Re: Consensus Industry Amendments to the DAA proposal

Jack,

It would be extremely helpful if you could explain your reasons for the changes and how precisely they differ from your original draft.

Thank you.
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
john@consumerwatchdog.org



On Jul 9, 2013, at 8:51 AM, Jack Hobaugh <jack@networkadvertising.org> wrote:

> Dear Colleagues,
> 
> The following consensus industry amendments to the DAA June 26 submission are proposed to provide further clarification to the June 26 submission.
> 
> We look forward to discussing the June 26 submission and these amendments.
> 
> Amendment # 1:
> Data is deidentified when a party:
> 
> 1.  has taken reasonable steps to ensure that the URL data across websites or Unique ID cannot reasonably be re-associated or connected to a specific user, computer, or device;
> 
> 2.  has taken reasonable steps to protect the non-identifiable nature of data if it is distributed to non-affiliates and obtain satisfactory written assurance that such entities will not attempt to reconstruct the data in a way such that an individual may be re-identified and will use or disclose the de-identified data only for uses as specified by the entity.
> 
> 3.  has taken reasonable steps to ensure that any non-affiliate that receives de-identified data will itself ensure that any further non-affiliate entities to which such data is disclosed agree to the same restrictions and conditions.
> 
> 4.  will commit to not purposely sharing this data publicly.
> 
> Data is delinked when a party:
> 
> 1. has achieved a reasonable level of justified confidence that data has been de-identified and cannot be internally linked to a specific user, computer, or other device within a reasonable timeframe;
> 
> 2. has taken reasonable steps to ensure that data cannot be reverse engineered back to identifiable data without the need for operational or administrative controls.
> 
> Amendment # 2:
> 
> Tracking is the collection and retention,  or use of a user’s browsing activity – the domains or URLs visited across non-affiliated websites -- linked to a specific user,  computer,  or device.
> 
> Amendment # 3:
> 
> The first party MUST NOT pass information without consent about this network interaction to third parties who could not collect or use the data themselves when DNT:1 is received. Information about the transaction MAY be passed on to service providers acting on behalf of the first party
> 
> Best regards,
> 
> Jack
> 
> Jack L. Hobaugh Jr
> Network Advertising Initiative | Counsel & Senior Director of Technology 
> 1634 Eye St. NW, Suite 750 Washington, DC 20006
> P: 202-347-5341 | jack@networkadvertising.org
> 
> 
> 
> 
>