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Re: SOX Requirements RE: ACTION-216 - Financial Reporting "Exceptions"

From: Tamir Israel <tisrael@cippic.ca>
Date: Sun, 29 Jul 2012 12:58:17 -0400
Message-ID: <50156BA9.9050205@cippic.ca>
To: Shane Wiley <wileys@yahoo-inc.com>
CC: Lee Tien <tien@eff.org>, Craig Spiezle <craigs@otalliance.org>, 'Chris Mejia' <chris.mejia@iab.net>, 'David Wainberg' <david@networkadvertising.org>, 'Jonathan Mayer' <jmayer@stanford.edu>, "'Dobbs, Brooks'" <Brooks.Dobbs@kbmg.com>, "public-tracking@w3.org" <public-tracking@w3.org>, 'Nicholas Doty' <npdoty@w3.org>
On 7/29/2012 12:22 PM, Shane Wiley wrote:
> (b) if so, does the retention requirement apply to the actual ad-serving transactional records that are generated by users' interactions with 3rd-party ad networks/companies?
> (Part of what I'm asking is what data/records the companies are currently retaining because of Sarb-Ox compliance -- and also, I think, the legal standard that defines the compliance line.)
>
> [Yes - as this is considered a "receipt" of the transaction as it's the billed element.  It's like asking if a grocery store must keep a record of each item purchased or if they can simply say a customer spent X in their store.  When ads are sold by impression - each impression must be retained to prove its validity and to be the actual record of receipt.]
>
> (c) if so, must the records contain user- or device-identifying information, or is that unnecessary?
> (Again, the legal standard may be ambiguous, but it would be helpful to know what that legal standard is....
>
> [Alteration of a legal record could be considered "evidence tampering" and therefore companies tend to stay on the conservative side of this line.]

This is where you lose me. If, as Jonathan and others have suggested, it 
is possible to confirm the # of transactions without unique IDs, why 
would the SEC care if you are or are not collecting identifiers? To pick 
up your grocery store example, no one forces Walmart to force customers 
to present a drivers license as a condition of cash payments....

Best,
Tamir
Received on Sunday, 29 July 2012 16:59:03 UTC

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