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

From: Mike Zaneis <mike@iab.net>
Date: Mon, 1 Oct 2012 13:47:51 +0000
To: Rigo Wenning <rigo@w3.org>, David Wainberg <david@networkadvertising.org>
CC: Nicholas Doty <npdoty@w3.org>, Alan Chapell <achapell@chapellassociates.com>, "public-tracking@w3.org" <public-tracking@w3.org>, "Dobbs, Brooks" <Brooks.Dobbs@kbmg.com>
Message-ID: <9FF2724793CE3843BF5E46A70AA609A5B7076585@IAB-NYC-EX1.IAB.local>

This is the not the first time you have brushed away industry's substantive concerns with the "So instead of complaining that the industry can't just go on with the current model, the industry needs to innovate" line.  I don't see how it is appropriate for the W3C staff to advocate for a substantive provision or to seek to be a change agent within this process.  The W3C staff should be facilitating the process so that the group can make substantive decision.  

As for characterizing the need to innovate and simply change, perhaps you underestimate the size and scope of what you are advocating.  The industry is constantly evolving in the area of consumer privacy, but it is a massive economic segment, affecting over 5 million American jobs (see new IAB economic study below), therefore it is necessary to consider our substantive arguments and not interject your personal views on where the process should end up. 



NEW YORK, NY (October 01, 2012) - Employment in the ad-supported internet ecosystem doubled over the past four years to 5.1 million, making it one of the most dynamic sectors in the recessionary American economy, according to a study by researchers at the Harvard University Business School, commissioned by the Interactive Advertising Bureau (IAB). The ecosystem contributed $530 billion to the U.S. economy last year, close to double 2007 figures, and accounted for 3.7 percent of the U.S. gross domestic product (GDP), an uptick from 2.1 percent four years ago.
These key findings are from the 2012 "Economic Value of the Advertising-Supported Internet Ecosystem," a comprehensive update to a study by the same name released by IAB in 2009, reviewing data from 2007. John Deighton, Harold M. Brierley Professor of Business Administration, Harvard Business School, who helped lead the previous version, directed the current study, with Leora D. Kornfeld, Research Associate, Harvard Business School, serving as principal investigator. The research was unveiled today at the annual IAB MIXX Conference in New York City to quantify the significant role the ad-supported digital sector plays in the expansion of the broader U.S. business landscape.  http://iab.informz.net/z/cjUucD9taT0xODUyOTYwJnA9MSZ1PTc3MTQ5MTEwMyZsaT04OTEzNjk2/index.html

Mike Zaneis
SVP & General Counsel
Interactive Advertising Bureau
(202) 253-1466

Follow me on Twitter @mikezaneis

-----Original Message-----
From: Rigo Wenning [mailto:rigo@w3.org] 
Sent: Monday, October 01, 2012 3:49 AM
To: David Wainberg
Cc: Nicholas Doty; Alan Chapell; public-tracking@w3.org; Dobbs, Brooks
Subject: Re: ACTION-255: Work on financial reporting text as alternative to legal requirements


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.


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 13:56:45 UTC

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