RE: Evolving Online Privacy - Advancing User Choice

Thank you Rob.  Looking forward to chatting more about proportionality offline and integrating those points into the proposal where appropriate.

- Shane

From: Rob van Eijk [mailto:rob@blaeu.com]
Sent: Wednesday, June 20, 2012 10:02 AM
To: Jason Bier
Cc: Mike Zaneis; Shane Wiley; public-tracking@w3.org; Edward W. Felten; Jonathan Mayer; Jeffrey Chester
Subject: 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@01CD4ECD.4D1052B0]

From: Mike Zaneis [mailto:mike@iab.net]
Sent: Wednesday, June 20, 2012 9:55 AM
To: Shane Wiley
Cc: public-tracking@w3.org<mailto: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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