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

From: Rigo Wenning <rigo@w3.org>
Date: Thu, 27 Sep 2012 10:29:42 +0200
To: Nicholas Doty <npdoty@w3.org>
Cc: Alan Chapell <achapell@chapellassociates.com>, public-tracking@w3.org, "Dobbs, Brooks" <Brooks.Dobbs@kbmg.com>
Message-ID: <5015953.VQAASq1Rh7@hegel.sophia.w3.org>
Nick, 

On Wednesday 26 September 2012 15:49:14 Nicholas Doty wrote:
> I think what Alan is getting at is that there may be some data
> retention not required by financial reporting laws that we would
> consider consistent with an expressed DNT preference. For
> example, retaining the IP address of users who see an ad would be
> done in order to prove to a third-party auditing/trade
> organization that ads of a certain type are not shown to users in
> a particular country.

In some countries, IP addresses are considered personal data. And 
the music industry's success in the pursuit of file sharing 
youngsters via recording of IP addresses rather proofs them right. 

Collecting personal data under DNT:1 for long term storage, tracking 
and positive/negative discrimination is against all goals  this 
effort started with. A permitted use would go directly against the 
overall stated goals. This will be hard to explain to the outside 
world.

Now if some country has a law requiring long time storage of IP 
addresses for targeting and filtering of communications, this is 
covered by our provision "law prevails" and does not need a 
permitted use. If it is a contractual obligation, this obligation 
can't be fulfilled in the DNT:1 mode. A provision should be added to 
that contract. Or an exception should be triggered. But I don't see 
any reason for a permitted use here. I also have some slight doubts 
whether the requirements of PCMCP are in line with EU data 
protection rules, but I haven't looked deeply into their rules 
either. 

Rigo
Received on Thursday, 27 September 2012 08:30:09 UTC

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