Re: transitivity of DNT exceptions

Nick, I think this goes even beyond what data protection authorities have been discussing. They would allow for an ad-network to be "authorised" on via website and use data cross-sites.

We need to discuss this with our members, as we see the transpositions across the EU/EEA to not be coherent or consistent.

Kind regards,
Kimon

Kimon Zorbas Vice President IAB Europe

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----- Reply message -----
From: "Nicholas Doty" <npdoty@w3.org>
To: "Tracking Protection Working Group" <public-tracking@w3.org>
Cc: "Matthias Schunter" <mts-std@schunter.org>
Subject: transitivity of DNT exceptions
Date: Wed, May 9, 2012 7:45 am



After some discussion of transitivity of exceptions on last week's call and some follow-up with Matthias, it sounds like there might be interest in specific exceptions (that might help with EU or other jurisdictions) for top-level third parties. For example, maybe a large site could more easily specify the ad networks or exchanges it works with in requesting an exception (such that those domains receive a DNT:0 opt-in signal) and then all further re-directs would also be excepted, because the further third-parties aren't using the data for any additional purposes (via some version of our Outsourcing exception, and perhaps fitting an EU "data processor" definition).

Does this sound workable for interpretations of EU law? For site or browser implementers?

Do we see other definitions of "transitivity of exceptions" that would be useful? Browsers could, for example, send DNT:0 to all resources that are re-directed from a request that was initiated with DNT:0, but that sounds both annoying to implement (for browser plug-ins, for example) and sometimes specifically not the intent of an exception (URL re-direction services, maybe).

Thanks,
Nick

(This isn't meant to duplicate Ian's action-194, though maybe it will be related.)