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Re: ISSUE-45 ACTION-246 Clarified proposal on compliance statements

From: David Wainberg <david@networkadvertising.org>
Date: Mon, 05 Nov 2012 13:33:11 -0500
Message-ID: <50980667.8010901@networkadvertising.org>
To: John Simpson <john@consumerwatchdog.org>
CC: Lauren Gelman <gelman@blurryedge.com>, Joseph Lorenzo Hall <joe@cdt.org>, Shane Wiley <wileys@yahoo-inc.com>, "public-tracking@w3.org" <public-tracking@w3.org>
     Hi John,

On 10/31/12 5:53 PM, John Simpson wrote:
>
> As I read your proposal, it would allow as many "tokens" as there were 
> DNT compliance specifications, isn't that correct?  I think you've 
> suggested that the market would serve to limit the number to 
> manageable amount, but in theory, as I understand it,  there could be 
> as many as people dreamed up.
>
Yes, hypothetically, but it's a red herring.

For bad actors, it doesn't matter. Even a monolithic DNT spec will not 
stop them from doing bad things. They will either ignore it entirely, or 
they will say they adhere to it and then won't. In the unlikely case a 
bad actor does choose to "dream up" a token -- though I don't know why 
they would -- it will be visible in their well known location, so they 
can be called out for it.

Since there's nothing we can do about the bad actors, the only remaining 
issue is how good actors will behave.

Good actors will not use strange, made-up tokens. Good actors will have 
little choice but to employ a reasonable, widely accepted DNT response. 
It's too much risk for them to do otherwise. Even aside from the risk, 
the market will push them to it. Advertisers and other partners are 
sensitive about privacy issues, so will mandate it in contracts.

But you do not agree with me that these dynamics will be sufficient. 
Your concern is related to the extent of variation. You worry that 
companies or groups of companies -- even good actors, and even in good 
faith-- may proffer unreasonable versions of DNT.

If that's right, let's discuss. I think we can overcome these concerns, 
and get the benefit of the flexibility this proposal offers. But let's 
not dismiss it based on a red herring.

-David
Received on Monday, 5 November 2012 18:33:41 UTC

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