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ISSUE-25: text to be discussed in today's call

From: Peter Swire <peter@peterswire.net>
Date: Wed, 17 Jul 2013 06:46:27 -0700
To: Kathy Joe <kathy@esomar.org>, "public-tracking@w3.org" <public-tracking@w3.org>
Message-ID: <CE0C14F6.91DEA%peter@peterswire.net>
Good morning:

So that we're sure to be on the same page for this, here is the normative and non-normative text on audience measurement for today's call.  Edits in red in light of recent discussions that Kathy Joe and her group have had with a number of WG members.




Issue 25: Aggregated data collection and use for audience measurement research 4 July 2013


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 pseudonymized before statistical analysis begins, such that unique key-coded data are

used to distinguish one individual from another without identifying them, 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


· 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.

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

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

From: Kathy Joe <kathy@esomar.org<mailto:kathy@esomar.org>>
Date: Wednesday, July 17, 2013 9:24 AM
To: "public-tracking@w3.org<mailto:public-tracking@w3.org>" <public-tracking@w3.org<mailto:public-tracking@w3.org>>
Subject: ISSUE-25 re 5.2 Audience measurement: ACTION 415 June change proposal:
Resent-From: <public-tracking@w3.org<mailto:public-tracking@w3.org>>
Resent-Date: Wednesday, July 17, 2013 9:25 AM

Dear All,

Over the last few weeks as agreed by the group, we have had several calls including Susan Israel, Richard Weaver, Adam Philips as well as Peter Swire with Rigo, Justin and Jeff - the wiki http://www.w3.org/wiki/Privacy/TPWG/Change_Proposal_Audience_Measurement is not yet updated to cover these exchanges including

 *   The mail from Rigo withdrawing his suggestion following my note to the group with a clarification
 *   The most recent submission following our call with Justin with additional wording on 'pseudonyized' . It also includes clarification on the purpose of AMR (see attached, text in red is new text not in the wiki version)
 *   A note to Jeff Chester clarifying part of the non normative text

I attach the email string below in advance of our call later today

Best regards

Kathy Joe
Received on Wednesday, 17 July 2013 13:47:00 UTC

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