RE: Issue-17, Issue-51 First party obligations

I agree with everyone on the chain thus far and believe if we're successful in crafting 1st and 3rd party definitions appropriately, DNT rules should naturally support the "agency/service provider/vendor" model - which is all an Ad Exchange is as it has no data ownership/control of its own (in EU terms - a data processor).  I'm speaking for RightMedia in this case but believe this is true of other Ad Exchanges as well such as AdX and AppNexus.

I suggest we round on this as a use case after we narrow in on the party position definitions to make sure this works as intended.  Fair?

- Shane

From: JC Cannon [mailto:jccannon@microsoft.com]
Sent: Tuesday, November 29, 2011 11:26 AM
To: Jeffrey Chester
Cc: John Simpson; <public-tracking@w3.org> (public-tracking@w3.org)
Subject: RE: Issue-17, Issue-51 First party obligations

I agree that those are worthwhile issues to address. I'm just concerned that if we continue to broaden our scope we won't meet our goal of finishing our work by July 2012.

JC
Twitter<http://twitter.com/jccannon7>

From: Jeffrey Chester [mailto:jeff@democraticmedia.org]
Sent: Tuesday, November 29, 2011 6:51 AM
To: JC Cannon
Cc: John Simpson; <public-tracking@w3.org> (public-tracking@w3.org)
Subject: Re: Issue-17, Issue-51 First party obligations

If a DNT system is to work, it must address how first party sites incorporate third party data and also use ad exchanges.  If a user has said they do not want to be tracked via a third party data service, such as eXelate, BlueKai or Experian (for example) then such user data should not be automatically imported or used by the First party site.  Sites increasingly mix in-house data with third party targeting data.  A user should have reasonable control of this process under DNT.



Jeffrey Chester
Center for Digital Democracy
1621 Connecticut Ave, NW, Suite 550
Washington, DC 20009
www.democraticmedia.org<http://www.democraticmedia.org>

On Nov 28, 2011, at 7:59 PM, JC Cannon wrote:

John,

I believe we are already in agreement that DNT will not apply to 1st party sites. I understand the need to clarify that 3rd-party sharing will be limited to certain exceptions, but I don't want to revisit something we have already agreed on.

JC
Twitter<http://twitter.com/jccannon7>

From: John Simpson [mailto:john@consumerwatchdog.org]
Sent: Monday, November 28, 2011 4:47 PM
To: <public-tracking@w3.org<mailto:public-tracking@w3.org>> (public-tracking@w3.org<mailto:public-tracking@w3.org>)
Subject: Issue-17, Issue-51 First party obligations

Colleagues,

I've been thinking a bit more about the idea of "1st Party" obligations if we use the frame of a 1st Party and 3rd Party distinction.  It seems clear to me that there is consensus that the 1st Party must not share data (some will say there are exceptions) with a 3rd party when DNT is enabled.

It does seem to me there are further obligations.  When I go to a 1st party  site and interact with it, I assume it is using my information for that transaction.  If I
have DNT enabled, I don't have ANY expectation that it will continue to use that information beyond that transaction.  The site should ask me if it can continue to store the information and use it beyond that specific visit to the site.

In other words from my perspective as a user, a 1st Party site should treat me as if I had cleared all my cookies the next time I visit the site if I have DNT enabled.

When DNT is enabled, a 1st party should treat each session with a user as an entirely new session unless it has been given permission to store his information and use it again.

73s,
John
----------
John M. Simpson
Consumer Advocate
Consumer Watchdog
1750 Ocean Park Blvd. ,Suite 200
Santa Monica, CA,90405
Tel: 310-392-7041
Cell: 310-292-1902
www.ConsumerWatchdog.org<http://www.ConsumerWatchdog.org>
john@consumerwatchdog.org<mailto:john@consumerwatchdog.org>