Issue 74: Are surveys out of scope & Issue 34: Exemption for aggregated data

Submission for W3C on behalf of Research Industry
Issue URL:
  http://www.w3.org/2011/tracking-protection/track/issues/74
Section number in the FPWD:
Contributors to this text: (Draft) Kathy Joe, (Edit) Alexandros Deliyannis in consultation with CASRO (Council of American Research Organisations)

Issue 74: Are surveys out of scope - close; covered under Issues 25 and 34.

Issue 34: Exemption for aggregated data - Aggregated data is permissible for purposes such as research, industry trends, and analytics. Parties wishing to use aggregated data must take reasonable steps to ensure that data does not reveal information about individual users, user agents, or devices and it must not be possible to identify an individual with aggregated cross site data.

Description: The research client wants statistical measurements of how many users have been exposed to their campaigns in broad categories across different sites. The client will for instance place the research company's tags on their ads on one or more sites that count viewers based on cookies. Any identifiers are removed as soon as the data has been sorted into broad categories eg country.

Suggestion/Example: ExampleResearch collects data for ExampleProducts Inc. which is running an ad campaign online on various sites. It gathers cross-site data on how often a user views a relevant ad but none of their other web behaviour. The purpose is to fulfil a request by a first party (the advertiser), and the results are shared only with the first party.

The output is restricted to aggregated and unidentifiable data, will not impact a user's experience, use is only for the statistical research purpose and cannot be linked to a specific user, computer or device and cannot be used for profiling. Identifiable data will be held as long as the campaign runs to provide consistent data and then all identifiers will be removed after a reasonable period.

Kathy Joe
Professional Standards & Public Affairs Director
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