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RE: ACTION-75: Write-up a hybrid of Do Not Profile and Do Not Cross-Site Track

From: JC Cannon <jccannon@microsoft.com>
Date: Sun, 12 Feb 2012 22:42:59 +0000
To: Shane Wiley <wileys@yahoo-inc.com>, Lee Tien <tien@eff.org>
CC: John Simpson <john@consumerwatchdog.org>, Rigo Wenning <rigo@w3.org>, "public-tracking@w3.org" <public-tracking@w3.org>
Message-ID: <DB4282D9ADFE2A4EA9D1C0FB54BC3BD76E4D0640@TK5EX14MBXC139.redmond.corp.microsoft.com>
I think we got off track here. Let's go back to Rigo's statement below. Logs must be collected as part of the communication process. However, logs should not be processed if collected with DNT:1 even if DNT:0 is later sent.


-----Original Message-----
From: Shane Wiley [mailto:wileys@yahoo-inc.com] 
Sent: Thursday, February 09, 2012 9:29 PM
To: Lee Tien
Cc: John Simpson; Rigo Wenning; public-tracking@w3.org; JC Cannon
Subject: RE: ACTION-75: Write-up a hybrid of Do Not Profile and Do Not Cross-Site Track


Yahoo! amended our search data retention policy last year (18 months log retention then anonymization <4-factor>, anonymization of IP address at 6 months <full address, not only the last octet>).

- Shane

-----Original Message-----
From: Lee Tien [mailto:tien@eff.org]
Sent: Thursday, February 09, 2012 4:01 PM
To: Shane Wiley
Cc: John Simpson; Rigo Wenning; public-tracking@w3.org; JC Cannon
Subject: Re: ACTION-75: Write-up a hybrid of Do Not Profile and Do Not Cross-Site Track


I don't know the current time spans, but this blog post suggests that
18 months is quite a long starting point for thinking about a retention standard.


Even HR 1981, which if enacted would mandate data retention for commercial providers, was amended to 12 months.

Also, I'm now uncertain about Yahoo!'s policy.  I'd thought that


Under Yahoo's new policy, the company will strip out portions of users' IP addresses, alter small tracking files known as "cookies" and delete other potential personally identifiable information after 90 days in most cases. In cases involving fraud and data security, the company will anonymize the data after six months.
Sunnyvale, Calif.-based Yahoo also said it will expand the scope of data that it anonymizes to encompass not only search engine logs, but also page views, page clicks, ad views and ad clicks. That information is used to personalize online content and advertising.

Yahoo will begin implementing the new policy next month and says it will be effective across all the company's services by mid-2010.

[end quote]


I don't track this stuff regularly, though, so I might be missing something really obvious here.


PS  What one means by "anonymization" is of course a separate issue.

On Feb 9, 2012, at 1:08 PM, Shane Wiley wrote:

> John,
> The IP Address is only one field within a log file though.  Yahoo!  
> is anonymize at 6 months.  J
> - Shane
> From: John Simpson [mailto:john@consumerwatchdog.org]
> Sent: Thursday, February 09, 2012 11:44 AM
> To: Shane Wiley
> Cc: Rigo Wenning; public-tracking@w3.org; JC Cannon
> Subject: Re: ACTION-75: Write-up a hybrid of Do Not Profile and Do Not 
> Cross-Site Track
> Doesn't Microsoft delete IP addresses after six months? Google 
> "anonymize" after nine months? And yahoo "anonymize" after 90 days?
> On Feb 9, 2012, at 9:16 AM, Shane Wiley wrote:
> If we're going to use arbitrary time spans for retention, I would 
> recommend that we leverage 18 months as the standard.  This is the 
> time Google, MSFT, and Yahoo! currently use for search logs and have 
> shared this policy with all of the EU DPAs and A29WP.  As the 
> advocates in this working group will likely share the perspective of 
> wanting this to be lower in common with EU DPAs, it's a helpful 
> starting point.  Otherwise we can stop using arbitrary numbers and 
> leverage minimization principles instead - which I personally believe 
> are the better standard to apply to varied business models and can 
> stand the test of time and innovation.
> - Shane
> -----Original Message-----
> From: Rigo Wenning [mailto:rigo@w3.org]
> Sent: Thursday, February 09, 2012 9:06 AM
> To: public-tracking@w3.org
> Cc: JC Cannon
> Subject: Re: ACTION-75: Write-up a hybrid of Do Not Profile and Do Not 
> Cross-Site Track
> I concur JC,
> On Tuesday 07 February 2012 18:51:27 JC Cannon wrote:
> It seems that we are still conflating collection with receipt of logs 
> by a server and processing of those logs for placement in a profile or 
> otherwise.
> I believe we all agreed that web servers must be able to receive logs 
> in order for the Internet to work as it does. I would like to propose 
> that the mere receipt of logs by a web server should not be considered 
> collection or be constrained by the rules of collection.
> However, any processing of the logs should be considered collection 
> and be governed by our DNT standard.
> Inasmuch as the logs will include a DNT signal, any retention policy 
> that comes out of our standard should apply to those logs.
> Whereas 22 of the ePrivacy Directive says:
> The prohibition of storage of communications and the related traffic 
> data by persons other than the users or without their consent is not 
> intended to prohibit any automatic, intermediate and transient storage 
> of this information in so far as this takes place for the sole purpose 
> of carrying out the transmission in the electronic communications 
> network and provided that the information is not stored for any period 
> longer than is necessary for the transmission and for traffic 
> management purposes, and that during the period of storage the 
> confidentiality remains guaranteed. Where this is necessary for making 
> more efficient the onward transmission of any publicly accessible 
> information to other recipients of the service upon their request, 
> this Directive should not prevent such information from being further 
> stored, provided that this information would in any case be accessible 
> to the public without restriction and that any data referring to the 
> individual subscribers or users requesting such information are 
> erased.
> As long as we talk about some defaults for retention and logging for 
> the purpose of carrying out the communication, we shouldn't prevent 
> logging. I think our task is beyond. We MAY give some hint when we 
> believe those logs are not necessary anymore.
> So while writing logs is collection of data, we may declare normal web 
> logs out of scope as long as they do not serve to build profiles and 
> as long as they have some expiry set. (One may be as scared about logs 
> that last forever then I would be scared about profile creation)
> Consequently, a third party that is not in an outsourcing context may 
> not collect data beyond normal web logs and should anonymize or erase 
> those logs after 60 Days (just to throw in some arbitrary count) This 
> would be my suggestion.
> Best,
> Rigo
> ----------
> John M. Simpson
> Consumer Advocate
> Consumer Watchdog
> 1750 Ocean Park Blvd. ,Suite 200
> Santa Monica, CA,90405
> Tel: 310-392-7041
> Cell: 310-292-1902
> www.ConsumerWatchdog.org
> john@consumerwatchdog.org
Received on Sunday, 12 February 2012 22:43:56 UTC

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