Re: Evolving Online Privacy - Advancing User Choice

Shane,

One major goal of your contribution was to explain [non-normative] why 
the processing with unique identifiers is proportionate.
In Washington we talked about a template. This contribution is however 
lacking any subsidiary arguments and there is no balance against the 
interests of a user.
Instead, the contribution is a firmer confirmation of the DAA multi-site 
principles.
Hope to learn more later on today, when your proposal is on the agenda.

Rob

-----Original Message-----
From: Rob van Eijk [mailto:rob@blaeu.com]
Sent: Thursday, April 12, 2012 1:27 PM
To: Shane Wiley
Subject: Template non-normative text

Shane,

(...)
In this spirit, the template I propose for the non-normative section
without making it a legal analysis, is:

- Start with a detailed business purpose (note: singular) description
(ie what is it that is permitted)
- Describe which categories of data will be tied to a identifier
- Explain why the processing with identifiers is proportionate
(proportianality test) and explain the alternatives (subsidiarity test)
for processing (ie why do you need a car if you can use a bycivle)
- Describe reasonable technical and organizational safeguards to prevent
further processing (e.g. by collection limitations, data silo,
authorization restrictions, k-anonimity, unlinkability, retention time,
anonimization, pseudonimization, data encryption etc.). I think our
report on TomTom [2],[3 page 13-14] is an interesting example to
correctly anonimize and aggregate a dataflow.

Finally,
- Take*all*  the above into account and describe the impact on the
privacy of the user (eg what is the harm). This is a key balancing
element.

Regards::Rob



On 20-6-2012 9:42, Jason Bier wrote:
>
> I would like to thank Shane for sending this as well and for Mike's 
> statement.  ValueClick also supports the industry proposal.  In the 
> spirit of cooperation and advancing interests on this matter, I hope 
> all of us can advance the process and find a solution that results in 
> meaningful adoption by a significant portion of the online advertising 
> industry.
>
> Jason
>
> **
>
> *Jason J. Bier, Esq., CIPP*
>
> *Chief Privacy Officer*
>
> *ValueClick, Inc.*
>
> *o: 312-588-3619*
>
> *f: 312-896-7422*
>
> cid:image001.png@01CCE0B7.B73DCF20
>
> *From:*Mike Zaneis [mailto:mike@iab.net]
> *Sent:* Wednesday, June 20, 2012 9:55 AM
> *To:* Shane Wiley
> *Cc:* public-tracking@w3.org
> *Subject:* Re: Evolving Online Privacy - Advancing User Choice
>
> Thank you for sending this Shane. While there are still some items we 
> would like to see in the two documents that might not be reflected in 
> the current industry proposal, in the spirit of cooperation and 
> advancing the process IAB supports this approach. I look forward to 
> discussing it this week.
>
> Mike Zaneis
>
> SVP & General Counsel, IAB
>
> (202) 253-1466
>
>
> On Jun 20, 2012, at 12:05 AM, "Shane Wiley" <wileys@yahoo-inc.com 
> <mailto:wileys@yahoo-inc.com>> wrote:
>
>     TPWG,
>
>     Please find attached the detailed proposal text we'll be reviewing
>     tomorrow afternoon (built upon the proposal outline I provided
>     last week).
>
>     The following individuals, companies, and trade associations
>     contributed to this proposal:
>
>     Marc Groman & David Wainberg -- NAI
>
>     Alan Chapell -- Chapell & Associates
>
>     Heather West, Sean Harvey, & Ian Fette -- Google
>
>     Shane Wiley -- Yahoo!
>
>     There is considerable detail covering numerous topics in this
>     proposal and therefore it should not be consider an endorsement by
>     all contributors to all parts of this proposal.  That said, all
>     contributors generally agree with the direction and approach of
>     this document.
>
>     We look forward to further discussion and fielding questions
>     tomorrow afternoon.
>
>
>     Thank you,
>     Shane
>
>     <Evolving Online Privacy - Advancing User Choice - W3C Seattle.docx>
>
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