Ms. Glasser,
Thank you for your comments (last June) on the Tracking Preference Expression Last Call Working Draft.
The decision to define the term tracking was previously resolved by the group; you do not provide new information to justify reopening this long-discussed issue. However, your concern about an exception for first party data is mistaken. The definition of tracking applies to all cross-context data collection and usage, and the group has determined that the use of data previously collected as a first party to target ads in a new context is not consistent with a Do Not Track request. Similarly, collection of data from widgets distributed around the web are defined as cross-context data collection in the specification, and thus are subject to DNT:1 requests.
The requirements on when user agents may send DNT:1 signals on behalf of a user as detailed in Section 4 of the TPE. The group previously rejected providing more detailed requirements; you do not provide new information or a proposal to cause us to reopen this issue. We revisited this issue during the Last Call process in considering a proposal to require information about the DNT setting party within the DNT field, but that proposal was rejected by the group.
See also: TPE Last Call comments, re: validation of user signals (issue-260)
https://lists.w3.org/Archives/Public/public-tracking-comments/2015Jun/0008.html
Please let us know whether these explanations resolve your concerns.
Thanks,
Nick Doty, W3C
(for Tracking Protection Working Group Co-Chairs: Carl, Justin and Matthias)