RE: Frequency Capping

Tamir,

Many of us in industry are more than willing to look a privacy enhancing technologies and process approaches to diminish the perceived risks associated with Permitted Use practices.  The issue is speed to resolution significantly delaying completion of the DNT standard.  I've often advocated a dual-pronged approach to this issue:  move the current DNT specification to resolution with Permitted Uses and develop a secondary track to focus purely on Permitted Uses, Unlinkability, and privacy enhancing technologies to reduce dependency on unique IDs at scale.

I would recommend we immediately branch this effort to another email list and begin work in parallel (it's already started here).  We can bring in more technical experts, begin testing hypothesis and limited research in this area, build test platforms, and move forward with production testing to confirm concepts hold up under mass scale.  Attempting to wait out this entire process in-line with the current DNT standard conversation will push out completion many months (if not years as I don't believe this to be a one-time conversation and rather an on-going evolution of privacy preserving technical approaches).

- Shane

From: Tamir Israel [mailto:tisrael@cippic.ca]
Sent: Friday, July 13, 2012 11:07 AM
To: Mike Zaneis
Cc: JC Cannon; Shane Wiley; Roy T. Fielding; Peter Eckersley; W3C DNT Working Group Mailing List
Subject: Re: Frequency Capping

Mike,

If there is a solution to F-capping that does not require unique identification of users than this will dramatically cut down the amount of 'tracking' that can occur under DNT-1 state. As opposed to some other possible permitted uses, an F-capping exception will permit unique identification of every single individual regardless of DNT state.

Look, there's really only 1 question here: is industry willing to at least explore alternative technical solutions that allow f-capping w/out unique identification of users?

If the answer is no, that is very disappointing. If the answer is yes, than I refer you back to:
http://lists.w3.org/Archives/Public/public-tracking/2012Jul/0075.html

Best,
Tamir

On 7/13/2012 1:32 PM, Mike Zaneis wrote:
Tamir,

At the very first meeting last September this group addressed the fact that under any standard coming out of the W3C that there would still be some "tracking" even with DNT turned on. Newer participants will either have to get comfortable with that fact or the group will have to go back to the beginning.

Mike Zaneis
SVP & General Counsel, IAB
(202) 253-1466

On Jul 13, 2012, at 12:33 PM, "Tamir Israel" <tisrael@cippic.ca<mailto:tisrael@cippic.ca>> wrote:
On 7/13/2012 12:20 PM, JC Cannon wrote:
It is not practical to expect many consumers to go through and manage a list of third-party sites. Even the small number of educated users won't understand all the third parties on a site. Consumers have to feel that when they visit a third-party site that their privacy will be protected and if not, that they have some recourse to address any harm.

That too : )



Moreover, I feel we should be addressing whether or not frequency capping is a permitted use and not spending time trying to design it in this working group.

JC -- I personally don't think it should be a permitted use, primarily because it allows for the possibility of 'tracking' in scenarios where a user has expressed their desire not to be tracked. Some others have expressed strongly their impression that some form of F-capping is necessary even in a DNT-1 state. The hope is that there is a technical solution to resolve this impasse.

Best,
Tamir



JC

From: Tamir Israel [mailto:tisrael@cippic.ca]
Sent: Friday, July 13, 2012 9:01 AM
To: Shane Wiley
Cc: Roy T. Fielding; Peter Eckersley; W3C DNT Working Group Mailing List
Subject: Re: Frequency Capping

Shane,

Your brick and mortar example to me highlights very precisely the problem here. The fact that Walmart chooses to carry Raisin Bran in addition to Lucky Charms (no accounting for taste : P) does not initiate any type of interaction between me and Raisin Bran. Just between me and Walmart and, if I'm hungry as I walk past the cereal section, me and Lucky Charms.

My expression of 'do not track me' should be able to encompass this type of model.

So, I should be able to say: I don't want to be tracked by anyone, but I'll grant an exception to yahoo and adobe (because I trust them), but not to 'financial-credit-profile-builder' (because I don't trust them). Making a list of third parties easily discoverable won't quite get us there because it targets the first party, whereas the potential bad behaviour and incentives need to be applied to the third parties. Therefore: a.) there is no way for me to communicate to the first party that my problem isn't with 98% of the third parties they're using to monetize, but only with x and y; and b.) there will not be any competitive pressures on particular servers to behave well (maintain anonymous cookie ID, for example).

Best,
Tamir

On 7/12/2012 4:19 PM, Shane Wiley wrote:

Tamir,



You've interacted with those 3rd parties as a part of your interaction with the 1st party -- as that 1st party has partnered with those 3rd parties to provide its services to you (monetization, analytics, content, widgets, etc.).  If a 1st party is transparent about those 3rd parties it works with (and/or highly discoverable through already existing web browser tools), is it fair to say you still have a choice at that point to decide to continue to interact with that 1st party?  If you disagree with a 3rd party's ability to maintain an anonymous cookie ID in relationship to the services its providing to the 1st party, you do not need to interact with that 1st party.  The choice is yours.



If there were true "harms" involved, then you may look at this through a slight different lens, but that has yet to be established.



To use a brick-n-mortar example, you do not have a right to require Wal-Mart carry a specific brand of cereal you may really like (your desire vs. their business obligation).  If you're unhappy with Wal-Mart due to this choice, you can decide to not shop at Wal-Mart.



- Shane



-----Original Message-----

From: Tamir Israel [mailto:tisrael@cippic.ca]

Sent: Thursday, July 12, 2012 12:56 PM

To: Roy T. Fielding

Cc: Peter Eckersley; W3C DNT Working Group Mailing List

Subject: Re: Frequency Capping



On 7/12/2012 3:12 PM, Roy T. Fielding wrote:

Yes, and it has been rejected many times because the ID cookies are

used by other features that won't be turned off by DNT.



Not so. I have never interacted and have no relationship with third

party server X. Why does it need to be able to identify me in any way?