Re: ISSUE-16, ACTION-166: define (data) collection

On Jun 1, 2012, at 10:21 AM, Rigo Wenning wrote:

> you were complaining about the fact that being "exposed" to data is often 
> interpreted as "collection".

Actually, I was complaining that the current definition in the
compliance spec is wrong because it says that collection happens
when I am merely exposed to data.  Nobody in the real world
equates exposure with collection.

> A definition that is tautologic doesn't solve 
> your issue. A definition that imports hairy problems of identification into 
> the definition isn't buying you peace either.

We know what "data" means without a specific definition in the
standard.  We know what "collection" means without a specific
definition in the standard.  The only reason we might want to
define "data collection" in the standard is if we have something
more specific in mind than the mere conjoining of those two
words would explain.  For example, if we want to apply
requirements to a specific sort of data being collected (PII)
or a specific mechanism of data collection (cookies) such that
readers are not confused by all the other forms of data collection
that are not constrained by this standard.

As I said, I have no need of a definition.  I object to having
an incorrect definition and then applying requirements to it
that are nonsensical based on that incorrect definition.

> So I suggest to define 
> "collection" for the sake of both Specifications as a process of the fact of 
> receiving, storing into memory and processing data for purposes other then 
> erasing.

That doesn't sound like collection to me.  That is using.

> BTW, the definition of collection is just that. It doesn't say anything 
> about the collection being legitimate or not. This is subject to other parts 
> and rules. 

Yes, my objection is based on how it is used throughout the rest
of the document.  If we don't use it, then we don't need a definition.
If we do use it, then we either need a correct definition or no definition.

....Roy

Received on Friday, 1 June 2012 18:13:34 UTC