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RE: Deciding Exceptions (ISSUE-23, ISSUE-24, ISSUE-25, ISSUE-31, ISSUE-34, ISSUE-49)

From: Shane Wiley <wileys@yahoo-inc.com>
Date: Wed, 8 Feb 2012 13:08:17 -0800
To: Rigo Wenning <rigo@w3.org>
CC: "public-tracking@w3.org" <public-tracking@w3.org>, "Roy T. Fielding" <fielding@gbiv.com>, Jonathan Mayer <jmayer@stanford.edu>
Message-ID: <63294A1959410048A33AEE161379C8023D0C8ACAFB@SP2-EX07VS02.ds.corp.yahoo.com>
Many of the 3rd party companies that DNT targets operate in both regions and therefore apply the same rules across their business practices.  

Attempting to arbitrarily set limitations on a business's implementation of frequency capping (what data is collected and used may vary by system although general elements will remain the same) will be difficult to capture in a manner that doesn't have unintended consequences (in either direction).  A prohibition that data only used for this very specific use and no other is a better application of the goals of the working group (this all started with OBA but we've clearly continued to down the slippery slope to halt all data collection).

As for user memory, I would argue memory is much longer than 2 days - especially if a user is seeing the same ad over and over again within a given month on a heavily used site.  Again, we're back to arbitrary assessments - this time of a human's ability to remember something.  

- Shane    

-----Original Message-----
From: Rigo Wenning [mailto:rigo@w3.org] 
Sent: Wednesday, February 08, 2012 12:50 PM
To: Shane Wiley
Cc: public-tracking@w3.org; Roy T. Fielding; Jonathan Mayer
Subject: Re: Deciding Exceptions (ISSUE-23, ISSUE-24, ISSUE-25, ISSUE-31, ISSUE-34, ISSUE-49)

On Wednesday 08 February 2012 12:33:32 Shane Wiley wrote:
> EU law requires each company retain data only for as long as it's needed for
> the intended purpose for which it was acquired.  This in essence is the
> minimization principle - and is tied to each company's unique and
> individual business models.

US law doesn't. So you would suggest DNT would following the finality principle 
for the frequency capping. This has actually not only one implication but two. 
You indicated only one in your previous email. 
The first implication, as you said, is that data is only kept as long as 
necessary for the purpose for which it was collected. But the second 
implication is as important: collect only the data that is absolutely needed 
for the intended purpose. And I think some of the researchers here debate 
whether all the collection is really needed for frequency capping. 

Why is it so important to have the capping during the entire add campaign? 
Ninja said "per session" as users don't remember after one or two days anyway. 


Received on Wednesday, 8 February 2012 21:09:39 UTC

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