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Re: tracking-ISSUE-178 (rachel_n_thomas): Add "Marketing" to list of permitted uses in Compliance document [Tracking Definitions and Compliance]

From: Roy T. Fielding <fielding@gbiv.com>
Date: Fri, 5 Oct 2012 03:20:07 -0700
Cc: Jonathan Mayer <jmayer@stanford.edu>, Jeffrey Chester <jeff@democraticmedia.org>, Tracking Protection Working Group <public-tracking@w3.org>
Message-Id: <1C45E6D0-36A6-46D8-BC2D-6E069E0DE11A@gbiv.com>
To: Rachel Thomas <RThomas@the-dma.org>
On Oct 4, 2012, at 5:42 AM, Rachel Thomas wrote:

> Marketing fuels the world. It is as American as apple pie and delivers relevant advertising to consumers about products they will be interested at a time they are interested.  DNT should permit it as one of the most important values of civil society.  Its byproduct also furthers democracy, free speech, and  most importantly in these times  JOBS.  It is as critical to society  and the economy  as fraud prevention and IP protection and should be treated the same way.  
> Marketing as a permitted use would allow the use of the data to send relevant offers to consumers through specific devices they have used. The data could not be used for other purposes, such as eligibility for employment, insurance, etc. Thus, we move to a harm consideration. Ads and offers are just offers  users/consumers can simply not respond to those offers  there is no associated harm.
> Further, DNT can stop all unnecessary uses of data using choice and for those consumers who do not want relevant marketing the can use the persistent Digital Advertising Alliance choice mechanism.  This mechanism has been in place for 2 years.


I appreciate that the DAA has done a lot of work in a somewhat
related area to the WG's efforts.  However, raising issues that
you know quite well will not be adopted is not an effective way
to contribute to this process.

The purpose of DNT is to express a user preference to not be
tracked.  Losing targeted marketing (but not contextual marketing)
is a trade-off that is best chosen by the user, presuming DNT
reflects their actual choice.  It is not a permitted use because
it is the collection of data for the sake of targeted marketing
that the user is specifically trying to turn off.  The harm is
clearly demonstrated by anyone looking over the shoulder (or
monitoring the traffic) of a user in a context different from
when that targeting data was collected.

Likewise, I have read the DAA principles and found that the entire
document (including its definitions) is self-referential and thus
unusable as the basis for definitions in TCS.  I suggest that, if
you wish a definition in TCS to change to be closer to one in DAA,
that you submit text that would be relevant outside the principles
(not based on compliance with DAA) and consistent with the other
definitions in our specifications.

For example, "Service Provider" in the DAA spec refers to ISPs
that do advertising, whereas in our WG that phrase refers to
software or infrastructure as a service vendors (SaaS/IaaS).


Roy T. Fielding                     <http://roy.gbiv.com/>
Principal Scientist, Adobe Systems  <http://adobe.com/enterprise>
Received on Friday, 5 October 2012 10:20:31 UTC

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