  
The application of research codes of conduct and practice has always placed
great emphasis on confidentiality and protecting the identity of the
respondent or data subject. The essential element of processing statistical
research data is that it may inform wider decisions about policy but not
inform decisions about a specific individual or have a direct effect on the
data subject. This is recognized by the FTC and in both the current EU Data
Protection Directive and the proposed DP Regulation.
 
Whilst we very much appreciate the progress being made by this group, we are
concerned that this standard, which aims to define the technical obligations
of a website that receives a DNT message, may be captured by a debate about
the compliance mechanism for EU legislation, in spite of the fact that the
legislative requirements between the EU 27 member states themselves, are
still being clarified.
 
Following the W3C meeting in Washington, and the meeting in Seattle which
few EU stakeholders can participate in because of lack of resources,
distance and the time difference, we very much hope that, as was previously
proposed, the W3C group will also have a meeting in Brussels which more EU
stakeholders can attend and engage in the discussions.


I'm sorry not to be able to join you in Seattle
 
Best 
 
Kathy Joe.
 
From:  Jonathan Mayer <jmayer@stanford.edu>
Date:  Tuesday, June 12, 2012 9:57 PM
To:  Kathy Joe <K.Joe@esomar.org>
Subject:  Do Not Track EFF/Mozilla/Stanford Compromise Proposal

 
 Kathy, 

Last we chatted, you wanted to make sure Do Not Track accommodates user
surveys by first parties and white-label third-party providers.  In drafting
our compromise proposal, we attempted to account for the market research
perspective by placing essentially no requirements on first parties and
establishing an outsourcing exception.  The proposal and discussion are on
the public-tracking@w3.org list, under the "Towards a Grand Compromise"
subject: 
http://lists.w3.org/Archives/Public/public-tracking/2012Jun/thread.html.
Thoughts and comments very welcome.

Best,
Jonathan

 





  

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