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Re: ACTION-172: Write up more detailed list of use cases for origin/origin exceptions

From: Rob van Eijk <rob@blaeu.com>
Date: Sat, 05 May 2012 18:02:03 +0200
Message-ID: <4FA54EFB.30305@blaeu.com>
To: public-tracking@w3.org
Overlap with explicit-explicit exception pairs:
See also the crosslink: 


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

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