Re: ACTION-255: Work on financial reporting text as alternative to legal requirements

David, 

The examples Alan gives have all a certain bias to a target. In 
order to prove that the target has been met, the service must 
collect a certain amount of data. The proposal, as far as I 
understand it, collects data as before for to proof this rather 
group-oriented targeting under the permitted use of financial 
reporting. As all business, at some point in time, has to have some 
accounting, your argument goes circular. We do targeted 
advertisement and we obliged ourselves to do so. Now we have a 
contractual reason to collect that data that we have fulfilled our 
obligation. 

Consequently, if a business does not target, they do not need to 
provide financial information for having done so. Where there is no 
service, there ain't no price and no accounting needed. 

But I hear you and Alan making a point. It looks like you want to 
target a certain group of people without identifying or 
individualizing them. Kimon can weigh in here, as the EU advertisers 
know how to do that without using personal data. As soon as there is 
no personal data anymore, there is no reason whatsoever for 
restrictions (within the limits of the de-anonymization debate)

So instead of complaining that the industry can't just go on with 
the current model, the industry needs to innovate. I heard that the 
European industry has already done something in this area. You 
should ask Kimon for more information.

Rigo

On Friday 28 September 2012 17:33:26 David Wainberg wrote:
> 
> I think the point is that there are legitimate reasons outside of
> statutory or regulatory requirements that this data may need to be
> retained. And I think those of us coming from the business side
> have been very willing to work on reasonable retention and use
> limits that can still accommodate those reasons.
> 
> There's now been a lot of explanation from people in the online
> advertising business about the needs to retain certain data for
> financial reporting reasons. It seems we're all agreed that online
> advertising should not be prohibited under DNT, so it follows
> that certain business needs around online advertising must be
> allowed for. So what harms stem from accommodating these business
> needs? Can you provide real examples of why the use of such data
> for financial reporting is a problem? Perhaps if we really
> understood specific cases you are concerned about, it would help
> us get on the same page about appropriate limitations.
> 
> -David

Received on Monday, 1 October 2012 07:49:44 UTC