Re: Request for comments on priorities for DNT

As members of the Online Publishers Association, The Walt Disney Company supports this set of priorities.

Ted Leung
Director, Advanced Technology
The Walt Disney Company

From: Chris Pedigo <CPedigo@online-publishers.org<mailto:CPedigo@online-publishers.org>>
Date: Friday, December 7, 2012 5:56 AM
To: Peter Swire <peter@peterswire.net<mailto:peter@peterswire.net>>, "public-tracking@w3.org<mailto:public-tracking@w3.org>" <public-tracking@w3.org<mailto:public-tracking@w3.org>>
Subject: RE: Request for comments on priorities for DNT
Resent-From: <public-tracking@w3.org<mailto:public-tracking@w3.org>>
Resent-Date: Friday, December 7, 2012 5:57 AM

Here are the priorities for the Online Publishers Association:


1)             Consistent with the FTC’s framework as laid out it in its 2012 report, DNT should reflect the unique relationship that consumers have with first parties.  Consumers have choices about where they can find content of interest to them and they do choose to visit these sites.  DNT should not limit first party data collection or use.  DNT could be a useful tool in providing consumers with choice with regard to third party data collection.  Similarly, DNT should be consistent with the FTC’s guidance that certain commonly accepted practices do not need to be subject to a choice mechanism.

2)             DNT should not be overly prescriptive in describing the methods of restricting third party data collection.  Any voluntary standard must allow for different ways to achieve compliance and for companies to develop new privacy-friendly methods that minimize data collection or improve privacy protections.

3)             This working group should seek to build on successful self-regulatory efforts.  Most companies have already taken voluntary efforts to limit data collection and use.  Companies that are compliant with self-regulatory efforts are unlikely to abandon these privacy-friendly practices in favor of a DNT standard that includes contradictory terms, definitions and scope.  Building a DNT standard that is complimentary to self-regulatory efforts is the clearest path to wide-spread adoption of DNT.

Chris Pedigo
VP, Government Affairs
Online Publishers Association
(202) 744-2967




From: Peter Swire [mailto:peter@peterswire.net]
Sent: Wednesday, November 28, 2012 4:43 PM
To: public-tracking@w3.org<mailto:public-tracking@w3.org>
Subject: Request for comments on priorities for DNT

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<http://www.peterswire.net>