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Re: ACTION-255: Work on financial reporting text

From: Rigo Wenning <rigo@w3.org>
Date: Wed, 31 Oct 2012 11:33:48 +0100
To: public-tracking@w3.org
Cc: Nicholas Doty <npdoty@w3.org>, Alan Chapell <achapell@chapellassociates.com>
Message-ID: <3039408.ST9biGUsok@hegel.sophia.w3.org>
Could we remind people of the purpose limitation and data 
minimization principle that govern all the permitted uses in the 
non-normative text? Because otherwise people may believe that under 
"financial data" you just collect the same data and use it for what 
ever suits your business. As the latter is not the case, I think a 
reminder is in order IMHO. 

Rigo

On Tuesday 30 October 2012 17:06:11 Nicholas Doty wrote:
> Hi all,
> 
> I'm not sure if Alan will have power/Internet access in New York 
at the moment, so I'm sending the proposal for this action to the 
group. Suggested text is:
> > Financial reporting and auditing
> > 
> > Operators may retain data related to a communication in a
> > third-party context to use for billing and auditing of
> > concurrent transactions. This may include counting ad
> > impressions to unique visitors, verifying positioning and
> > quality of ad impressions and auditing compliance with this and
> > other standards.
> This text would be one of the enumerated permitted uses, replacing
> the current editors' draft section 6.1.2.5.
> I suggested additional text, that might just be non-normative or 
explanatory, but I don't believe that Alan thinks it's necessary, so 
consider this part just from me:
> > Note that (as described above/below) these requirements do not
> > prohibit retention and use of data required by law or
> > regulation, but the existence of a contractual requirement to
> > retain data does not take precedence over compliance with these
> > requirements.
> > 
> > This permitted use is intended to provide for recording,
> > reporting and verifying delivery of and interaction with online
> > advertising and similar activities. It is not intended to cover
> > retaining a user's ad impression to combine with later browsing
> > activity, subsequent conversion, frequency capping or ad
> > sequencing. Note that when a user meaningfully interacts with
> > an ad or widget, such interaction is likely in a first-party
> > context (and therefore not restricted by these third-party
> > requirements).
> This proposal is a new attempt at a replacement for existing text
> on financial reporting, an update from a past proposal based on
> financial reporting law. The limiting factor of the "concurrent
> transaction" is an attempt to enable the transactional billing
> (and related audits) while not allowing any type of data
> collection required by a contract, as I believe is the common
> intent of the group. We believe this might also help with the
> ongoing discussion about MRC and other self-regulatory regimes;
> where those systems are auditing for financial reporting, then
> this permitted use might be more focused and perhaps address
> concerns we've heard on that thread.
> 
> A version of this text is present in my updated draft on permitted
> uses, here:
> http://npdoty.name/w3c/middle-way#financial-reporting-and-auditin
> g
> 
> Please let us know what you think.
> Thanks,
> Nick
Received on Wednesday, 31 October 2012 10:34:26 UTC

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