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Re: Feedback on Proposed Plan from IAB, DAA, DMA and NAI

From: Matthias Schunter (Intel Corporation) <mts-std@schunter.org>
Date: Tue, 17 Sep 2013 13:47:35 +0100
Message-ID: <52384F67.9010201@schunter.org>
To: public-tracking@w3.org
Dear Chris, and members of IAB, DAA, DMA, and NAI,


thanks a lot for the hard work to produce this timely feedback on the 
poll and
plan.

As indicated, our goal was to improve the plan and we have incorporated 
feedback
wherever possible.

FEEDBACK: [Ad 9] Clear and sufficient deadlines when closing issues:"

RESPONSE: As suggested by Shane, I will make 2 changes to the plan:
- Closing issues must be announced in writing
- There must be 14 calendar days between announcement
and the deadline for objections/comments.

FEEDBACK: [Ad 2] Ensure that no definitive decisions (on issues) are 
executed before the
results of the poll has been obtained

RESPONSE: This is good feedback. Note that we understood this concern 
and therefore
did not plan to close controversial issues before October 23 (2 weeks after
the poll). Formally, this means that we will not issue a call for 
objections
while the poll is still open.

FEEDBACK: [Ad 4] Consensus and decision making [...]

RESPONSE: Our goal is to close issues based on consensus. Ideally, all
participants will be able to live with a single agreed-upon proposal 
that is
then included into the ED. In cases where this is not possible, we decided
to use the “call for objections” to determine consent. In this process, the
substance (not the number or the vigor) of objections will be assessed
against the charter and our goals to determine consensus.
---

In addition to these high-level responses, I added some in-line comments 
below.

Note that as a chair, I am only defining how the working group will 
proceed.
Success (or failure) will depend on the participants in the Working Group.

I hope that this addresses some of your concerns and I appreciate 
further input and
feedback.


Regards,
Matthias

=============== Detailed [[Comments]] In-Line ==============

Dear TPWG Chair, W3C Staff, and fellow TPWG Members,
 >
 > In accordance with the September 13th deadline for feedback on "the 
proposed
plan", I respectfully provide the following feedback on the proposed 
plan and
process:
 >
 > IAB, DAA, DMA, and NAI incorporates by reference, their objections 
submitted on
July 12, 2013.
See http://www.w3.org/2002/09/wbs/49311/datahygiene/results.
 >
 > In addition to renewing their objections to the use of the Editors' 
draft as the
basis for moving forward, IAB, DAA, DMA, and NAI also respectfully 
submit the
following feedback in opposition to proceeding with the proposed plan:
 >
 > 1. Genuine Working Group consensus cannot be achieved through the 
proposed
plan and it remains entirely unclear what "consensus" means or how it is
reached.

[[Thanks for this input. Note that it is important to raise these points
individually in the poll. “This process of arbitrary decision making 
will likely
create a disjointed patch-work document that would be neither the 
product of the
working group nor a cohesive compliance document that could be adopted.”

I fully understand this concern, but believe that we have defined a 
process that
leads to reasoned, non-arbitrary decisions. I sincerely hope that we do 
not need
many “call for objections” and that the ones that we need will lead to a
comprehensive document. The Chairs plan to guide the Working Group toward a
cohesive document. and would appreciate everyone’s help in doing so. 
When we ask
for a consensus for the Last Call document, the WG will be able to 
assess whether
we succeeded.

Note that our “call for objections” is inspired by the decision 
procedure in the
HTML5 group where it has worked in the past. ]]

 >
 > 2. The Due Dates suggest that the Poll is an exercise in futility.
 >
 > Because the W3C is proceeding with Option 1 prior to the opening of 
the poll
to discuss other options, it is apparent that the W3C is intent on moving
forward with the proposed plan regardless of the outcome of the Poll. "The
clear recommendation from the Chair/Staff is to make progress with 
Options 1 or
2." (Sep. 3, 2013 email from M. Schunter to public-tracking@w3.org). We
note that Option 2 only pushes out the hard issues to a later version of 
the
standard. Unfortunately, the hard issues, those that cannot find 
consensus, are
at the heart of the standard itself. Indeed, the W3C has suggested that the
technology is not ready for a DNT standard: "Thus, we are focused on the
appropriate DNT solution for release in 2013-14 which we call DNT 1.0. As
technology and user references evolve, we fully expect that there will be
further releases that address scenarios that are not well addressed today."
(Sep. 3, 2013 email from M. Schunter to public-tracking@w3.org)(emphasis
added). DAA, IAB, NAI, ANA, AAAA, DMA object to the W3C's approach of 
moving
forward before the analysis of the poll results.

[[While we are proceeding our preparations in parallel with the poll and 
the
beginnings of ordinary issue-resolution, no decisions will be finalized 
on that
timeline before the poll results are available to be assessed. The 
intent of the
“V2.0” is not to push all hard issues to a later time – I agree that 
many hard
issues are at the heart of the standard. The idea was rather that pieces 
where no
one has sufficient implementation experience or where no one has a sound 
proposal
how to potentially resolve this issue should be pushed to V2.0. I agree 
with you
that in both cases (with and without V2.0), we have to tackle many of 
the hard
issues that are at the core of this standard. ]]


 > 3. Move the issue closing process to one based on membership voting. 
This
would fast track the process and could still allow for a formal objection
process to follow. This mirrors the escalation structure to ACRs and has 
been
discussed in the past. This process would be limited to W3C membership 
as they
represent actual implementers of standards.

[[While we agree that agreement among a subset of the stakeholders would 
be easier to
achieve, W3C’s definition of “consensus” is broader
http://www.w3.org/2005/10/Process-20051014/policies.html#Consensus. At 
this point
in time, I would like to stay true to our charter and aim for broad 
stakeholder
support since this is the unique opportunity offered by this forum (as 
compared to
pure industry forums)]]

 > 5. Participation

[[I would like to refer to our W3C team for the details on participation. I
personally would appreciate broader participation of “the companies 
likely to be
most impacted economically”. If your organisations can help increasing this
support, it would clearly expand the expertise in this group. ]]

 >
 > 6. Charter
 > a. What is the meaning of "The Working Group will not design
mechanisms for the expression of complex or general-purpose policy
statements."

[[Personally, as far as I remember, this statement was meant to indicate
that we do not aim at another version of “P3P” and rather focus on
privacy issues and signalling that is related to tracking and targeting. ]]


 > c. What is the meaning of "The group will actively engage
governmental, industry, academic and advocacy organizations to seek
global consensus definitions and codes of conduct."

[[IMHO, the broad stakeholder participation that we managed to achieve 
in the
current set up of the group. ]]

 > 7. What are the criteria and milestones for continuing or winding 
down the
group, if progress is not made?

[[This will be decided by the W3C Director and management, based on our 
progress, the
outputs of the poll, and any other information available to him.]]

 > 8. W3C process requires an implementation and testing phase. How will 
this
apply to the compliance specification? Can elements of the compliance spec
become "features at risk"? What about crucial elements of the technical 
spec
that are closely coupled with the policy?

[[Like all other recommendations, the compliance spec will be tested as 
usual in W3C
to allow us to further improve this recommendation. ]]

 > 9. Provide detailed timelines and decision criteria for each Formal
Objection being considered prior to requesting WG input.

[[It is important to distinguish “calls for objection” and “Formal 
Objections”. Calls
for objection, as described in the Plan, have timelines with clear 
periods for
objections with reasoned responses. “Formal Objections,” as defined in 
the W3C
process, are requests that the Director consider an objection when a 
Working Group
product comes to him for decision. For the former (“Call for 
objections”), we have introduced
a 14day response time to accommodate your concern. The latter is defined 
by W3C.]]

 > 10. More firmly state within the updated plan that driving towards a 
standard
that will achieve broad industry adoption is a core goal (otherwise, why 
are we
here?).

[[Our current goal is to achieve broad stakeholder adoption. At this 
point in time,
we would like to define a standard that all stakeholders can live with. 
Depending
on the outcome of the poll and the option that the director chooses, 
this may
change. ]]

 >
 > 11. We need clear criteria for reopening issues. The "new 
information" standard
is overly vague and inconsistently applied.
AFAIK, this is standardprocedure for W3C. If nothing has changed, why 
re-open an
issue?



 > 12. We need assurances about the process for closing issues, including
addressing the problem of having to continually raise and re-raise 
issues. We
need a predictable, rational process for bringing issues to close.

[[The proposed plan provides a predictable process to raise and close 
issues.]]

 > 13. What is the status of the global considerations effort?

[[According to Rigo (its lead), the Global considerations work is paused 
for the
moment, because the situation around the EU regulation is unclear. Any 
help with
this is welcome. But for the moment, all effort is concentrated on 
advancing the
formal deliverables of the Group (TCS & TPE). The Global considerations 
work can
be revived if there is sufficient interest. This could start with writing a
document explaining how to use Do Not Track in non-US jurisdictions. Any 
help
with this is welcome. ]]

 > 14. Who is the new co-chair? It is impossible to express our faith or 
lack of
it in the poll without knowing who will co-lead the group going forward.

[[We hope to announce this Wednesday after the respective organisations 
have OK-ed
their chairing. ]]

 > 15. What is the status of FTC participation, and who is speaking for 
the FTC?
Is Ed Felton speaking for FTC? Or Paul Ohm?

[[When they speak up, individuals from the FTC usually indicate whether 
they are
speaking in a representative or individual capacity. ]]

 >
 > 16. What is the status of the PAG?

[[The PAG is still running and has new information. Rigo Wenning, the 
PAG Chair plans
to reconvene a meeting in the near future. At the moment, he is 
investigating
feedback on Prior art. A DRAFT PAG report could be available next month 
if the
inquiries are conclusive. ]]
Received on Tuesday, 17 September 2013 12:48:07 UTC

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