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Re: Questions/Comments on the current Compliance Spec Draft

From: David Singer <singer@apple.com>
Date: Mon, 23 Sep 2013 11:39:27 -0700
Message-id: <B3AE90BF-14E2-43E9-92D6-577099589F22@apple.com>
To: "public-tracking@w3.org List" <public-tracking@w3.org>
Hi Vinay, friends

Matthias asked me to take a look, as one of the editing team, and suggest what was editorial and what you should probably raise an issue about.

Here are my suggestions.  Unless you, or anyone in the group, objects, we'll do the editorials in about a week's time.  (Note, this isn't a hard deadline, as reversing an editorial change can easily be done, and an issue raised, if we later realize that the edit had implications we had not realized.)


On Sep 18, 2013, at 9:41 , Vinay Goel <vigoel@adobe.com> wrote:

> Comment 1 — I believe Editorial:  Section 2.8 — Deidentified
> - Current text: "commits to try not to reidentify the data;"
> - Comment: First off, the spec uses 're-identify' in #3.  So I'd suggest switching to re-identify for consistency.  Second, the current language is a tongue twister.  Instead, would something like "Commits from trying to re-identify the data" or "Commits to not trying to re-identify the data"?  I believe both capture the same intent but are clearer to read.

clearly editorial, suggest:  
  "commits to make no attempt to re-identify the data" (reduce the number of verbs)

> Comment 2 — I believe both Editorial and Structural: Section 2.10 — Definition of Collects
> - Current Text: "A party collects data if it receives the data and shares the data with other parties or stores the data for more than a transient period."
> - Comment: This sentence has unclear conjunctions.  I think it would help a lot if you add 'either' between 'and' and 'shares'.  Second, I would change the sentence to "A party collects data if it receives the data and either shares the data or stores the data for more than a transient period." Since Shares is defined below, do we need to restate 'with other parties'?  Third, personally, I feel like the idea 'stores the data for more than a transient period' is 'retaining the data'.  Is there a reason why you don't use 'retain' here?

deal with the editorial:
  A party collects data if it receives the data, and either shares the data with other parties, or stores the data for more than a transient period.

On possible confusion between collection and retention, an issue would be needed.


> Comment 3 — I believe Editorial: Section 2.10 — Definition of Uses
> - Current Text: "A party uses data if the party processes the data for any purpose other than storage or merely forwarding it to another party."
> - Comment: Again, I think we need to add 'either' between 'than' and 'storage'.  Otherwise, is the or between storage and forwarding or processes and forwarding.

I think editorial:
  A party uses data if the party processes the data for any purpose other than either storage or merely forwarding it to another party.

> Comment 4 — Questions on language: Section 2.10 — Definition of Shares
> - Current Text: "A party shares data if the party enables another party to receive or access the data."
> - Comment: Why do we say 'receive or access the data' instead of 'collects, retains or uses'?

Issue needed. This is not editorial.

> Comment 5 — Questions on language / editorial / content: Section 4 — First Party Compliance
> - Current Text: "…first party MAY engage in its normal collection and use of information."
> - Comment:  What if the first party's norma collection is to share it with 3rd parties for reselling purposes?  I know there are limits in the next paragraph on passing information to other parties, but why even set this up?  Why not just say something to the effect of "If a first party receives a DNT:1 signal, the first party MAY collect, retain, and use information to customize the content, services and advertising in the context of the first party experience."?

Issue needed.  This is not editorial.

> Comment 6 — Questions on language / editorial / content: Section 4 — First Party Compliance
> - Current Text: "The first party MUST NOT pass…"
> - Comment:  Why pass and not share here?  Pass is undefined, whereas share is defined.  Seems like we should be using defined terms when possible.

Issue needed.  This is not editorial.

> Comment 7 — Questions on language / editorial: Section 4 — First Party Compliance
> - Current Text: "First parties may elect to follow third party practices."
> - Comment:  I think this is worded badly.  I don't think this language is necessary.  But, without fighting that battle, how about "A first party MAY elect to follow the rules outlined for a third party within this specification."

I would leave out "outlined" or use "defined" or the like; probably editorial:
  "A first party MAY elect to follow the rules defined here for third parties."

(I agree, it's silly to say it.  We are about saying where the fence is;  of course you can stay well within the fence.)

> Comment 8 — Third Party Compliance
> - Current Text: "Further, parties may collect, use, and retain such information to comply with applicable laws, regulations, and judicial processes."
> - Comment: I get what you're trying to do here, but this language should be done in both First Party compliance and Third Party compliance. Otherwise, its odd to have just 'parties' here in a section titled 3rd Party compliance.  Also, I think its worth calling out 'share' here.

Suggest editorial, and just move this sentence so it's clearly general:
  "Notwithstanding anything in this specification, parties may collect, use, share, and retain information required to comply with applicable laws, regulations, and judicial processes."

But this is closer to the border, and could be an issue if anyone wishes.

> Comment 9 — Third Party Compliance
> - Current Text: "… So long as the information is not transmitted to a third party…."  (in the 6th paragraph)
> - Comment: Why not just say share here?

Issue needed.  This is not editorial.

> Comment 10 — User-Granted Exceptions
> - Current Text: "… Recommendation …."  (last sentence of the first paragraph)
> - Comment: Why are we calling it a recommendation here but call it a standard in the first sentence of the next paragraph?

Editorial. W3C issues recommendations, not standards.
  globally replace "this standard" with "this recommendation".

David Singer
Multimedia and Software Standards, Apple Inc.
Received on Monday, 23 September 2013 18:40:08 UTC

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