Re: Request for comments on priorities for DNT

1. A meaningful compliance document is essential. If we were to finalize
the DNT standard with a polished TPE but a watered down or non-existent
compliance document, then only a guise of a standard will have passed,
and users will lose as a result since they will only have
pretend-privacy. This is a worse outcome than no DNT standard at all.

2. Unique ids should not be allowed without more evidence. The issue of
collecting unique ids for DNT:1 users by third parties needs to be
discussed thoroughly. This is an essential issue at the core of
tracking. What are the exact reasons that unique ids -- unique cookies,
browser fingerprints, etc* -- ostensibly need to be collected for a
DNT:1 user? Absent strong evidence, we need to ensure a standard which
does NOT allow the collection of unique ids for DNT:1 users.

3. Defaults. We must respect user choice for DNT. Without prescriptively
specifying user agent implementations of DNT, we need to come to some
consensus on what is reasonable behavior for user agents (and publisher
exceptions) with respect to how DNT is presented to the user. I posted a
query to the list earlier about a user agent with a "forced choice"
implementation, in which there is no default but a user affirmatively
must choose a DNT setting (on, off, or unset). This could happen in a
browser, for example, as a user sets up her browser profile for the
first time. I find it hard to believe that anyone would argue against
such an implementation, but I would like to ensure consensus here so
that we can avoid later being mired in endless finger-pointing about
non-compliant user agents.

* To clarify: IP addresses and other protocol data from HTTP are NOT
considered unique ids.



On 11/28/2012 01:42 PM, Peter Swire wrote:
> To Tracking Protection Working Group:
>
> First, let me once again echo the thanks that many of you have given
> to Aleecia for her service with this group.  I have found Aleecia
> unfailingly gracious and fair in her dealings with me, and I am glad
> she is planning to continue to share her insights with the group as we
> move forward.
>
> As mentioned on the weekly call today, to assist me in getting up to
> speed, the Working Group chairs solicit input from participants, with
> comments due by noon Eastern time on Wednesday, December 5.  The
> intent would be to discuss these comments on the December 12 call.
>
> We ask that you emphasize no more than 3 points and do your submission
> in no more than 300 words.  (To help you be brief, we will prioritize
> in our reading the comments that comply with the limits.)
>
> As you make these points, we are interested in what you think are the
> priority points for the co-chairs to consider, including: areas of
> agreement, what principles should guide our work, and what will best
> bring the new co-chair up to speed.
>
> (If this request for comments feels vague or not precise enough, my
> apologies.  It perhaps is a sign of my lack of experience with
> defining problems within the W3C procedures.  The basic idea, however,
> should be clear -- what are the priority things for the new co-chair
> to know.)
>
> Please post your comments to this email list.
>
> In looking forward to working with you all,
>
> Peter
>
>
>
> Professor Peter P. Swire
> C. William O'Neill Professor of Law
>     Ohio State University
> 240.994.4142
> www.peterswire.net


-- 
Dan Auerbach
Staff Technologist
Electronic Frontier Foundation
dan@eff.org
415 436 9333 x134