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Re: Poll text call: final text by 28 September

From: John Simpson <john@consumerwatchdog.org>
Date: Fri, 28 Sep 2012 16:18:11 -0700
Message-Id: <0A7175B4-1471-4D69-B29A-96022E210DF5@consumerwatchdog.org>
Cc: "public-tracking@w3.org (public-tracking@w3.org)" <public-tracking@w3.org>
To: John Simpson <john@consumerwatchdog.org>
That was meant to be " ... ought not be retained in *identifiable* form."  The danger of too many negatives....


----------
John M. Simpson
Consumer Advocate
Consumer Watchdog
2701 Ocean Park Blvd., Suite 112
Santa Monica, CA,90405
Tel: 310-392-7041
Cell: 310-292-1902
www.ConsumerWatchdog.org
john@consumerwatchdog.org

On Sep 28, 2012, at 4:13 PM, John Simpson wrote:

> Sure, David.
> 
> As I understand it what we're talking about here are log files and that sort of thing that are passively collected with any Internet transaction.  If DNT is enabled they ought not be retained in unidentifiable form.  The question: What is a reasonable time frame for that?
> 
> I came up with two weeks based on an analogy to the sort of common workplace understanding about leaving a job.  You give two weeks notice when you quit. You give the boss two weeks two get things in order upon your departure.  Here the user  is giving the server two weeks notice to get things in order to honor his or her explicit preference about not being tracked.
> 
> 
> Best,
> John
> 
> ----------
> John M. Simpson
> Consumer Advocate
> Consumer Watchdog
> 2701 Ocean Park Blvd., Suite 112
> Santa Monica, CA,90405
> Tel: 310-392-7041
> Cell: 310-292-1902
> www.ConsumerWatchdog.org
> john@consumerwatchdog.org
> 
> On Sep 28, 2012, at 3:49 PM, David Wainberg wrote:
> 
>> John,
>> 
>> It might be helpful to provide your basis for suggesting the two week period as a viable option.
>> 
>> -David
>> 
>> 
>> On 9/28/12 6:33 PM, John Simpson wrote:
>>> Aleecia,
>>> 
>>> I would offer this option:
>>> 
>>> Option 3:
>>> 
>>> Operators MAY retain data related to a communication in a third-party context for up to TWO weeks. During this time, operators may render data unlinkable (as described above) or perform processing of the data for any of the other permitted uses
>>> 
>>> ----------
>>> John M. Simpson
>>> Consumer Advocate
>>> Consumer Watchdog
>>> 2701 Ocean Park Blvd., Suite 112
>>> Santa Monica, CA,90405
>>> Tel: 310-392-7041
>>> Cell: 310-292-1902
>>> www.ConsumerWatchdog.org
>>> john@consumerwatchdog.org
>>> 
>>> On Sep 28, 2012, at 3:12 PM, David Wainberg wrote:
>>> 
>>>> Aleecia,
>>>> 
>>>> In reviewing this to provide feedback, it occurs to me that it relies on the definition of unlinkable, which is still very much up for debate. How can companies weigh in on these options without understanding what the requirements actually are? We should postpone this poll               until we define unlinkable so that companies can give realistic feedback regarding the time and effort needed to meet the requirements.
>>>> 
>>>> Thanks,
>>>> 
>>>> David
>>>> 
>>>> 
>>>> On 9/25/12 6:20 PM, Aleecia M. McDonald wrote:
>>>>> From the call on 12 September, we discussed topics where we have increasing clarity on options for permitted uses. I want to make sure we have the text right to reflect our options prior to doing a decision process with a poll calling for objections, which is responsive to Ian's feedback. We also want to move quickly, as Roy suggests.
>>>>> 
>>>>> Please propose specific alternative text if you believe that the two texts given below do not reflect the options before us by Friday, 28 September. We will briefly review these texts on the call tomorrow, just to make sure no one misses anything, and here we are on the mailing list, for those who cannot make the call.
>>>>> 
>>>>>  Aleecia
>>>>> 
>>>>> -----
>>>>> Log files: issue-134
>>>>> ----
>>>>> 
>>>>> This normative text fits into the section on Third Party Compliance, subsection 6.1.1.1, Short Term Collection and Use, <http://www.w3.org/2011/tracking-protection/drafts/tracking-compliance.html#short-term>. We will also want non-normative text, and have some suggested, but that will be clearer once we have the normative text settled. (Options for definitions of unlinkable data are in section 3.6, Unlinkable Data, <http://www.w3.org/2011/tracking-protection/drafts/tracking-compliance.html#def-unlinkable>.)
>>>>> 
>>>>> Option 1:
>>>>>  Operators MAY retain data related to a communication in a third-party context for up to 6 weeks. During this time, operators may render data unlinkable (as described above) or perform processing of the data for any of the other permitted uses.
>>>>> 
>>>>> Option 2:
>>>>>  Operators MAY retain data related to a communication in a third-party context. They MUST provide public transparency of their data retention period, which MUST have a specific time period (e.g. not infinite or indefinite.) During this time, operators may render data unlinkable (as described above) or perform processing of the data for any of the other permitted uses.
>>>>> 
>>>>> 
>>>>> 
>>>> 
>>> 
>> 
> 
Received on Friday, 28 September 2012 23:18:09 UTC

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