Global considerations delta document: audience measurement research

Hi Rigo,


Here is the text re audience measurement research for global considerations
document also attached as a word doc:
 
Article 6(1)(b) of the EU Privacy Directive allows further processing for
'historical, statistical or scientific purposes' supported by recitals (29
and 30) on appropriate safeguards.

 

Article 6(1e) allows data to be stored for longer periods for historical,
statistical or scientific and member states to prescribe appropriate
safeguards. 

 

Art 11.2 enables data to not have been obtained from the data subject for
statistical, historical or scientific research if there are appropriate
safeguards. Recital 40 provides that 'it is not necessary to [provide notice
to the data subject] if they already have the information' and that 'there
will be no such obligation if the recording or disclosure are expressly
provided for by law or if the provision of information to the data subject
proves impossible or would involve disproportionate effort, which could be
the case where processing is for historical, statistical or scientific
purposes; 

 

Article 13.2 allows member states to restrict Article 12 re access and
erasure of data for historical, statistical and scientific research as long
as there are no privacy risks and 'appropriate safeguards' are applied by
ensuring that the data will not be used to support measures or decisions
regarding any particular individuals subject to member states.

 
Similar conditions are also contained in Articles 5(e), 6.2 and Article 83
of the proposed GDPR.
 
Text regarding safeguards provided by anonymisation, and
pseudo-anonymisation is included in the Art29WP Opinion on personal data
(2007) and the ArtWP29 Opinion on purpose limitation wrt historical,
statistical or scientific purposes (2013).
 
 
Kathy Joe,
Director, International Standards and Public Affairs


From: Rigo Wenning [mailto:rigo@w3.org]
To: public-tracking-international@w3.org
Cc: Nicole Nauen [mailto:nicole.nauen@nugg.ad]
Sent: Tue, 02 Apr 2013 15:40:29 +0100
Subject: Delta Document

Dear all, 

as we agreed at the Berlin meeting, before making any further decision, we
wanted to see the deltas to the EU environment and potential areas of
issues. 

As promised, I made a first Draft that is now open for comment and
improvement: 

http://www.w3.org/2011/tracking-protection/1303-gloco-delta.html

You can either comment in email to the list or you can import the HTML into
your favorite word-processing tool and activate the change-control
or you can edit the html with a text editor and markup your changes with
<ins></ins> and <del></del> and send me the resulting page per email.

All people with CVS access can directly edit the source file while
respecting the change-control indicated above.

Please comment by Tuesday next week as I want to have a first round of
comments before scheduling a teleconference.

--Rigo


> From: Kathy Joe [mailto:kathy@esomar.org]
> To: adam.phillips@realresearch.co.uk, Elise.Berkower@nielsen.com,
> rweaver@comscore.com, david.stark@gfk.com, George.Pappachen@kantar.com
> Cc: k.smouter@esomar.org, F.Raben@esomar.org
> Sent: Wed, 03 Apr 2013 15:22:52 +0100
> Subject: Follow up from last week and a call with Rigo Wenning
> 
> Dear All,
> 
> I attach the notes from last weeks W3C call and a follow up conversation with
> Rigo Wenning who contacted us, acting as a go-between for Rob van Eyck. Finn
> participated in the call with Rigo.
> 
> It was agreed that whilst not including commercially sensitive info, we should
> provide clarification on:
> 
> * Use of word Œpseudonymisation¹ (KJ: Do we need to adjust definition?)
> * Kind of data that is collected and stored (KJ: Do we need to define what is
> excluded?) 
> * Why word Œpanel¹ closes door to bad payers (KJ: Do we need to say why this
> will not be misused?)
> Timing: discuss at next W3C f2f meeting but as budgets are stretched and this
> restricts participation, would we prefer to do it in online if possible?
> Other topics raised by Rob van Eyck:
> ·  If MR permitted use over-rides the user DNT choice, how does this meet EU
> law which requires information and consent for placing cookies and collecting
> and storage of personal data?
> ·  How can Out of band consent work for panels if the MR company cannot check
> if it has consent in real time? Do they collect and hold the data (without
> consent as in preferred use)? Are they then collecting richer data sets that
> are destroyed if the consent cannot be confirmed?
> Please could you indicate your availability on this doodle
> http://doodle.com/b5eaixzc8bdqubia
> We will probably need an hour to go through this plus discuss next steps re
> Firefox DNT.
> I also attach the notes from last week's call so you can see the range of
> concerns aired. We are getting  closer but still need to do some work to
> ensure they understand audience measurement research, but also how we want to
> deal with EU law as this came up in the recently distributed global
> considerations doc. which I will send separately
> Many thanks
> 
> 
> Kathy Joe 
> 
> 
> 
> 
>