Re: Examples of successful opt-in implementations

It's important to disentangle the third-party and first-party components of the ePrivacy Directive.  Quite a few participants, myself included, have suggested we should carefully consider facilitating third-party compliance.  I've heard a few discussions about first-party compliance, but none treating it as more than a possible repurposing of the DNT protocol.

Jonathan

On Wednesday, June 13, 2012 at 2:47 PM, Ian Fette (イアンフェッティ) wrote:  
> We agreed it was directed at third parties, however it seems some people (as we heard on the call today) are trying to turn DNT into something to solve opt-in problems, presumably for first parties as well. I'm trying to figure out how much of hole we're getting dug into :)
>  
> "No one has managed to figure this out in a deployable manner. Please give us a solution by 1 January 2013" is a bit of a frightening thought :)
>  
> -Ian
>  
> On Wed, Jun 13, 2012 at 2:30 PM, Jonathan Mayer <jmayer@stanford.edu (mailto:jmayer@stanford.edu)> wrote:
> > The cookie manager widget at http://www.bt.com/ seems passable.  
> >  
> > At any rate, I'm unsure where this line of inquiry is going.  We've already agreed that Do Not Track is directed towards third parties, not first parties.  
> >  
> > Jonathan
> >  
> > On Wednesday, June 13, 2012 at 3:18 PM, Dobbs, Brooks wrote:
> >  
> > > Ian,
> > >  
> > > I would say that I have seen some sites that are arguably one step closer, though not truly opt-in.   
> > >  
> > > If you look at http://www.nectar.com/ you’ll see a similar disclosure to that on the FT, but with a Cookie Consent link that takes you to a cookie inventory with a place for the status of each cookie and the purpose of each cookie.  Now while they get points for making a greater effort, I would say that the final result seems fairly problematic as: 1) though the site lists 52 cookie issuers, my personal packet sniff showed both that they included cookies that I didn’t come across (no problem - I didn’t actually read every page) AND missed cookies that I did come across (problem) and 2) a number of the 52 cookies issuers where listed as having “undisclosed” purposes with a specific inability to offer choice.   
> > >  
> > > So even if they took the particularly consumer annoying step of making the user go through 52 pop-up, opt-in screens, they still would not be opt-in compliant.
> > >  
> > > Not trying to pick on them, just pointing out that, as you seem to suggest, we aren’t seeing a lot of (any?) real opt-in compliant websites in the wild, and that the closer they get, the more troubles they seem to make for themselves.    
> > >  
> > > -Brooks
> > >  
> > >  
> > > On 6/13/12 3:26 PM, "Ian Fette   (イアンフェッティ)" <ifette@google.com (http://ifette@google.com)> wrote:
> > >  
> > > > Out of curiosity, on today's call two examples of "successful" opt-in implementations were given.
> > > >  
> > > > 1. was the financial times - http://www.ft.com/home/us. This shows a popup saying the following: "FT Cookie Policy
> > > > We have published a new cookie policy. It explains what cookies are and how we use them on our site. To learn more about cookies and their benefits, please view our cookie policy.
> > > >  
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> > > >  
> > > > Before you even accept anything, I counted 40 cookies being set, including 18 from Financial Times. FT itself used HTML5 local storage in addition to the 18 cookies.
> > > >  
> > > > 2. The other was the UK CIO's site -- this seems to be down at the moment. www.cio.gov.uk (http://www.cio.gov.uk) <http://www.cio.gov.uk>  redirects to some archive page. Taking another government site as an example, I see 7 cookies including GUIDs from http://www.cabinetoffice.gov.uk/content/privacy-policy
> > > >  
> > > > So, I'd like to re-raise my question of whether anyone has actually successfully managed to deploy an opt-in compliant website in the wild...
> > > >  
> > > > -Ian
> > > >  
> > >  
> > > --  
> > >  
> > > Brooks Dobbs, CIPP | Chief Privacy Officer | KBM Group | Part of the Wunderman Network
> > > (Tel) 678 580 2683 (tel:678%20580%202683) | (Mob) 678 492 1662 (tel:678%20492%201662) | kbmg.com (http://kbmg.com)  
> > > brooks.dobbs@kbmg.com (http://brooks.dobbs@kbmg.com)
> > >  
> > >  
> > >  
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> >  
>