Re: Proposed Text for Local Law and Public Purpose

Chris:  The MRC is a creature of industry.  Here's its member list:  http://mediaratingcouncil.org/Member%20Companies.htm
It's an industry accreditation company that helps the industry expand its data analytics and measurement practices, for advertising on and offline: http://mediaratingcouncil.org/Accredited%20Services.htm

Because it is so tied to the marketing industry, I fail to see how it can serve as a independent source for criteria related to the work we are doing.  Perhaps we need to focus on this issue on a call?

Thanks,

Jeff


Jeffrey Chester
Center for Digital Democracy
1621 Connecticut Ave, NW, Suite 550
Washington, DC 20009
www.democraticmedia.org
www.digitalads.org
202-986-2220

On Oct 22, 2012, at 11:54 AM, Chris Mejia wrote:

> Jeff, by listing members of the MRC in your email, are you suggesting that the MRC operates with some sort of industry bias?  You understand that the MRC reports to Congress, right?  Their entire purpose is to ensure that companies in the space are held accountable and there is no bias.  If you still have such a concern, you should take it directly to MRC— I think you'll find that they have put plenty of safeguards in place to ensure that there is no bias.
> 
> Chris Mejia | Digital Supply Chain Solutions | Ad Technology Group | Interactive Advertising Bureau - IAB
> 
> 
> From: Jeffrey Chester <jeff@democraticmedia.org>
> Date: Saturday, October 20, 2012 1:49 PM
> To: Richard Weaver - ComScore <rweaver@comscore.com>
> Cc: John Simpson <john@consumerwatchdog.org>, Amy Colando <acolando@microsoft.com>, W3C DNT Working Group Mailing List <public-tracking@w3.org>
> Subject: Re: Proposed Text for Local Law and Public Purpose
> Resent-From: W3C DNT Working Group Mailing List <public-tracking@w3.org>
> Resent-Date: Saturday, October 20, 2012 1:50 PM
> 
> Thanks.  I hope we aren't suggesting that somehow industry set guidelines for its own MRC should in any way impact our work to provide user choice in a meaningful manner for DNT.  The MRC is a media/industry industry run initiative, involved in a wide range of TV and online measurement tools that play a key role in the user targeting experience:  http://mediaratingcouncil.org/Accredited%20Services.htm
> 
> Companies involved with the Council include Google, Disney, Adobe, comScore, AOL, Microsoft, Yahoo, etc.   I suggest that it's guidelines do not reflect the privacy concerns addressed by this group.  The history of ratings, as many of us know, has been quite controversial (such as Hispanic measurement).  Congress has been critical of many of the industry practices.    Is someone suggesting that there be a data retention source period for one year or more to please the MRC?
> 
> 
> 
> 
> Jeffrey Chester
> Center for Digital Democracy
> 1621 Connecticut Ave, NW, Suite 550
> Washington, DC 20009
> www.democraticmedia.org
> www.digitalads.org
> 202-986-2220
> 
> On Oct 17, 2012, at 5:26 PM, Weaver, Richard wrote:
> 
>> 
>>  
>> I hope Chris Mejia won’t mind that I’m cutting and pasting his previous description of MRC:
>>  
>>  
>> According to the Media Rating Council (MRC), the normal retention period for "source data" required for industry accreditation of third-party audience estimates is 1-year, as documented in their published standards: "Minimum Standards for Media Rating Research" (available for download at http://mediaratingcouncil.org/MRC%20Standards.htm).  Depending on the case however (and on a case-by-case basis), special concessions may be made outside of this standard from time to time as deemed appropriate by the CPAs/auditor and the MRC.
>>  
>> About the MRC, their mission and authority:
>> In the early 1960’s a U.S. Congressional Committee held hearings on the purpose and accuracy of audience research and considered regulation related to the TV and Radio industries.  These public hearings are commonly referred to as the “Harris Committee Hearings on Broadcast Ratings.”  After investigation and extensive testimony the Committee determined that Industry self-regulation, including independent audits of rating services was preferable to government intervention.  The Harris Committee hearings resulted in the formation of an Industry-funded organization to review and accredit audience rating services called the Broadcast Rating Council (now referred to as the MRC).
>> Aligned with the actions deemed necessary by the House Committee, the activities of the MRC include:
>> 
>> The establishment and administration of Minimum Standards for rating operations;
>> The accreditation of rating services on the basis of information submitted by such services; and
>> Auditing, through independent CPA firms, of the activities of the rating services.
>>  
>> The Media Rating Council seeks to improve the quality of audience measurement by rating services and to provide a better understanding of the applications (and limitations) of rating information.  The Bylaws of the MRC document the organization’s mission as: “to secure for the media industry and related users audience measurement services that are valid, reliable and effective; to evolve and determine minimum disclosure and ethical criteria for media audience measurement services; and to provide and administer an audit system designed to inform users as to whether such audience measurements are conducted in conformance with the criteria and procedures developed.”  This mission was established with the support of the House Committee.
>>  
>> More on the MRC at http://mediaratingcouncil.org/History.htm
>>  
>>  
>> 
>>  
>> Richard Weaver Deputy Privacy Officer | comScore, Inc. (NASDAQ:SCOR)
>> o +1 (703) 438-2354 | rweaver@comscore.com
>> ...........................................................................................................
>> 
>> 
>> Introducing Mobile Metrix 2.0 - The next generation of mobile behavioral measurement 
>> www.comscore.com/MobileMetrix
>> 
>>  
>> 
>> From: John Simpson [mailto:john@consumerwatchdog.org] 
>> Sent: Wednesday, October 17, 2012 5:14 PM
>> To: Amy Colando
>> Cc: public-tracking@w3.org
>> Subject: Re: Proposed Text for Local Law and Public Purpose
>>  
>> I'm sorry, maybe I missed something -- it certainly wouldn't be the first time -- but what is MRC accreditation?
>>  
>>  
>> ----------
>> John M. Simpson
>> Consumer Advocate
>> Consumer Watchdog
>> 2701 Ocean Park Blvd., Suite 112
>> Santa Monica, CA,90405
>> Tel: 310-392-7041
>> Cell: 310-292-1902
>> www.ConsumerWatchdog.org
>> john@consumerwatchdog.org
>>  
>> On Oct 17, 2012, at 1:46 PM, Amy Colando (LCA) wrote:
>> 
>> 
>> Hi John.
>>  
>> This was intended to address the MRC accreditation scenario that was previously raised. 
>>  
>> From: John Simpson [mailto:john@consumerwatchdog.org] 
>> Sent: Wednesday, October 17, 2012 1:19 PM
>> To: Amy Colando (LCA)
>> Cc: public-tracking@w3.org
>> Subject: Re: Proposed Text for Local Law and Public Purpose
>>  
>> Amy,
>>  
>> A clarifying question: Can you please give a use case for what sort of data would be collected for "relevant self-regulatory requirements"?
>> Thanks,
>> John
>>  
>> ----------
>> John M. Simpson
>> Consumer Advocate
>> Consumer Watchdog
>> 2701 Ocean Park Blvd., Suite 112
>> Santa Monica, CA,90405
>> Tel: 310-392-7041
>> Cell: 310-292-1902
>> www.ConsumerWatchdog.org
>> john@consumerwatchdog.org
>>  
>> On Oct 17, 2012, at 8:05 AM, Amy Colando (LCA) wrote:
>> 
>> 
>> 
>>> Apologies that I have lost track of Action number, which I will look up later.  Many thanks to Vinay, MeMe and David W. for assisting with this text.
>>>  
>>> 6.1.1.9 Compliance with Local Law and Public Purpose
>>>  
>>> Normative: Regardless of DNT signal, information MAY be collected, retained, used and shared for complying with applicable laws, regulations, legal obligations and other public purposes, including, but not limited to, intellectual property protection, delivery of emergency services, and relevant self-regulatory verification requirements.
>>>  
>>> Non-normative: This specification does not purport to require parties to breach existing contractual obligations.  At the same time, it is expected that parties implementing this specification should not enter into new contractual obligations that have the effect of circumventing specification requirements. This specification recognizes that there are legitimate self-regulatory regimes that both protect consumer interests and govern certain data practices, and the specification does not intend to conflict with these regimes. However, parties should whenever possible adhere to the letter and spirit of this specification, and should not look to such regimes as merely a means to circumvent the specification.
>>>  
>>>  
>> 
>>  
>>  
>> 
>> 
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