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

From: Nicholas Doty <npdoty@w3.org>
Date: Wed, 19 Sep 2012 09:02:35 -0700
Message-Id: <319B87CA-6C3B-49FD-ADBF-400FEF182C61@w3.org>
Cc: Alan Chapell <achapell@chapellassociates.com>
To: "public-tracking@w3.org (public-tracking@w3.org)" <public-tracking@w3.org>
I believe this is intended for the Tracking Protection Working Group. —Nick

Begin forwarded message:

> Resent-From: public-privacy@w3.org
> From: Alan Chapell <achapell@chapellassociates.com>
> Subject: ACTION-255: Work on financial reporting text as alternative to legal requirements
> Date: September 19, 2012 8:14:20 AM PDT
> To: <public-privacy@w3.org>
> Good Morning,
> 
> 
> 
> Here is the language we came up with. I'm on a plane. I'll be on IRC, but not the call until perhaps the end.
> 
> 
> 
> 6.1.1.5 Financial Logging and Auditing
> 
> Regardless of DNT signal, any information sent via the request may be collected, retained and used as a record that the request occurred and that the request met various criteria set forth by the contract or as terms of more standard industry audits used to determine the quality of impressions, clicks or actions.  This may include information used to verify:
> 
> Number and quality of ad impressions
> Basics of MRC audit and of all contracts
> Unique visitors receiving impressions
> Typical contractual term
> Number and quality of clicks
> Basic of MRC audit and of all contracts and vital to confidence in CPM pricing
> Unique visitors imparting clicks
> Basics of MRC audit and all contracts
> Subsequent action(s) or conversion post click or impression
> Key to entire CPA billing model
> Unique visitors engaging in post click or impression action or activity
> Key to entire CPA billing model
> The degree to which ad ad was rendered
> MRC audit IAB standard contracts
> Display time and user interaction with ad
> Contracts
> Location on page where ad rendered
> Contracts
> URL Location on which ad rendered
> Contract and used to ensure that ads are delivered on "inappropriate" sites (per Alans' comments) 
> 
> 6.1.1.5.1 Examples
> This section is non-normative.
> 
> A snow tire manufacturer, BigSnowTire Co, enters into a contract to buy 1 billion ad impressions at $3 per thousand on BigPublisher to specific pages on BigPublisher's site to viewers in certain Northern US sites at a given time of day.  BigSnowTire Co uses a popular ad delivery tool to record IP address, Ad Unit Served , URL on which it was served, Time it was served (among other information) to ensure that the terms of its contract with BigPublisher were met.  Absent this data BigSnowTire Co would have no lasting record that significant financial outlay of $3million was correctly delivered.
> 
> A large law firm with a class action practice, DewyCheatim LLC, purchases CPM based advertising at a rate of $50 a click for keyword "classactionenoma" from a large search engine, BigSearch.  DewyCheatim uses a popular 3rd party tool provider to record click information including cookie, IP address, user agent and time stamp relating to the click to ensure that contract terms with BigSearch were met by retaining the ability to filter multiple clicks by the same end user, filter "low quality" clicks coming from competing law firm "AndHow LLC" or clicks potentially coming from BigSearch or its affiliates.
> 
> A large credit card agency, BigPlastic, offers a $100 bounty to all sites who run display ads featuring BigPlastic credit card offers where within 24 hours of a user's view of such ad or click on such ad, user visits BigPlastic.com and signs up for a card.  BigPlastic.com by contract retains the right to hold back such bounty if user later fails to qualify or use such card.  BigPlastic.com retains a 3rd party ad service provider who, on BigPlastic's behalf, retains or supplies to BigPlastic, data which would allow such correlation to occur including IP, ReferringURL and unique cookie.
> 
> An industry group called the Prescription Medicines Code of Practice Authority (PCMCP) is charged with regulating certain aspects of  (among other things) pharmaceutical advertising in the UK.  An Advertising Network campaign was created and run for a U.S. based pharma company, Burtussion Pharmaceuticals.  The site list for the campaign included “News.co.uk” a site that is widely viewed by people located across both the U.S. and Europe. A user located in the UK who was served an at from Burtussion on News.co.uk took a snapshot and filed a complaint with the PMCPA as it was against the PMCPA Code for an American company to advertise an American prescription / Rx product in the UK. However, if the ad network could demonstrate that the User was a) located in the U.S. and b) had been previously served a Burtussion ad on a U.S. based site as part of this campaign, the likelihood of the PMCPA taking action would diminish greatly. 5000 UK impressions were served as part of a remarketing campaign. Six months after the campaign had run, PMCPA contacted the ad network, the ad agency and Burtussion as part of their investigation into the alleged breach of their code and requested (among other items): demonstrable proof that re-targeted viewers had to have seen the Burtussion Pharmaceuticals advertisement previously on a US site before they could be served the same advertisement on the UK based site. i.e. if the viewer saw the advertisement on the News.co.uk website.  The ad network was asked to check its logs to confirm that those applicable Users have viewed the advertisement previously. The agency shared that the pharmaceutical company was facing fines, and that there’s was a high potential that the issue would be escalated if the ad network didn’t clarify the above points quickly.
> ·         
> 
> Alan
> 
Received on Wednesday, 19 September 2012 16:02:45 UTC

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