- From: Vinay Goel <vigoel@adobe.com>
- Date: Thu, 21 Jun 2012 12:16:11 -0700
- To: "Roy T. Fielding" <fielding@gbiv.com>
- CC: Tracking Protection Working Group <public-tracking@w3.org>
- Message-ID: <CC08C0F1.E3DA%vigoel@adobe.com>
Very raw notes… First Party - Not too much debate on first parties - One area without a resolution is appending 3rd party (offline) data o Most don’t think its within the scope of tracking o Maybe its not a good fit within DNT o May be a privacy concern, but not a DNT issue o DNT is ‘stateless’ technology discussing a specific transaction, this is beyond that o Possible for any party to add additional rules based on jurisdiction; but DNT is the baseline rule - Frank’s goal: not to restrict the usage of a DNT signal for a first party o This is our goal, but it’s a may not a must o Wewant to codify here the common ground o First partys can choose to do more if they receive DNT:1 - First party cannot share (send) data with a 3rd party if that other party is not a first party or service provider - Sending o Cannot ‘send’ - First Party responsibility 1: o If you receive DNT:1, you cannot facilitate sharing with a 3rd party for data profiling - Can first parties enforce compliance for third parties on its site? o There are other ways to protect data on its site o Its impractical to ask first parties to police its 3rd parties o DNT is a signal to me as a user to interact with that site o Can’t feasibly bar first party to tell data to third party - What are the obligations of a first party if they say they’re DNT complaint? o The only obligation it has is to not facilitate third party tracking o The first party has a really hard time telling third parties who’s on its site o First party has no restrictions on receiving/using data for its own purpose o Material difference between going to BlueKai to get data about them and getting data from a service provider like Acxiom o First party gives data to 3rd party data vendor; cannot be used for any purpose other than getting data back from the vendor o If the third party isn’t on the site, there is no way for it to ‘come back to the user’ with response headers o Imagine I’m a website. I know their IP address because I get that. I can use a service to see if this IP address has been involved in any attacks. This service responds yes or no. Is that allowed? § It should be, but may need to be parked because it’s a use case we haven’t thought through yet o FB: We should not prohibit first parties from sending the data to a 3rd party § It doesn’t care about how the user sends the data on to a 3rd party - We NEED TO TAKE CARE OF PRODUCT FULFILLMENT USE CASE - Would first parties store DNT flag within log files? o Tat would require some significant infrastructure changes o JC: This should be in the standard log files o FB: The fact that I’m in seattle and sent a bunch of messages isn’t assocatiated with the DNT header o JC: When I’m processing that one server log and see the DNT header, then I can record it o FB: Because you’re a first party, there should be no prohibition on sharing o Susan: What I’ve understood the requirement to be is that the first party cannot share the data with third parties to enhance/augment profiles o Privacy advocates have said that its not enough to get consent by agreeing to Terms of Use/Privacy Policy - Is ‘share’ button a consent mechanism? o But, does that include whether I’m in seattle when I share it? - DNT shouldn’t affect the first party’s broader ability to do business - Maybe suggest to the group that being in a logged-in state may impact the application to DNT - Question is: To what extent is it practical to restrict a first party from sharing data with third parties (who are not a service provider) when the first party receives a DNT:1 signal? o What they are trying to get at is trying to create a work-around from having the third party on the site directly - A first party cannot subvert DNT by intentionally sending data to a third party that the third party would have received directly itself if it was present on the page itself o Cannot help a third party bypass the DNT signal o Someone is going to have to audit against DNT whether that will have force § Priority should be simple and clear that users, sites, auditors can check it § Point of non-consensus, but am moving on - DNT is flagged within the logs, and when the application is processing the logs, you look to see whether the use is affected by DNT. If so, honor it; if not, don’t honor it. o In private discussions, regulators get that o Don’t include that data within the permitted uses Permitted Uses - Add product fulfillment - Fraud - needs to be broad - Security - needs to be broad - Transactional - needs to be broad - Contextual serving - Aggregate Reporting - Analytics o Some analytics – needs further clarification - De-identified - Legally required purposes - Product debugging and improvement - Service monitoring - Hard part is ‘retention’ - Can’t limit all retention to 2 weeks - Perhaps can use some technical and process rules to limit access to the data - Whole argument for permitted uses is: you can’t keep the information that long otherwise it will be abused o Instead, we should be addressing the abuse o Have good standards for re-identification if it is retained - People do not believe that we will limit access to use data appropriately - Long-tail publishers need longer retention periods because they need it to retain diversity/known audiences. Cannot do it with 2 weeks of data. Got to have tools to sell inventory toadvertisers - “What’s protected depends a lot on who’s looking” - Can’t make ‘absolute’ standards. Need to do it with reasonable protections and limitations - In any of these, there needs to be a path for innovation. - Market Research - Define terms for which it means to put data in ‘databases’. There can be separate records for each permitted use - “Access controls and technical mechanisms” - Frequency capping (should be a broader category for which that falls) – maybe campaign management o Needs to be spelled out further - Making sure that two competing advertisers ads aren’t side by side/on the same page o Can this be contextual advertising? o Content delivery management § Conflicting advertisers § Advertisers don’t want to be on certain pages - Reading the FTC’s accepted practices Third Party - when you’re a third party, you can’t write to a profile Service Provider - Under contract that prohibits the data for its own purpose except for permitted uses - Contract needs to say that the services provided need to act on its behalf and have the same obligations As part of a relationship with a 3rd party on its site, you ‘ask’ that it be compliant with the specs - From the EU perspective, it’s the websites responsibility at the end, not the responsibility of the ad network - To the extent that you have a relationship with the third party, ask that the third party be compliant From: "Roy T. Fielding" <fielding@gbiv.com<mailto:fielding@gbiv.com>> To: Vinay Goel <vigoel@adobe.com<mailto:vigoel@adobe.com>> Cc: Tracking Protection Working Group <public-tracking@w3.org<mailto:public-tracking@w3.org>> Subject: Re: Meeting Notes from the Text only, please. ....Roy On Jun 21, 2012, at 11:22 AM, Vinay Goel wrote: Here are our group's meeting notes. -Vinay ________________________________ Confidentiality Notice: The contents of this e-mail (including any attachments) may be confidential to the intended recipient, and may contain information that is privileged and/or exempt from disclosure under applicable law. If you are not the intended recipient, please immediately notify the sender and destroy the original e-mail and any attachments (and any copies that may have been made) from your system or otherwise. Any unauthorized use, copying, disclosure or distribution of this information is strictly prohibited. <ACL> <Team Meeting Notes.docx>
Received on Thursday, 21 June 2012 19:16:42 UTC