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Re: ACTION-255: Work on financial reporting text as alternative to legal requirements

From: David Wainberg <david@networkadvertising.org>
Date: Tue, 02 Oct 2012 17:41:43 -0400
Message-ID: <506B5F97.2040909@networkadvertising.org>
To: Rigo Wenning <rigo@w3.org>
CC: Nicholas Doty <npdoty@w3.org>, Alan Chapell <achapell@chapellassociates.com>, public-tracking@w3.org, "Dobbs, Brooks" <Brooks.Dobbs@kbmg.com>
Hi Rigo,

I realize this thread has continued well past this, but I wanted to 
provide my own response.

If you believe DNT means no advertising, let's get that out front right 
now. Assuming you believe some advertising should be allowed under DNT, 
however, then I think what we're trying to say is that it follows that 
there must be some record keeping and verification. Current practices 
have evolved over many, many years, not just online, but have also been 
imported from a long history of tv, radio, and print advertising. We 
should not presume that we have the expertise or the authority to alter 
these practices in one swipe of the pen. If we desire to change these 
practices, and we believe that there are preferable alternatives that 
are viable, then it must be a long and incremental process involving all 
of the many stakeholders. I don't think we have that here, so should be 
careful not to overreach and promulgate a standard that no one (or only 
very few) can actually implement.

As to Alan's example, this particular example goes to geo-targeting, 
which is a widespread and necessary practice. There are legal 
restrictions that vary by jurisdiction on advertising tobacco, gambling, 
alcohol, drugs, pharmaceuticals. There are also cultural issues -- 
taboos, sensitivities, etc -- that require advertisers to control 
advertising by geography. Regulators and advertisers will both require 
proof that these limits are being respected. This is not something we 
can change with a W3C standard. We all understand that on the internet 
the location of the user can be very hard to pin down, but as I 
understand it, today the best method available is geo based on IP 
address. So this type of geo-targeting is required, and I think it is 
safe to say that any DNT standard that prohibits it will be DOA.

-David


On 10/1/12 3:49 AM, Rigo Wenning wrote:
> David,
>
> The examples Alan gives have all a certain bias to a target. In
> order to prove that the target has been met, the service must
> collect a certain amount of data. The proposal, as far as I
> understand it, collects data as before for to proof this rather
> group-oriented targeting under the permitted use of financial
> reporting. As all business, at some point in time, has to have some
> accounting, your argument goes circular. We do targeted
> advertisement and we obliged ourselves to do so. Now we have a
> contractual reason to collect that data that we have fulfilled our
> obligation.
>
> Consequently, if a business does not target, they do not need to
> provide financial information for having done so. Where there is no
> service, there ain't no price and no accounting needed.
>
> But I hear you and Alan making a point. It looks like you want to
> target a certain group of people without identifying or
> individualizing them. Kimon can weigh in here, as the EU advertisers
> know how to do that without using personal data. As soon as there is
> no personal data anymore, there is no reason whatsoever for
> restrictions (within the limits of the de-anonymization debate)
>
> So instead of complaining that the industry can't just go on with
> the current model, the industry needs to innovate. I heard that the
> European industry has already done something in this area. You
> should ask Kimon for more information.
>
> Rigo
>
> On Friday 28 September 2012 17:33:26 David Wainberg wrote:
>> I think the point is that there are legitimate reasons outside of
>> statutory or regulatory requirements that this data may need to be
>> retained. And I think those of us coming from the business side
>> have been very willing to work on reasonable retention and use
>> limits that can still accommodate those reasons.
>>
>> There's now been a lot of explanation from people in the online
>> advertising business about the needs to retain certain data for
>> financial reporting reasons. It seems we're all agreed that online
>> advertising should not be prohibited under DNT, so it follows
>> that certain business needs around online advertising must be
>> allowed for. So what harms stem from accommodating these business
>> needs? Can you provide real examples of why the use of such data
>> for financial reporting is a problem? Perhaps if we really
>> understood specific cases you are concerned about, it would help
>> us get on the same page about appropriate limitations.
>>
>> -David
Received on Tuesday, 2 October 2012 21:42:11 UTC

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