RE: issue-199

Rob,

I feel that’s a fair question in both directions.  ☺  For me, this approach was reviewed with the FTC and DPAs through-out the EU as de-identification as part of the Search Retention discussion – hence my desire to keep that in place.

I’ve offered up alternatives such as “disassociated” or “de-identified but event linkable” so that use of “de-identified” on its own becomes less of an issue for those married to other definitions of “de-identified” as a standalone term.

- Shane

From: Rob van Eijk [mailto:rob@blaeu.com]
Sent: Wednesday, July 10, 2013 12:29 PM
To: Shane Wiley; David Singer
Cc: Mike O'Neill; 'achapell'; npdoty@w3.org; tlr@w3.org; public-tracking@w3.org; jeff@democraticmedia.org
Subject: RE: issue-199


So why are you married to the term de-identified. Please explain.

Rob

Shane Wiley <wileys@yahoo-inc.com<mailto:wileys@yahoo-inc.com>> wrote:

David,

Fair call outs and it's exactly those activities that are prohibited in the Yellow Zone and require a blend of technical, operational, and administrative controls to reasonably achieve that outcome.

- Shane

-----Original Message-----
From: David Singer [mailto:singer@apple.com]
Sent: Wednesday, July 10, 2013 11:48 AM
To: Shane Wiley
Cc: Mike O'Neill; 'achapell'; npdoty@w3.org<mailto:npdoty@w3.org>; tlr@w3.org<mailto:tlr@w3.org>; public-tracking@w3.org<mailto:public-tracking@w3.org>; jeff@democraticmedia.org<mailto:jeff@democraticmedia.org>
Subject: Re: issue-199


On Jul 9, 2013, at 19:29 , Shane Wiley <wileys@yahoo-inc.com<mailto:wileys@yahoo-inc.com>> wrote:

Mike,

Deidentification is about removing the association between a unique ID (any source:  cookie, digital fingerprint, etc.) an!

 d the

actual/specific user/device.  In this context:

Red:  actual user/device
Yellow:  not actual user/device but events are linkable (and only usable for analytics/reporting)

I think that yellow data is fairly easily related to a user/device, isn't it, given that the same 'key' is consistently used for the same user/device?
a) if I get access to the association from the user/device to the key
b) if I know the algorithm to calculate the key from a transaction
c) if I can trigger the user into performing a 'tracer' transaction, and see which record that gets appended to
d) if I can look at the accumulated data and infer who it is, under some circumstances (geography, gender, and so on)

There are probably more.  It might be harder to identify them than if the user's obvious identifiers are in the record, but it's still a tracking record of a specific user/device.

So I agree, it's not until we get to green th!

 at we

get out of scope:

Green:  not actual user/device and events are not linkable (outside the scope of DNT)

David Singer
Multimedia and Software Standards, Apple Inc.