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

From: David Wainberg <david@networkadvertising.org>
Date: Fri, 28 Sep 2012 17:33:26 -0400
Message-ID: <506617A6.7050806@networkadvertising.org>
To: Rigo Wenning <rigo@w3.org>
CC: Nicholas Doty <npdoty@w3.org>, Alan Chapell <achapell@chapellassociates.com>, public-tracking@w3.org, "Dobbs, Brooks" <Brooks.Dobbs@kbmg.com>
Rigo,

On 9/27/12 4:29 AM, Rigo Wenning wrote:
> 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.
I think this thread has been about retaining the data for financial 
reporting purposes. I don't think anyone claimed that IP addresses 
retained for those purposes should be available also for 
positive/negative discrimination.
>
> 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.
I think the point is that there are legitimate reasons outside of 
statutory or regulatory requirements that this data may need to be 
retained. And I think those of us coming from the business side have 
been very willing to work on reasonable retention and use limits that 
can still accommodate those reasons.

There's now been a lot of explanation from people in the online 
advertising business about the needs to retain certain data for 
financial reporting reasons. It seems we're all agreed that online 
advertising should not be prohibited under DNT, so it follows that 
certain business needs around online advertising must be allowed for. So 
what harms stem from accommodating these business needs? Can you provide 
real examples of why the use of such data for financial reporting is a 
problem? Perhaps if we really understood specific cases you are 
concerned about, it would help us get on the same page about appropriate 
limitations.

-David
>
Received on Friday, 28 September 2012 21:33:56 UTC

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