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Re: Proposed Text for Local Law and Public Purpose

From: Ed Felten <ed@felten.com>
Date: Tue, 23 Oct 2012 21:13:03 -0400
Message-ID: <CANZBoGgdMNvph1YsirhYV_Q5ke_Sw2vJc+pzogOnUD+cKshgfg@mail.gmail.com>
To: Chris Mejia <chris.mejia@iab.net>
Cc: "public-tracking@w3.org" <public-tracking@w3.org>
So your position is that the MRC documents do require companies to collect
linkable data about every consumer?

On Tue, Oct 23, 2012 at 6:24 PM, Chris Mejia <chris.mejia@iab.net> wrote:

>   Ed, I provided the original citation and the link to the MRC document
> (at the request of Jeff Chester).  I'm also a domain expert with respect to
> this subject-matter.  Jonathan's argument is not valid here (we have coved
> that twice), nor is he a domain expert.  I have presented the evidence to
> this forum and I am attesting to it in my capacity as an industry expert in
> this domain— what else would you like?
>
>
>  Chris Mejia | Digital Supply Chain Solutions | Ad Technology Group |
> Interactive Advertising Bureau - IAB
>
>   From: Ed Felten <ed@felten.com>
> Date: Tuesday, October 23, 2012 2:59 PM
> To: Chris Mejia - IAB <chris.mejia@iab.net>
> Cc: W3C DNT Working Group Mailing List <public-tracking@w3.org>
>
> Subject: Re: Proposed Text for Local Law and Public Purpose
>
>  Jonathan's argument, as I understand it, was that the MRC documents do
> not require companies to collect linkable data about every consumer.   Do
> you disagree with that?   Do you have a citation in the documents to the
> contrary?
>
> On Tue, Oct 23, 2012 at 5:49 PM, Chris Mejia <chris.mejia@iab.net> wrote:
>
>>   Jonathan,
>>
>>  I sit on the MRC's Digital Audit Review Committee.  As such, I have
>> attended countless MRC audits, and am asked to apply the MRC guidelines to
>> the audited companies— I do this, every week.  Unless you are accusing me
>> of lying or not being qualified (please be transparent and direct if you
>> are), then I am attesting to the fact that data retention, of any data that
>> relates to the bought/billed unit (impression, click, action, etc.) is
>> required per the guidelines.  The issue is by no means closed, nor are you
>> qualified to close it.
>>
>>  If you want to provide evidence to the contrary, please contact the MRC
>> yourself and do your homework.  You are a Stanford grad student,
>> representing Stanford University in this forum— I can only assume that
>> conducting thorough primary research is still something valued at your
>> institution.  So if you believe you are right (and I am wrong), then do the
>> real primary research (call the MRC, interview them, etc.) and provide
>> concrete evidence to discredit my testimony as an expert in this domain.
>>  But simply reading a document online and pulling parts of it out of
>> context to suit your ill-placed argument, is not only detrimental to this
>> working group's mission, it reflects poorly on the institution you are
>> representing.
>>
>>  Finally, I'd like to know who your academic  advisor is, or the
>> official at Stanford who supervises your contribution to the W3C?  Since
>> your membership to this forum seems to be associated with your student
>> affiliation at Stanford University, I'd be interested in understanding
>> whether your views and actions here are those of the University, or just
>> yourself as a private citizen?
>>
>>
>>  Chris Mejia | Digital Supply Chain Solutions | Ad Technology Group |
>> Interactive Advertising Bureau - IAB
>>
>>   From: Jonathan Mayer <jmayer@stanford.edu>
>> Date: Tuesday, October 23, 2012 2:14 PM
>> To: "Dobbs, Brooks" <Brooks.Dobbs@kbmg.com>
>> Cc: Kimon Zorbas - IAB Europe <vp@iabeurope.eu>, Jeffrey Chester <
>> jeff@democraticmedia.org>, "Amy Colando (LCA)" <acolando@microsoft.com>,
>> Richard Weaver - ComScore <rweaver@comscore.com>, "John Simpson ," <
>> john@consumerwatchdog.org>, W3C DNT Working Group Mailing List <
>> public-tracking@w3.org>
>>
>> Subject: Re: Proposed Text for Local Law and Public Purpose
>>  Resent-From: W3C DNT Working Group Mailing List <public-tracking@w3.org>
>>  Resent-Date: Tuesday, October 23, 2012 2:15 PM
>>
>>   Here's my concrete proposal: The MRC issue should be CLOSED.  As
>> always, if a working group member produces new information, we should take
>> it into account.
>>
>>  Background: The MRC issue was RAISED many months ago.  We still haven't
>> been presented with an iota of evidence that the MRC guidelines require
>> collection of user data.  A plain reading of the MRC Minimum Standards cuts
>> against that view.  So does a plain reading of the draft MRC guidelines
>> on digital video.
>>
>>  The issue appears to rest on a fundamental misunderstanding of the MRC
>> guidelines.  The MRC, in general, specifies *how* a user's behavior is
>> measured.  It does not address *whether* the behavior is measured in the
>> first place.
>>
>>  I agree with Brooks—much of the MRC's language is antiquated or
>> domain-specific.  But, for our purposes, the import seems reasonably clear.
>>  And to the extent our plain reading is inaccurate, again, working group
>> members are welcome to present that new information.
>>
>>  Jonathan
>>
>>  On Tuesday, October 23, 2012 at 9:14 AM, Dobbs, Brooks wrote:
>>
>>    Jonathan,
>>
>>  I have no objection to, and indeed it does make sense to, learn(ing)
>> what MRC actually requires.  In the meantime, while we agree that the full
>> extent of what is required is not yet yet fully understood, it is helpful
>> to avoid misleading folks that a standard which speaks to diaries, busy
>> signals and facsimiles and was started in the 60s has specifically
>> anticipated DNT signals at the rate likely to be seen by default settings;
>> it hasn't.
>>
>>  -Brooks
>>
>>  --
>>
>> *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
>>
>>
>> *
>> This email – including attachments – may contain confidential
>> information. If you are not the intended recipient,
>>  do not copy, distribute or act on it. Instead, notify the sender
>> immediately and delete the message.
>>
>>   From: Jonathan Mayer <jmayer@stanford.edu>
>> Date: Tuesday, October 23, 2012 11:49 AM
>> To: Brooks Dobbs <brooks.dobbs@kbmg.com>
>> Cc: Kimon Zorbas <vp@iabeurope.eu>, Jeffrey Chester <
>> jeff@democraticmedia.org>, "Amy Colando (LCA)" <acolando@microsoft.com>,
>> "Richard Weaver (Comscore)" <rweaver@comscore.com>, "John Simpson ," <
>> john@consumerwatchdog.org>, "public-tracking@w3.org" <
>> public-tracking@w3.org>
>> Subject: Re: Proposed Text for Local Law and Public Purpose
>>
>>   Brooks,
>>
>>  Some members of the working group have claimed they require a Do Not
>> Track exemption to accommodate the MRC Minimum Standards for content
>> measurement.  The nation is that the MRC Minimum Standards *require* some
>> data collection about users.  Before even considering such an exemption, it
>> seems prudent to validate the premise—we should look into whether the MRC
>> Minimum Standards actually require any data collection.
>>
>>  I agree that the MRC's document reads antiquated in many places.  That
>> should come as little surprise—it traces back to 1964.  (Latest version:
>> December 2011.)  The document explicitly does not, however, limit itself to
>> old technology.  In the provision we're discussing, it talks about "
>> diaries" and "tape records" (hah!), but it also includes "other primary
>> sources of audience data."  (It seemed to me uncontroversial to elide
>> "diaries" and "tape records" to save the group a few moments of reading.)
>>  Since the working group members who invoke MRC consistently cite an
>> eleven-month source data retention requirement, and this is the only
>> eleven-month source data retention requirement in the document, it seems
>> reasonable to conclude this is the relevant provision.
>>
>>  So no, no straw man here.  I'm attempting to honestly unpack the claim
>> that the MRC Minimum Standards require data collection about users.  It
>> seems to me that, in a plain reading, they do not.  Until a working group
>> member produces evidence otherwise, we should be safe in dropping the
>> proposed "relevant self-regulatory verification requirements" exemption.
>>
>>  Jonathan
>>
>>
>>  On Tuesday, October 23, 2012 at 6:58 AM, Dobbs, Brooks wrote:
>>
>>    Jonathan,
>>
>>  Did you really just accuse someone of creating a straw man and then
>> raise this as an example?
>>
>>  Let's go back and add the actual words left out by your ellipsis:
>>
>>    1.
>>
>>    Each rating service shall maintain, for at least eleven months from
>>    the end of the period covered by the report, all diaries and interviews (or
>>    a complete facsimile thereof), tape records and/or other primary sources of
>>    audience data. These shall include material actually used in the
>>    preparation of published rating reports as well as material collected but
>>    not used. In addition, each service shall maintain records of:
>>
>>    B) All unsuccessful attempts to obtain information, including- but
>>    not limited to - refusals, not at home, cases requiring further discussion
>>    and/or correspondence (e.g., with another member of the household), busy
>>    signals (phone), and returns from postal authorities.
>>
>>  It is pretty clear from reading this in full context that this has
>> nothing to do with web measurement (diaries, interviews, tape records were
>> conveniently redacted).  Even the language about unsuccessful attempts is
>> unrelated.  DNT ad calls are real ad calls that result in ad responses –
>> there is nothing "unsuccessful" about them.
>>
>>  So none of that is meant to defend or degrade the MRC.  I have no idea
>> if they are secretly plotting to disenfranchise the hispanic community.
>>  Maybe they are and that should be dealt with outside this group.  I do
>> know they provide measurement validation services that allow the entire ad
>> economy to work (not just Behavioral).  Per my previous post – and to mix
>> metaphors – if no one trusts the scales no one is paying for advertising.
>>  It has been said before, but is obviously worth repeating, upsetting core
>> measurement of a multi-tens of billion dollar ecosystem doesn't seem
>> consistent with the charter and is not an acceptable outcome.
>>
>>  -Brooks
>>
>>
>>  --
>>
>> *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
>>
>>
>> *
>> This email – including attachments – may contain confidential
>> information. If you are not the intended recipient,
>>  do not copy, distribute or act on it. Instead, notify the sender
>> immediately and delete the message.
>>
>>   From: Jonathan Mayer <jmayer@stanford.edu>
>> Date: Tuesday, October 23, 2012 1:41 AM
>> To: Kimon Zorbas <vp@iabeurope.eu>
>> Cc: Jeffrey Chester <jeff@democraticmedia.org>, "Amy Colando (LCA)" <
>> acolando@microsoft.com>, Brooks Dobbs <brooks.dobbs@kbmg.com>, "Richard
>> Weaver (Comscore)" <rweaver@comscore.com>, "John Simpson ," <
>> john@consumerwatchdog.org>, "public-tracking@w3.org" <
>> public-tracking@w3.org>
>> Subject: Re: Proposed Text for Local Law and Public Purpose
>>
>>   This is our second trip through the purported MRC justification.  In
>> our last visit, I pointed out that the MRC guidelines anticipate that not
>> all users will have data collected.
>>
>> On Thursday, September 27, 2012 at 6:18 PM, Jonathan Mayer wrote:
>>
>>  The MRC document explicitly accommodates consumers opting out of data
>> collection.  Page 8:
>>
>>  Each rating service shall maintain, for at least eleven months from the
>> end of the period covered by the report, all . . . primary sources of
>> audience data. These shall include material actually used in the
>> preparation of published rating reports as well as material collected but
>> not used. In addition, each service shall maintain records of:
>> . . .
>> b. All unsuccessful attempts to obtain information, including- but not
>> limited to - refusals . . . .
>>
>>   Until a working group member can furnish an MRC or MRC-like
>> *requirement* that users have their browsing histories collected, this
>> entire conversation seems moot.
>>
>>  Jonathan
>>
>>
>>  On Monday, October 22, 2012 at 11:33 AM, Kimon Zorbas wrote:
>>
>>   In Europe, we have Jics, industry committees, that run measurement in
>> (as far as I know) each country.
>> There is no agreed standard across Europe.
>> Sometimes they use their own technology (less often) sometimes partner
>> with companies such as Nielsen, comscore, Gemius, spring, etc. I am by no
>> means as expert on Jics. Unlike the MRC, Jics do not certify but mandate /
>> run the measurement, which de facto becomes THE standard in those countries.
>>
>> Colleagues from comscore / Nielsen might be better placed to respond.
>>
>> Kimon
>>
>> ----- Reply message -----
>> From: "Jeffrey Chester" <jeff@democraticmedia.org>
>> To: "Kimon Zorbas" <vp@iabeurope.eu>
>> Cc: "Amy Colando (LCA)" <acolando@microsoft.com>, "Dobbs, Brooks" <
>> Brooks.Dobbs@kbmg.com>, "Richard Weaver (Comscore)" <rweaver@comscore.com>,
>> "John Simpson ," <john@consumerwatchdog.org>, "public-tracking@w3.org" <
>> public-tracking@w3.org>
>> Subject: Proposed Text for Local Law and Public Purpose
>> Date: Mon, Oct 22, 2012 8:22 pm
>>
>>
>>
>> Kimon:    Our measurement companies in US are not congressional
>> chartered.  Can you send the names of the organizations you have in mind?
>>
>>
>>   Jeffrey Chester
>>  Center for Digital Democracy
>> 1621 Connecticut Ave, NW, Suite 550
>> Washington, DC 20009
>>  www.democraticmedia.org
>> www.digitalads.org
>> 202-986-2220
>>
>>  On Oct 22, 2012, at 2:08 PM, Kimon Zorbas wrote:
>>
>>   I also would like to point out that measurement in Europe works
>> somehow different with respect to organisational setup. We would like those
>> entities,not setup by the equivalent of European or national Congress, to
>> be reflected in the text. Would anyone have an issue?
>>
>> Kind regards,
>> Kimon
>>
>>
>> ----- Reply message -----
>> From: "Amy Colando (LCA)" <acolando@microsoft.com>
>> To: "Dobbs, Brooks" <Brooks.Dobbs@kbmg.com>, "Jeffrey Chester" <
>> jeff@democraticmedia.org>, "Richard Weaver (Comscore)" <
>> rweaver@comscore.com>
>> Cc: "John Simpson ," <john@consumerwatchdog.org>, "public-tracking@w3.org"
>> <public-tracking@w3.org>
>> Subject: Proposed Text for Local Law and Public Purpose
>> Date: Mon, Oct 22, 2012 6:30 pm
>>
>>
>>
>>  You beat me to it Brooks. I'll just add my own analogy that MRC
>> accreditation is a way of ensuring accurate and consistent counting
>> methodologies of clicks and impressions, which form the basis for
>> calculating the amount that advertisers are billed and sites are paid. The
>> analogy that springs to mind is the state agencies that certify that gas
>> stations are measuring gallons of gas accurately and billing consumers
>> accordingly.
>>
>> The reason that you see so many companies on the MRC accreditation page
>> is that this certification as to accuracy of measurement is vitally
>> important for providing online advertising services, whether targeted or
>> untargeted. I believe your reference to Hispanic measurement refers perhaps
>> to demographics in relation to TV geo advertising markets; if so, I don't
>> understand the relevance to our discussion.
>>
>> Sent from my Windows Phone
>>  ------------------------------
>> From: Dobbs, Brooks
>> Sent: 10/22/2012 9:12 AM
>> To: Jeffrey Chester; Weaver, Richard
>> Cc: John Simpson ,; Amy Colando (LCA); public-tracking@w3.org
>> Subject: Re: Proposed Text for Local Law and Public Purpose
>>
>>   Jeff,
>>
>>  I think you are missing the MRC's role in the ecosystem here.  We may
>> even need to do a 101 on the ad serving economy as compared to a more
>> tangible industry -  say pork bellies in the commodities market.  If this
>> is obvious, please forgive the review, but I think an analogy is helpful
>> here.
>>
>>  If I spend $150k on 200k lbs of frozen pork bellies at 75 cents a pound
>> a huge tractor trailer(s) show up and I see frozen pork bellies.  I can
>> further weigh them on an NTEP certified scale, and if it turns out that
>> only 180k lbs are there I can negotiate a $15k discount.  We can agree on
>> this because even though the bellies were weighed at my facility, they
>> scales where certified by an organization both buyer and seller trust.
>>
>>  If alternatively, I spend $150k on 10k CPMs of advertising on
>> Big1stParty.com at $15/CPM targeted to IP addresses in the Spokane WA
>> area from 4pm to 7pm local time – where's the beef?  I live in Atlanta.  If
>> the ad buy was delivered correctly, I should see exactly ZERO of the ads.
>>  How then does the purchaser have confidence that all 10k CPMs occurred?
>>  Advertisers have this confidence because they traditionally pay on numbers
>> that their system records, a log of "quality" deliveries.  But the obvious
>> question is then – what about the seller?  How does he have confidence in
>> the buyer's numbers?  Couldn't the buyer have just thrown away 5k
>> impressions as invalid so as to avoid paying for them?  MRC is the answer
>> here.  MRC will give both parties confidence that they have a common frame
>> of reference from which to conduct business.  The buyer (and/or seller)
>> will have his system MRC certified and there is an agreed upon counting
>> standardto use as a basis for payment.
>>
>>  If you are suggesting that accommodating MRC audits shouldn't play a
>> role in these discussions, the argument is akin to saying no one should
>> certify scales in the commodities market.
>>
>>  -Brooks
>>  --
>>
>> *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
>>
>> <image[50].png>
>> *
>> This email – including attachments – may contain confidential
>> information. If you are not the intended recipient,
>>  do not copy, distribute or act on it. Instead, notify the sender
>> immediately and delete the message.
>>
>>   From: Jeffrey Chester <jeff@democraticmedia.org>
>> Date: Saturday, October 20, 2012 4:49 PM
>> To: "Weaver, Richard" <rweaver@comscore.com>
>> Cc: John Simpson <john@consumerwatchdog.org>, Amy Colando <
>> acolando@microsoft.com>, "public-tracking@w3.org" <public-tracking@w3.org
>> >
>> Subject: Re: Proposed Text for Local Law and Public Purpose
>> Resent-From: <public-tracking@w3.org>
>> Resent-Date: Saturday, October 20, 2012 4:50 PM
>>
>>  Thanks.  I hope we aren't suggesting that somehow industry set
>> guidelines for its own MRC should in any way impact our work to provide
>> user choice in a meaningful manner for DNT.  The MRC is a media/industry
>> industry run initiative, involved in a wide range of TV and online
>> measurement tools that play a key role in the user targeting experience:
>> http://mediaratingcouncil.org/Accredited%20Services.htm
>>
>>  Companies involved with the Council include Google, Disney, Adobe,
>> comScore, AOL, Microsoft, Yahoo, etc.   I suggest that it's guidelines do
>> not reflect the privacy concerns addressed by this group.  The history of
>> ratings, as many of us know, has been quite controversial (such as Hispanic
>> measurement).  Congress has been critical of many of the industry
>> practices.    Is someone suggesting that there be a data retention source
>> period for one year or more to please the MRC?
>>
>>
>>
>>
>>   Jeffrey Chester
>>  Center for Digital Democracy
>> 1621 Connecticut Ave, NW, Suite 550
>> Washington, DC 20009
>>  www.democraticmedia.org
>> www.digitalads.org
>> 202-986-2220
>>
>>  On Oct 17, 2012, at 5:26 PM, Weaver, Richard wrote:
>>
>>
>>
>>  I hope Chris Mejia won’t mind that I’m cutting and pasting his previous
>> description of MRC:
>>
>>
>>  According to the Media Rating Council (MRC), the normal retention
>> period for "source data" required for industry accreditation of third-party
>> audience estimates is 1-year, as documented in their published standards: "
>> *Minimum Standards for Media Rating Research*" (available for download
>> at http://mediaratingcouncil.org/MRC%20Standards.htm).  Depending on the
>> case however (and on a case-by-case basis), special concessions may be made
>> outside of this standard from time to time as deemed appropriate by the
>> CPAs/auditor and the MRC.
>>
>>  *About the MRC, their mission and authority:*
>>  In the early 1960’s a U.S. Congressional Committee held hearings on the
>> purpose and accuracy of audience research and considered regulation related
>> to the TV and Radio industries.  These public hearings are commonly
>> referred to as the “Harris Committee Hearings on Broadcast Ratings.”  After
>> investigation and extensive testimony the Committee determined that
>> Industry self-regulation, including independent audits of rating services
>> was preferable to government intervention.  The Harris Committee hearings
>> resulted in the formation of an Industry-funded organization to review and
>> accredit audience rating services called the Broadcast Rating Council (now
>> referred to as the MRC).
>>
>> Aligned with the actions deemed necessary by the House Committee, the
>> activities of the MRC include:
>>
>>    - The establishment and administration of Minimum Standards for
>>    rating operations;
>>    - The accreditation of rating services on the basis of information
>>    submitted by such services; and
>>    - Auditing, through independent CPA firms, of the activities of the
>>    rating services.
>>
>>
>>  The Media Rating Council seeks to improve the quality of audience
>> measurement by rating services and to provide a better understanding of the
>> applications (and limitations) of rating information.  The Bylaws of the
>> MRC document the organization’s mission as: “to secure for the media
>> industry and related users audience measurement services that are valid,
>> reliable and effective; to evolve and determine minimum disclosure and
>> ethical criteria for media audience measurement services; and to provide
>> and administer an audit system designed to inform users as to whether such
>> audience measurements are conducted in conformance with the criteria and
>> procedures developed.”  This mission was established with the support of
>> the House Committee.
>>
>>  More on the MRC at http://mediaratingcouncil.org/History.htm
>>
>>
>>
>>
>>  Richard Weaver Deputy Privacy Officer | comScore, Inc. *(NASDAQ:SCOR)*
>>  o +1 (703) 438-2354 | rweaver@comscore.com
>>
>> ...........................................................................................................
>>
>>
>>
>>  *Introducing Mobile Metrix 2.0 - The next generation of mobile
>> behavioral measurement
>> *www.comscore.com/MobileMetrix<http://www.comscore.com/Products_Services/Product_Index/Mobile_Metrix_2.0>
>>
>>
>>     *From:* John Simpson [mailto:john@consumerwatchdog.org<john@consumerwatchdog.org>
>> ]
>> *Sent:* Wednesday, October 17, 2012 5:14 PM
>> *To:* Amy Colando
>> *Cc:* public-tracking@w3.org
>> *Subject:* Re: Proposed Text for Local Law and Public Purpose
>>
>>  I'm sorry, maybe I missed something -- it certainly wouldn't be the
>> first time -- but what is MRC accreditation?
>>
>>
>>    ----------
>>   John M. Simpson
>>   Consumer Advocate
>>   Consumer Watchdog
>>    2701 Ocean Park Blvd., Suite 112
>>    Santa Monica, CA,90405
>>   Tel: 310-392-7041
>>   Cell: 310-292-1902
>>   www.ConsumerWatchdog.org
>>   john@consumerwatchdog.org
>>
>>   On Oct 17, 2012, at 1:46 PM, Amy Colando (LCA) wrote:
>>
>>
>>   Hi John.
>>
>>   This was intended to address the MRC accreditation scenario that was
>> previously raised.
>>
>>    *From:* John Simpson [mailto:john@consumerwatchdog.org<john@consumerwatchdog.org>
>> ]
>> *Sent:* Wednesday, October 17, 2012 1:19 PM
>> *To:* Amy Colando (LCA)
>> *Cc:* public-tracking@w3.org
>> *Subject:* Re: Proposed Text for Local Law and Public Purpose
>>
>>   Amy,
>>
>>    A clarifying question: Can you please give a use case for what sort
>> of data would be collected for "relevant self-regulatory requirements"?
>>    Thanks,
>>    John
>>
>>     ----------
>>    John M. Simpson
>>    Consumer Advocate
>>    Consumer Watchdog
>>     2701 Ocean Park Blvd., Suite 112
>>     Santa Monica, CA,90405
>>    Tel: 310-392-7041
>>    Cell: 310-292-1902
>>    www.ConsumerWatchdog.org
>>    john@consumerwatchdog.org
>>
>>    On Oct 17, 2012, at 8:05 AM, Amy Colando (LCA) wrote:
>>
>>
>>
>>     Apologies that I have lost track of Action number, which I will look
>> up later.  Many thanks to Vinay, MeMe and David W. for assisting with this
>> text.
>>
>>    *6.1.1.9 Compliance with Local Law and Public Purpose*
>>
>>    *Normative:* Regardless of DNT signal, information MAY be collected,
>> retained, used and shared for complying with applicable laws, regulations,
>> legal obligations and other public purposes, including, but not limited to,
>> intellectual property protection, delivery of emergency services, and
>> relevant self-regulatory verification requirements.
>>
>>    *Non-normative: *This specification does not purport to require
>> parties to breach existing contractual obligations.  At the same time, it
>> is expected that parties implementing this specification should not enter
>> into new contractual obligations that have the effect of circumventing
>> specification requirements. This specification recognizes that there are
>> legitimate self-regulatory regimes that both protect consumer interests and
>> govern certain data practices, and the specification does not intend to
>> conflict with these regimes. However, parties should whenever possible
>> adhere to the letter and spirit of this specification, and should not look
>> to such regimes as merely a means to circumvent the specification.
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>


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Received on Wednesday, 24 October 2012 01:13:49 UTC

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