Proposed friendly amendments to industry draft

his document and how they may be used elsewhere, it may help to introduce the definitions by saying, "For purposes of this specification, ...." 

Substantive:  To clarify one of the differences between the de-identified and de-linked categories as I understand them, it may be helpful to add language that indicates that the de-identified category permits reliance on operational controls in addition to technical controls, which I believe is consistent with the ideas Thomas Schauf presented.  

Thus, the definition would read, "Data is de-identified when a party

1. has taken reasonable steps to ensure that the data cannot be reasonably re-associated or connected to a specific user, computer, or device without the use of additional data that is subject to separate and distinct technical and organizational controls to ensure such non-attribution, or when such attribution would require a disproportionate amount of time, expense and effort; ...." 

I also support adding the audience measurement language that has been discussed and revised with  several participants and submitted by Esomar to the permitted uses section, 5.2. 




Susan Israel
Comcast Cable
215.286.3239
215.767.3926 mobile
917.934.1044 NY
susan_israel@comcast.com

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Received on Tuesday, 9 July 2013 15:32:18 UTC