Re: ISSUE 25: ACTION 415: Audience measurement research


Rob:

Thank you for this helpful update on your view.

Peter


Prof. Peter P. Swire
C. William O'Neill Professor of Law
	Ohio State University
240.994.4142
www.peterswire.net

Beginning August 2013:
Nancy J. and Lawrence P. Huang Professor
Law and Ethics Program
Scheller College of Business
Georgia Institute of Technology






-----Original Message-----
From: Rob van Eijk <rob@blaeu.com>
Reply-To: "rob@blaeu.com" <rob@blaeu.com>
Date: Wednesday, July 3, 2013 3:21 AM
To: Rigo Wenning <rigo@w3.org>, "jeff@democraticmedia.org"
<jeff@democraticmedia.org>, Kathy Joe <kathy@esomar.org>,
"Susan_Israel@Comcast.com" <Susan_Israel@comcast.com>, Richard Weaver
<rweaver@comscore.com>, "Adam I.C. Phillips Phillips"
<adam.phillips@realresearch.co.uk>, Peter Swire <peter@peterswire.net>
Cc: Mailing List <public-tracking@w3.org>
Subject: Re: ISSUE 25: ACTION 415: Audience measurement research

>
>Peter,
>
>After talking to Rigo last night, I see the progress on the normative
>language and specifically in purpose limitation and not applying the
>audience measurement data to individuals, a computer of device. I see
>the right mindset in terms of privicy by design: changing data from a
>site visitor into data about a site object.
>
>Since we are negotiating here: if Audience Measurement becomes a
>permitted use, than Shane's proposal to allow the collection of intrest
>categories before de-identification needs to go off the table.
>
>Rob
>
>Rigo Wenning schreef op 2013-07-02 19:27:
>> Dear all,
>> 
>> based on the text attached at the end of this email, that I received
>> today from Kathy, and that was discussed during a call today, I
>> withdraw
>> my requirement for a minimum bucket size of 812 people. I support the
>> new text suggested as attached:
>> 
>> ====
>> Information may be collected, retained and used by a third party for
>> audience measurement research where the information is used to
>> calibrate, validate or calculate through data collected from opted-in
>> panels, which in part contains information collected across sites and
>> over time from user agents.
>> 
>> 
>> A third party eligible for an audience measurement research permitted
>> use MUST adhere to the following restrictions. The data collected by
>> the
>> third party:
>> 
>> ?     Must be pseudonymised before statistical analysis begins, and
>> ?     Must not be shared with any other party unless the data are de-
>> identified prior to sharing, and
>> ?     Must be deleted or de-identified as early as possible after the
>> purpose of collection is met and in no case shall such retention,
>> prior
>> to de-identification, exceed 53 weeks and
>> ?     Must not be used for any other independent purpose including
>> changing an individual¡¯s user experience or building a profile for ad
>> targeting purposes.
>> ?     In addition, the third party must be subject to an independent
>> certification process under the oversight of a generally-accepted
>> market
>> research industry organization that maintains a web platform providing
>> user information about audience measurement research. This web
>> platform
>> lists the parties eligible to collect information under DNT standards
>> and the audience measurement research permitted use and it provides
>> users with an opportunity to exclude their data contribution.
>> 
>> Non-normative: collection and use for audience measurement research
>> 
>> Audience measurement research creates statistical measures of the
>> reach
>> in relation to the total online population, and frequency of exposure
>> of
>> the content to the online audience, including paid components of web
>> pages.
>> 
>>  Audience measurement research for DNT purposes originates with opt-in
>> panel output that is calibrated by counting actual hits on tagged
>> content on websites. The panel output is re-adjusted using data
>> collected from a broader online audience in order to ensure data
>> produced from the panel accurately represents the whole online
>> audience.
>> 
>> This online data is collected on a first party and third party basis.
>> This collection tracks the content accessed by a device rather than
>> involving the collection of a user¡¯s browser history. Audience
>> measurement is centered around specific content, not around a user.
>> 
>> The collected data is retained for a given period for purposes of
>> sample
>> quality control, and auditing.  During this retention period
>> contractual
>> measures must be in place to limit access to, and protect the data, as
>> well as restrict the data from other uses. This retention period is
>> set
>> by auditing bodies, after which the data must be de-identified.
>> 
>> The purposes of audience measurement research must be limited to:
>> 
>> ¡¤    Facilitating online media valuation, planning and buying via
>> accurate and reliable audience measurement.
>> ¡¤    Optimizing content and placement on an individual site.
>> 
>> The term ¡°audience measurement research¡± does not include sales,
>> promotional, or marketing activities directed at a specific computer
>> or
>> device.  Audience measurement data must be reported as aggregated
>> information such that no recipient is able to build commercial
>> profiles
>> about particular individuals or devices.
>> 
>> ===
>> 
>> As there is no other concrete text proposal, I would hope that we can
>> reach consensus on this proposal to be included as a permitted use in
>> the Compliance Specification and close ISSUE-25.
>> 
>>  --Rigo
>> 
>> On Tuesday 02 July 2013 18:05:28 Kathy Joe wrote:
>>> Following up on this action, as part of a series of calls, the two
>>> most recent amendments to the normative text were discussed today in
>>> a call with Rigo Wenning, Susan Israel, Richard Weaver and Adam
>>> Phillips where it was clarified:
>>> 
>>> ŒCalibrate, validate or calculate through©ö Susan noted this was added
>>> to more clearly express that the panel data is used to better
>>> understand the census data, in addition to the census data being used
>>> to calibrate the panel data so that each informs the other. This does
>>> not radically change the process - it just describes it more clearly.
>>> 
>>> ŒMust not be used for any other independent purposes including
>>> changing an individual©ös user experience or building a profile for ad
>>> targeting purposes©ö. This had already been added to cover concerns
>>> like those that have been expressed on the list by Rigo and Jeff
>>> Chester, which Rigo further explained to us on the call -- that an
>>> audience measurement research permitted use would allow data to be
>>> collected and used for another purpose, ie to change a piece of
>>> advertising inflight or for addressability to particular, small
>>> target groups based on user profiles, with the potential for abuse,
>>> such as through redlining or offering different prices to users with
>>> different profiles. This is not the purpose of, and is excluded from
>>> the AMR permitted use, which is to provide a general measurement of
>>> an audience (ie the number of viewers and general characteristics of
>>> the audience that saw a piece of content).  The only use of AMR to
>>> determine any pricing would be that a web site owner could charge an
>>> advertiser or media buyer a higher rate based on traffic to a
>>> website.
>>> 
>>> Comments are welcome and we will arrange additional calls with Justin
>>> Brookman and Jeff Chester.

Received on Wednesday, 3 July 2013 11:46:35 UTC