Issue-22, Still have "operational use" of data

Issue-22, Still have "operational use" of data (auditing of where

ads are shown, impression tracking, etc.)

Draft: Sid Stamm

Edit: Shane Wiley



In order to not "break the Internet" and still protect consumer privacy concerns, it will be necessary to provide operational

purpose exemptions for necessary business activities when the DNT signal is on. There are several key categories of data collection and use that must remain intact such that web site operators who are (in the vast majority) offering their services free of charge in exchange for advertising on their properties:



> Frequency Capping - A form of historical tracking to ensure the number of times a user sees the same ad is kept to a minimum.



> Financial Logging - Ad impressions and clicks (and sometimes conversions) events are tied to financial transactions (this is how online advertising is billed) and therefore must be collected and stored for billing and auditing purposes.



> Aggregated Reporting - Similar to Financial Logging, as advertising is a billed event it must be reported on to advertisers. This does not occur at a "per user" level.



> 3rd Party Auditing - Online advertising is a billed event and there are concerns with accuracy in impression counting and quality of placement so 3rd party auditors provide an independent reporting service to advertisers and agencies so they can compare reporting for accuracy.



> Security - From traditional security attacks to more elaborate fraudulent activity, ad networks must have the ability to log data about suspected bad actors to discern and filter their activities from legitimate transactions. This information is sometimes shared across 3rd parties in cooperatives to help reduce the daisy-chain effect of attacks across the ad ecosystem.