TPWG Public Comment on DNT Standard

Dear TPWG Members:

I want to direct everyone's attention to this WSJ article
<http://online.wsj.com/article_email/SB1000142412788732409640457835453301095
8940-lMyQjAxMTAzMDEwMTExNDEyWj.html>  that highlights the issues with
"first" and "third" parties.  While a technical standard must be
implemented, it should be consistent with consumer expectations, not warped
into something that continues to obfuscate data collection from consumer,
publisher and advertiser scrutiny.  Privacy preference management is
typically assumed to be between the consumer and the website (or brand) by
most people.  Only highly informed individuals realize that every time they
"click" on something they could be dealing with a "new" first party and that
their data may now be collected by some unknown entity ­ even though their
intent was not to share, or only to share with the trusted brand or site.

I am a marketer and I understand the implications of this kind of change, as
do other marketers as noted in this recent AdExchanger article
<http://www.adexchanger.com/data-driven-thinking/please-track-me/> .
Marketing will adapt ­ it always has.  I hope you will incorporate this
reality into the final standard, as it represents a key issue driving the
need for a DNT standard.  We are only at this point and requiring a standard
because one small, but powerful group of marketers is hiding behind the tech
and not treating the collection and distribution of people's personal
information with respect.  This is not new, and has been happening since
long before the internet - with the selling of snail mail list for profit
without the consumer's knowledge or consent.

The consumer is not "the customer" of data aggregators, ad exchanges, ad
networks or profiling companies.  Their customers are the publishers/sites
and advertisers who utilize these services.  These companies care deeply
about customer loyalty and their brands.  They are becoming more aware of
how their marketing data is collected and the risks it may cause their
organizations.  If their data management practices willingly or
inadvertently undermine the trust they work so hard build with their
customers, then the whole system comes crashing down and they'll simply find
a different method for spending their ad dollars in a way that better
supports their business objectives.   Better to adapt in a controlled
fashion than have it ripped out from under us.

Thank you for your consideration as you work to bring this standard to
conclusion,

Liz Coker