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RE: June Change Proposal: Section 2

From: Amy Colando (LCA) <acolando@microsoft.com>
Date: Wed, 26 Jun 2013 12:59:51 +0000
To: "public-tracking@w3.org public-tracking@w3.org" <public-tracking@w3.org>
Message-ID: <81152EDFE766CB4692EA39AECD2AA5B61EB0ACC4@TK5EX14MBXC295.redmond.corp.microsoft.com>
SECTION 2: DEFINTIONS

We propose modifying the definition of "share" as follows:  A PARTY "SHARES" DATA IF IT TRANSFERS OR PROVIDES A COPY OF DATA THAT IT HAS COLLECTED TO ANY OTHER PARTY"
o	Rationale: This definition was previously submitted by a small group of participants.  The definition of "share" (or "pass") is used in reference to First Party obligations under the Specification.  The rationale behind preventing sharing is preventing circumvention of restrictions on Third Parties by allowing First Parties to collect information and then pass that information on to third parties.  However, the original text was sufficiently broad that it could be read to cover the independent and direct collection of data by Third Parties (e.g., when a third party ad network is collecting data on a publisher site because of its ad delivery activities)
o	Elsewhere in the specification, we should use a single term "share" or "pass" as those two verbs appear to be used interchangeably at present, or an ISSUE should be opened to define PASS.


We recommend that the last sentence in the "party" definition regarding a "list of affiliates" be deleted.

o	Rationale: We do not understand why it is necessary to be able to provide a list of all affiliates, and instead believe it would be sufficient to determine the corporate entity that owns or operates the domain.  The current text is not clear as to whether the "single click" requirement is globally required for all DNT implementers, or only necessary when common party status is relied upon. In addition, the overly prescriptive requirement of "a single user interaction from each page" is unworkable in practice and unlikely to be helpful to users who are likely to be looking in a single place for explanation as to DNT implementation.  We therefore propose that the method of how parties may choose to make the list of affiliates "easily discoverable" be left to an implementation guide.  If participants desire to retain a text in the specification, the section could be modified as follows:  "For unique corporate entities to qualify as a common party with respect to this document, those entities MUST be commonly owned and commonly controlled and MUST provide easy discoverability of affiliate organizations; FOR EXAMPLE, A LIST OF AFFILIATES THAT IS AVAILABLE VIA A LINK FROM A RESOURCE WHERE A PARTY DESCRIBES DNT PRACTICES WOULD BE CONSIDERED EASILY DISCOVERABLE."
Received on Wednesday, 26 June 2013 13:01:17 UTC

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