Re: 4A's Comments to W3C TPWG Final Call

Hi Peter,

Thank you for your comments (last June) on the TPE Last Call Working Draft.

The question of how to ensure the validity of DNT signals is not a new one for the group.  Section 4 of the TPE provides requirements for user agents in ensuring that signals reflect the preference of the user. Additional requirements were suggested during the Last Call process; however, a proposal to include information about DNT-setting party within the DNT signal was rejected by the Working Group. You do not propose any other alternative approach.

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

The group has also spent a great deal of time deliberating over to whom DNT signals should apply. The definitions of "parties" and "context" have been settled, and you do not provide information to reopen those definitions, only a conclusory statement that they may be subject to "varied interpretations."

Your statement that the DNT standard exempts certain companies is incorrect --- the rules apply regardless of the size of an organization. Moreover, under the terms of the companion TCS document, companies may not use data previously collected as a first party in new contexts to target advertisements.

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)

Received on Sunday, 12 July 2015 21:28:49 UTC