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Re: Proposed Text for Local Law and Public Purpose

From: Lauren Gelman <gelman@blurryedge.com>
Date: Fri, 26 Oct 2012 11:13:32 -0700
Cc: Rigo Wenning <rigo@w3.org>, "public-tracking@w3.org" <public-tracking@w3.org>, Jeffrey Chester <jeff@democraticmedia.org>, Ed Felten <ed@felten.com>
Message-Id: <37CAD165-F2D6-4DE8-95C1-77071EDEAF7B@blurryedge.com>
To: "Dobbs, Brooks" <Brooks.Dobbs@kbmg.com>

Can someone explain exactly why this matters?  Is it the "compliance with other rules" language?  If so I suggest we cut this section all together.  No company needs an exception in a voluntary standard to comply with local laws.  And let individual companies figure out how compliance with DNT affects any other obligations (current or future)-- which they are going to do based on business needs and risk no matter what is written here.

It seems this is a hot of hoopala, and a lot of hoops, over something that is going to have very little practical value.  If my client has a Congressionally mandated compliance requirement, legal requirement, receives a valid law enforcement request, etc. it's going to matter very little to me what DNT says about it.

Lauren Gelman
BlurryEdge Strategies
415-627-8512

On Oct 26, 2012, at 7:59 AM, Dobbs, Brooks wrote:

> Rigo,
> 
> I appreciate you trying to find a solution here, but I am really the wrong
> person to essentially be negotiating for what the MRC does or doesn't need
> or how they can rejigger their systems.  Again I think I can guess pretty
> accurately at what MRC or Company XYZ Anti-clickfraud squad might need,
> but if you are asking specifics or how to change what they do - I'd go to
> the horses mouth.  Does anyone object to bringing the MRC into the
> process? 
> 
> -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
> 
> 
> 
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> 
> 
> On 10/26/12 4:47 AM, "Rigo Wenning" <rigo@w3.org> wrote:
> 
>> On Thursday 25 October 2012 15:40:10 Dobbs, Brooks wrote:
>>> It may be that it is concluded that accrediting measurement is
>>> incompatible with DNT, but I would suggest that this is an
>>> outcome with exceedingly broad reaching consequences.
>> 
>> There is a big eco-system. But we can't just do nothing because a
>> change here would affect changes there. I would hope that we can do
>> DNT so that it is feasible with MRC. Ed has hinted that maybe MRC
>> can be implemented in a way that is more privacy friendly and thus
>> acceptable even under DNT:1. I hear Kimon saying that they have done
>> their homework already and measure without personal data. Maybe a
>> simple tweak will help. Can we compare IAB EU way to the others?
>> 
>> Nobody ever said that this endeavor will be simple. But again, if as
>> is fits, fine. If we need to tweak, we have to identify what. To
>> know, we need to know what personal identifiers they use. I hear
>> Brooks saying "IP" but there may be other identifiers. Nobody wants
>> to end measuring. But we have to resolve a conflict here between
>> measuring (and accuracy) against an expressed will of not being
>> followed and put into a dossier.
>> 
>> Brooks do you happen to know what MRC collects? Or is this too
>> sensitive for a public mailing-list?
>> 
>> Rigo
>> 
> 
> 
Received on Friday, 26 October 2012 18:14:00 UTC

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