- From: Rob van Eijk <rob@blaeu.com>
- Date: Sat, 05 May 2012 18:02:03 +0200
- To: public-tracking@w3.org
Overlap with explicit-explicit exception pairs: See also the crosslink: http://lists.w3.org/Archives/Public/public-tracking/2012May/0089.html Rob On 4-5-2012 0:05, Rob van Eijk wrote: > Explicit/explicit gives Controllers the opportunity to signal which > 3rd parties are processors. Because the controller determines the > purpose and means, controller is responsible for valid consent in the EU. > > So my use case [A] would be: a DNT:0 signal sent to the limited and > known list of processors, who are bound by a legal contract, i.e. the > processor agreement. In my opinion, this is not the use case to use > the '*' parameter, i.e. MUST NOT be used. In this case the list > [Inc_A,Inc_B,...,Inc_Z] SHOULD/MUST be used. > > Use case [B]: a DNT:0 signal to service providers, not being > processors, but as a result controllers themselves or in some cases > joint controller. It could be useful, but I haven't given it a lot of > thought. My assumption for DNT:0 to be useful in this scenario is that > the browser reflects user consent. This implies that the user has made > an informed choice, preferably in the install/update flow of the > browser to use DNT technology as a granular consent expression mechanism. > > Rob > > > On 2-5-2012 9:54, Nicholas Doty wrote: >>>> * Separate data controllers in EU jurisdictions >>>> >> A DNT:0 signal sent to a third-party service in the EU might >>>> usefully be interpreted as consent for independent use by that >>>> thid-party (that the service would itself be a data controller, not >>>> just a processor). EU regulations, however, may require that this >>>> consent be specific to the party rather than site-wide. (Suggested >>>> by Ninja, who may be able to add more detail.) >>> > > Importance: Medium >>> > > Design Notes: >>> > I agree that being able to provide consent via DNT is useful. I >>> cannot >>> > judge what extent explicit/explicit is needed or whether a site-wide >>> > exception would also be considered consent. An important question in >>> > this use case is what responsibilities (under EU law) are implied >>> from >>> > the corresponding "Trust myself and my third parties" statement. >> I also welcome input from Ninja, Rob and others on this issue. >> > > >
Received on Saturday, 5 May 2012 16:02:31 UTC