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Re: ACTION-110: Write proposal text for what it means to "not track" (ISSUE-119)

From: Ninja Marnau <nmarnau@datenschutzzentrum.de>
Date: Mon, 13 Feb 2012 18:14:19 +0100
Message-ID: <4F3944EB.1040804@datenschutzzentrum.de>
To: Shane Wiley <wileys@yahoo-inc.com>
CC: "<public-tracking@w3.org> (public-tracking@w3.org)" <public-tracking@w3.org>, Tom Lowenthal <tom@mozilla.com>
Hi Shane,

I understand your concerns that this may only apply to a few self hosted 
websites or privacy aware companies.

Is there an option to losen the requirements in a way that does not 
exclude 3rd party hosted sites?

- Ninja

Am 13.02.2012 17:44, schrieb Shane Wiley:
> Ninja,
> I agree with the sentiment (and that this should continue to be a response option) but want to call out that most small publishers do not have the ability to manage data collection at this level as they typically purchase hosting services from a 3rd party provider (often from their domain mgmt vendor).  It will take time for 3rd party providers to update their environments (if they even feel compelled) to allow for a strict "no collection" position so we shouldn't expect that this option will be used very often outside of highly technical, privacy sensitive, small web site publishers.
> - Shane
> -----Original Message-----
> From: Ninja Marnau [mailto:nmarnau@datenschutzzentrum.de]
> Sent: Monday, February 13, 2012 9:10 AM
> To:<public-tracking@w3.org>  (public-tracking@w3.org); Tom Lowenthal
> Subject: ACTION-110: Write proposal text for what it means to "not track" (ISSUE-119)
> Here is my proposal for a definition of "absolutely not tracking":
> A party may claim that it is not tracking, if it
> 1) only collects identifying data which is strictly necessary to answer
> the user's HTTP request and to fulfil it's contractual obligation
> towards the user
> 2) does not send, collect or check for unique identifiers
> 3) does not correlate the data of a DNT HTTP request with any other data
> 4) deletes the identifying data as soon as the original purpose is fulfilled
> Motivation:
> This should be a starting point fo discussing a possible response header
> (This site does not track at all) fo very small websites that do no
> profiling or customisation at all. Currently, these websites have only
> the option to state within the response header that they comply with DNT
> and may use all the exceptions of the standard. This should not
> necessarily indicate that sites which do not adhere to the points above
> are tracking their users.
> -Ninja


Ninja Marnau
mail: NMarnau@datenschutzzentrum.de - http://www.datenschutzzentrum.de
Telefon: +49 431/988-1285, Fax +49 431/988-1223
Unabhaengiges Landeszentrum fuer Datenschutz Schleswig-Holstein
Independent Centre for Privacy Protection Schleswig-Holstein
Received on Monday, 13 February 2012 17:12:14 UTC

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