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Re: June Change Proposal, Geolocation

From: David Singer <singer@apple.com>
Date: Fri, 21 Jun 2013 11:43:43 -0700
Message-id: <0B20ADE6-2368-4EA1-8ECB-A50225ED9B2F@apple.com>
To: "public-tracking@w3.org List" <public-tracking@w3.org>
It's been pointed out to me that an alternative is to make it clear that the Geolocation section is a specific addition to the general requirements on non-tracking, rather than a replacement or relaxation.  That would be fine.

On Jun 20, 2013, at 16:48 , David Singer <singer@apple.com> wrote:

> This web site might provide some idea why I fear that 'allowing' postal-code (zip-code) granularity might not be OK
> 
> http://localistica.com/usa/zipcodes/least-populated-zipcodes/
> 
> 
> On Jun 20, 2013, at 15:29 , David Singer <singer@apple.com> wrote:
> 
>> Problem
>> 
>> Section 5.3: 
>> "If a third party is part of a network interaction with a DNT: 1 signal, then geolocation data must not be used in that interaction at any level more granular than postal code, unless specific consent has been granted for the use of more granular location data."
>> 
>> 
>> 1) This suggests that Geolocation data can be treated differently. Though it deserves careful handling, I am not sure it's qualitatively different.
>> 2) This is actually weaker than the definition of 'tracking' for the cases of postal codes with few inhabitants.
>> 
>> 
>> Proposal
>> 
>> 1) Delete 5.3
>> 2) Insert after the definition of 'tracking':
>> Note:  Geolocation data requires careful handling, as in some cases it can be combined with other readily available data to identify a specific user, user-agent, or device.
>> 3) In the accompanying non-normative text, expand on the explanations of why geolocation data needs treating with kid gloves.
>> 
>> David Singer
>> Multimedia and Software Standards, Apple Inc.
>> 
>> 
> 
> David Singer
> Multimedia and Software Standards, Apple Inc.
> 
> 

David Singer
Multimedia and Software Standards, Apple Inc.
Received on Friday, 21 June 2013 18:44:11 UTC

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