Re: transitivity of DNT exceptions

Hi Kimon,

I believe that this also holds for DNT with transitive exceptions:
- If an ad-network receives an exception, this holds for its descendants
too (the transitivity)
- These third parties are then exempted from the DNT constraints and can
use the collected data as before
- This includes cross-site use among sites where a user has agreed to an

E.g., if a user granted a site-wide exception at site1 and site2 and
both use an adnetwork adnet1 then adnet1 can correlated the data
collected at site1 and site2. However, if a user has not granted a
site-wide exception for site3, then the data collected via site3 is
still constrained by DNT and must not be pooled for cross-site use.


On 09/05/2012 19:46, Kimon Zorbas wrote:
> 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" <>
> To: "Tracking Protection Working Group" <>
> Cc: "Matthias Schunter" <>
> 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.)

Received on Monday, 14 May 2012 14:35:57 UTC