- From: (unknown charset) Justin Brookman <justin@cdt.org>
- Date: Thu, 09 Feb 2012 18:17:31 -0500
- To: (unknown charset) public-tracking@w3.org
I disagree with this statement. The FTC has announced five criteria necessary for "Do Not Track" to be successful; the fourth is that "Do Not Track" needs to address collection as well as usage. Similarly, the Article 29 Working Party identified failure to address collection/retention as a limitation in the existing DAA opt-out framework. So it is not at all correct to state that regulators are only interested in use limitations. That said, I think these regulators have also recognized that a complete prohibition on third-party collection is not practical or desirable. Given that the standard currently recognizes that third parties are frequently going to be allowed to obtain uniquely-identifying user agent strings despite the presence of a DNT:1 header, I personally don't think that fixating on client-side versus server-side solutions for frequency capping or conversion reporting is all that important. However, that does argue for the need for accountable statements on the part of complying third-parties (whether through a response header or something else). Justin Brookman Director, Consumer Privacy Center for Democracy& Technology 1634 I Street NW, Suite 1100 Washington, DC 20006 tel 202.407.8812 fax 202.637.0969 justin@cdt.org http://www.cdt.org @CenDemTech @JustinBrookman On 2/9/2012 5:50 PM, Matthias Schunter wrote: > Hi Team, > > for DNT-related data, Roy's assessment of the key regulatory concerns > matches my experience > > Regards, > matthias > > On 2/9/2012 10:49 PM, Roy T. Fielding wrote: >> Judging from my personal discussions with regulators, I would not >> say that data collection constraints are a significant concern. >> Data sharing (on purpose or by failure to handle it properly) is >> the primary concern. Data retention beyond that necessary to >> support user-consented operational uses, or in a form that is >> unnecessary to support operational uses, is a concern. >> Obtaining specific and informed consent is a concern. > > >
Received on Thursday, 9 February 2012 23:18:00 UTC