Re: Request for comments on priorities for DNT

Dear Peter,

1. No linkable data collection when DNT=1. Matching (unique) identifiers 
are essential when it comes to user profiling, (micro)segmentation and 
(micro)optimization, (re)targeting, mapping user IDs between platforms, 
(real-time) buying and selling of data, end-user privacy controls, 
frequency capping of ads, web analytics, on-line advertising attribution 
and verification, web metrics, focus-group calibration etc. The digital 
marketing-list goes on and on, and innovation will add new business 
models. Whether matching (distinct) unique identifiers are used for each 
business purpose, or whether the future will standardize towards a 
single ID, the point is that when DNT=1, it means do not collect, by 
default.

2. Add proportionality to the global requirements (No Secondary Use, 
Data Minimization and Transparency,Reasonable Security,No 
Personalization) for permitted uses. It is a cornerstone principle in 
modern privacy thinking. When this group is truly looking for consensus 
on data processing practices, the proportionality of the determined 
business purposed and the means used to accomplish these must be taken 
into account.

3. Interoperability and meaningfulness. Being conformant to the W3C 
standards still leaves the gap to become legally compliant. Revisiting 
the party definitions, and align them with the EU concept of data 
controller/processor is going to make it easier to close that gap.

Regards,
Rob

On 28-11-2012 22:42, 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