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Re: FTC Chairwoman Edith Ramirez's speech

From: Rob van Eijk <rob@blaeu.com>
Date: Wed, 17 Apr 2013 23:23:18 +0200
To: John Simpson <john@consumerwatchdog.org>, <peter@peterswire.net>
Cc: <public-tracking@w3.org>
Message-ID: <96ab0a27a6edfd2de268983e9985c9bd@xs4all.nl>

Thank you John, it inspired me to write an open letter to the chairs 
and the group.

Dear Peter,
Dear Matthias,
Dear group members,

The honorable mrs. Ramirez makes it clear in her speech that the FTC 
advocates a DNT that allows consumers to stop the collection of nearly 
all behavioral data gathered across sites and not just the serving of 
targeted ads. On behalf of the Article 29 Data Protection Working Party 
I am echoing this criterium of collection limitation.

As expressed on the call, time has come to make a choice whether Do Not 
Track means Do Not Collect or Do Not Use. The privacy advocates 
positions gear towards a collection limitation instrument, the 
advertising industry positions gear towards a use limitation approach 
that may well resemble or carbon copy the DAA code of conduct.

Peter called for proposals to move forward. Before proposing a way to 
move forward I will address three concerns.

First, It is clear to me that trying to bridge the two positions is a 
waste of our time. The two positions are so far apart that in terms of 
game theory no optimal solution is possible. I expressed this on the 
call today, when Peter thinking through the possible scenario's for the 
upcoming face 2 face meeting.

Second, it is also clear to me that the W3C process of the least 
objectionable proposal, is not suited to bridge the gap between the 
compliance positions. If a decision is based on choosing the least 
objectionable proposal, it will show that the process is not a democracy 
by votes. It also has an an important implication, namely that if the 
chair is making such a decision, W3C becomes the problem owner. I find 
the fact that W3C may become the problem owner a big risk for a multi 
stakeholder process. It is a risk that concerns me.

Third, time is ticking. Last Call is planned for July 2013 and this 
status is an important deadline. It is unlikely that the group will 
remain complete if the deadline of July 2013 is not met. It is a risk 
that concerns me even more. Making a swift choice what the problem is 
the group is willing to solve should be on the top of our issue list.

I therefore propose a way to move forward. A wise way forward IMHO 
would be to make an affirmative choice either 1. for collection 
limitation or 2. for use limitation with clear and specific added value 
to the existing self regulatory solutions or 3. for a NoGo (ie a 
premature closure of the whole multi stakeholder exercise).

This choice for 1 or 2 allows the disentanglement of many of the 
interdependent issues that have held the process in a deadlock for too 
long. This choice also allows for the breakdown of the problem at hand 
into sub-issues, that can effectively be addressed in time and solved 
before Last Call. Making this choice asap allows us to make use of our 
valuable face 2 face time in Sunnyvale.

Whether a choice for option 2 will be acceptable for the privacy 
advocates remains to be seen. Although the time is ticking, there is a 
window of opportunity for the stakeholders of the advertising industry 
to do the right things to convince the privacy advocates of the added 
value that DNT will bring to their self regulatory solutions.

Regards,
Rob van Eijk

John Simpson schreef op 2013-04-17 21:34:
> Colleagues,
> 
> FTC Chairwoman Edith Ramiez has just made an interesting speech to
> the American Advertising Federation that touches on our efforts to
> develop a Do Not Track standard.
> 
> I've attached it as a PDF file.
> 
> Regards,
> John
> 
> 
> ---------
> 
> John M. Simpson
> Privacy Project Director
> Consumer Watchdog
> 2701 Ocean Park Blvd., Suite 112
> Santa Monica, CA, 90405
> 
> Tel: 310-392-7041
> Cell: 310-292-1902
> www.ConsumerWatchdog.org [1]
> john@consumerwatchdog.org
> 
> 
> 
> Links:
> ------
> [1] http://www.ConsumerWatchdog.org
Received on Wednesday, 17 April 2013 21:23:53 UTC

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