- From: Dan Auerbach <dan@eff.org>
- Date: Tue, 23 Oct 2012 17:38:30 -0700
- To: public-tracking@w3.org
- Message-ID: <50873886.4010307@eff.org>
Chris, I think email is a much better forum for this. You can lay out an example in detail, and we can digest it. On a call, discussing details is quite a bit more difficult. On 10/23/2012 04:52 PM, Chris Mejia wrote: > John, > > I fully understood the questions. And I answered them. Once again > (and for the last time please), let's get this added to the agenda for > discussion on a working group call— I'm happy to discuss it there. I > am not going to continue writing this statement, so if you (and > others) are genuinely interested in having a civil conversation on the > matter, and you feel it's important, I'll be happy to accommodate that > conversation on a W3C working group call. Short of that (or in > addition to it), I would suggest that you approach the MRC directly > with your questions— they have a process for dealing with such > questions. In my opinion, this is not the appropriate forum to > discuss the ins and outs of other organization's standards and > requirements. > > Regards, > > Chris > > > Chris Mejia | Digital Supply Chain Solutions | Ad Technology Group | > Interactive Advertising Bureau - IAB > > > > From: John Simpson <john@consumerwatchdog.org > <mailto:john@consumerwatchdog.org>> > Date: Tuesday, October 23, 2012 4:40 PM > To: Chris Mejia - IAB <chris.mejia@iab.net <mailto:chris.mejia@iab.net>> > Cc: Jonathan Mayer <jmayer@stanford.edu <mailto:jmayer@stanford.edu>>, > "Dobbs, Brooks" <Brooks.Dobbs@kbmg.com > <mailto:Brooks.Dobbs@kbmg.com>>, Kimon Zorbas - IAB Europe > <vp@iabeurope.eu <mailto:vp@iabeurope.eu>>, Jeffrey Chester > <jeff@democraticmedia.org <mailto:jeff@democraticmedia.org>>, "Amy > Colando (LCA)" <acolando@microsoft.com > <mailto:acolando@microsoft.com>>, Richard Weaver - ComScore > <rweaver@comscore.com <mailto:rweaver@comscore.com>>, W3C DNT Working > Group Mailing List <public-tracking@w3.org > <mailto:public-tracking@w3.org>> > Subject: Re: Proposed Text for Local Law and Public Purpose > > Chris, > > I've always understood that the list is place to discuss issues and > ask clarifying questions. It saves time on calls and generally has > been very helpful and productive. I asked my questions, "Exactly what > data in what form would need to be collected to meet MRC requirements > when DNT is enabled? How would that differ from the data that would be > collected when DNT is not enabled?" in that clarifying spirit. I am > not debating, not arguing, not building a record. I simply am seeking > to understand the proposal that's on the table as an open issue. > > Perhaps I am unduly dull witted and dense. For that I apologize to the > entire Working Group. Nonetheless, I suspect there is at least one or > two others who would appreciate understanding the proposal. Why won't > you simply explain, "Exactly what data in what form would need to be > collected to meet MRC requirements when DNT is enabled? How would that > differ from the data that would be collected when DNT is not enabled?" > > To your first point, I see you did respond to Ed Felton and I > appreciate that. However, I think he was also simply seeking > clarification. While you responded, you didn't answer his question. > He said that Jonathan's view was that the MRC documents do not > require companies to collect linkable data about every consumer. > > He than asked, "Do you disagree with that?" and "Do you have a > citation in the documents to the contrary?" > > Your response was, "Jonathan's argument is not valid here (we have > coved that twice), nor is he a domain expert. I have presented the > evidence to this forum and I am attesting to it in my capacity as an > industry expert in this domain— what else would you like?" > > The clarifying question is, "Do you believe that the MRC documents > require companies to collect linkable data about every consumer?" > That seems simple enough, the answer is either yes or no. Then the > second point, if yes, where is that in the documents? > > I am not arguing with you or anyone else. I am simply trying to > understand. > > 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 <http://www.ConsumerWatchdog.org> > john@consumerwatchdog.org <mailto:john@consumerwatchdog.org> > > On Oct 23, 2012, at 4:08 PM, Chris Mejia wrote: > >> John, I already answered Ed's email— it's in the record on this >> thread. To your second point, I'm happy to discuss this issue on a >> W3C working group call should the chairs see fit to include it on the >> agenda. >> >> Regards, >> >> Chris >> >> Chris Mejia | Digital Supply Chain Solutions | Ad Technology Group | >> Interactive Advertising Bureau - IAB >> >> From: John Simpson <john@consumerwatchdog.org >> <mailto:john@consumerwatchdog.org>> >> Date: Tuesday, October 23, 2012 3:55 PM >> To: Chris Mejia - IAB <chris.mejia@iab.net <mailto:chris.mejia@iab.net>> >> Cc: Jonathan Mayer <jmayer@stanford.edu >> <mailto:jmayer@stanford.edu>>, "Dobbs, Brooks" <Brooks.Dobbs@kbmg.com >> <mailto:Brooks.Dobbs@kbmg.com>>, Kimon Zorbas - IAB Europe >> <vp@iabeurope.eu <mailto:vp@iabeurope.eu>>, Jeffrey Chester >> <jeff@democraticmedia.org <mailto:jeff@democraticmedia.org>>, "Amy >> Colando (LCA)" <acolando@microsoft.com >> <mailto:acolando@microsoft.com>>, Richard Weaver - ComScore >> <rweaver@comscore.com <mailto:rweaver@comscore.com>>, W3C DNT Working >> Group Mailing List <public-tracking@w3.org >> <mailto:public-tracking@w3.org>> >> Subject: Re: Proposed Text for Local Law and Public Purpose >> >> Colleagues, >> >> As the fellow who started this thread simply by asking "what sort of >> data would be collected for 'relevant self-regulatory requirements?', >> I am shocked and appalled by the completely unprofessional and >> outrageously personal nasty tone it has taken. Some apologies to >> the entire working group are in order. >> >> Let's all cool off a bit here and then could someone please answer Ed >> Felton's questions, which I will repeat: >> "Jonathan's argument, as I understand it, was that the MRC documents >> do not require companies to collect linkable data about every >> consumer. Do you disagree with that? Do you have a citation in >> the documents to the contrary?" >> >> Second could someone please answer these questions: >> Exactly what data in what form would need to be collected to meet MRC >> requirements when DNT is enabled? How would that differ from the data >> that would be collected when DNT is not enabled? >> >> Thank you >> >> 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 <http://www.ConsumerWatchdog.org/> >> john@consumerwatchdog.org <mailto:john@consumerwatchdog.org> >> >> On Oct 23, 2012, at 2:49 PM, Chris Mejia wrote: >> >>> Jonathan, >>> >>> I sit on the MRC's Digital Audit Review Committee. As such, I have >>> attended countless MRC audits, and am asked to apply the MRC >>> guidelines to the audited companies— I do this, every week. Unless >>> you are accusing me of lying or not being qualified (please be >>> transparent and direct if you are), then I am attesting to the fact >>> that data retention, of any data that relates to the bought/billed >>> unit (impression, click, action, etc.) is required per the >>> guidelines. The issue is by no means closed, nor are you qualified >>> to close it. >>> >>> If you want to provide evidence to the contrary, please contact the >>> MRC yourself and do your homework. You are a Stanford grad student, >>> representing Stanford University in this forum— I can only assume >>> that conducting thorough primary research is still something valued >>> at your institution. So if you believe you are right (and I am >>> wrong), then do the real primary research (call the MRC, interview >>> them, etc.) and provide concrete evidence to discredit my testimony >>> as an expert in this domain. But simply reading a document online >>> and pulling parts of it out of context to suit your ill-placed >>> argument, is not only detrimental to this working group's mission, >>> it reflects poorly on the institution you are representing. >>> >>> Finally, I'd like to know who your academic advisor is, or the >>> official at Stanford who supervises your contribution to the W3C? >>> Since your membership to this forum seems to be associated with >>> your student affiliation at Stanford University, I'd be interested >>> in understanding whether your views and actions here are those of >>> the University, or just yourself as a private citizen? >>> >>> Chris Mejia | Digital Supply Chain Solutions | Ad Technology Group | >>> Interactive Advertising Bureau - IAB >>> >>> From: Jonathan Mayer <jmayer@stanford.edu <mailto:jmayer@stanford.edu>> >>> Date: Tuesday, October 23, 2012 2:14 PM >>> To: "Dobbs, Brooks" <Brooks.Dobbs@kbmg.com >>> <mailto:Brooks.Dobbs@kbmg.com>> >>> Cc: Kimon Zorbas - IAB Europe <vp@iabeurope.eu >>> <mailto:vp@iabeurope.eu>>, Jeffrey Chester <jeff@democraticmedia.org >>> <mailto:jeff@democraticmedia.org>>, "Amy Colando (LCA)" >>> <acolando@microsoft.com <mailto:acolando@microsoft.com>>, Richard >>> Weaver - ComScore <rweaver@comscore.com >>> <mailto:rweaver@comscore.com>>, "John Simpson ," >>> <john@consumerwatchdog.org <mailto:john@consumerwatchdog.org>>, W3C >>> DNT Working Group Mailing List <public-tracking@w3.org >>> <mailto: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 <mailto:public-tracking@w3.org>> >>> Resent-Date: Tuesday, October 23, 2012 2:15 PM >>> >>> Here's my concrete proposal: The MRC issue should be CLOSED. As >>> always, if a working group member produces new information, we >>> should take it into account. >>> >>> Background: The MRC issue was RAISED many months ago. We still >>> haven't been presented with an iota of evidence that the MRC >>> guidelines require collection of user data. A plain reading of the >>> MRC Minimum Standards cuts against that view. So does a plain >>> reading of the draft MRC guidelines on digital video. >>> >>> The issue appears to rest on a fundamental misunderstanding of the >>> MRC guidelines. The MRC, in general, specifies *how* a user's >>> behavior is measured. It does not address *whether* the behavior is >>> measured in the first place. >>> >>> I agree with Brooks—much of the MRC's language is antiquated or >>> domain-specific. But, for our purposes, the import seems reasonably >>> clear. And to the extent our plain reading is inaccurate, again, >>> working group members are welcome to present that new information. >>> >>> Jonathan >>> >>> On Tuesday, October 23, 2012 at 9:14 AM, Dobbs, Brooks wrote: >>> >>>> Jonathan, >>>> >>>> I have no objection to, and indeed it does make sense to, >>>> learn(ing) what MRC actually requires. In the meantime, while we >>>> agree that the full extent of what is required is not yet yet fully >>>> understood, it is helpful to avoid misleading folks that a standard >>>> which speaks to diaries, busy signals and facsimiles and was >>>> started in the 60s has specifically anticipated DNT signals at the >>>> rate likely to be seen by default settings; it hasn't. >>>> >>>> -Brooks >>>> >>>> -- >>>> >>>> *Brooks Dobbs, CIPP *| Chief Privacy Officer |*KBM Group*| Part of >>>> the Wunderman Network >>>> (Tel) 678 580 2683 | (Mob) 678 492 1662 | *kbmg.com <http://kbmg.com/>* >>>> _brooks.dobbs@kbmg.com <x-msg://290/brooks.dobbs@kbmg.com> >>>> >>>> <image[74].png> >>>> _ >>>> This email – including attachments – may contain confidential >>>> information. If you are not the intended recipient, >>>> do not copy, distribute or act on it. Instead, notify the sender >>>> immediately and delete the message. >>>> >>>> From: Jonathan Mayer <jmayer@stanford.edu <mailto:jmayer@stanford.edu>> >>>> Date: Tuesday, October 23, 2012 11:49 AM >>>> To: Brooks Dobbs <brooks.dobbs@kbmg.com <mailto:brooks.dobbs@kbmg.com>> >>>> Cc: Kimon Zorbas <vp@iabeurope.eu <mailto:vp@iabeurope.eu>>, >>>> Jeffrey Chester <jeff@democraticmedia.org >>>> <mailto:jeff@democraticmedia.org>>, "Amy Colando (LCA)" >>>> <acolando@microsoft.com <mailto:acolando@microsoft.com>>, "Richard >>>> Weaver (Comscore)" <rweaver@comscore.com >>>> <mailto:rweaver@comscore.com>>, "John Simpson ," >>>> <john@consumerwatchdog.org <mailto:john@consumerwatchdog.org>>, >>>> "public-tracking@w3.org <mailto:public-tracking@w3.org>" >>>> <public-tracking@w3.org <mailto:public-tracking@w3.org>> >>>> Subject: Re: Proposed Text for Local Law and Public Purpose >>>> >>>> Brooks, >>>> >>>> Some members of the working group have claimed they require a Do >>>> Not Track exemption to accommodate the MRC Minimum Standards for >>>> content measurement. The nation is that the MRC Minimum Standards >>>> *require* some data collection about users. Before even >>>> considering such an exemption, it seems prudent to validate the >>>> premise—we should look into whether the MRC Minimum Standards >>>> actually require any data collection. >>>> >>>> I agree that the MRC's document reads antiquated in many places. >>>> That should come as little surprise—it traces back to 1964. >>>> (Latest version: December 2011.) The document explicitly does >>>> not, however, limit itself to old technology. In the provision >>>> we're discussing, it talks about "diaries" and "tape records" >>>> (hah!), but it also includes "other primary sources of audience >>>> data." (It seemed to me uncontroversial to elide "diaries" and >>>> "tape records" to save the group a few moments of reading.) Since >>>> the working group members who invoke MRC consistently cite an >>>> eleven-month source data retention requirement, and this is the >>>> only eleven-month source data retention requirement in the >>>> document, it seems reasonable to conclude this is the relevant >>>> provision. >>>> >>>> So no, no straw man here. I'm attempting to honestly unpack the >>>> claim that the MRC Minimum Standards require data collection about >>>> users. It seems to me that, in a plain reading, they do not. >>>> Until a working group member produces evidence otherwise, we >>>> should be safe in dropping the proposed "relevant self-regulatory >>>> verification requirements" exemption. >>>> >>>> Jonathan >>>> >>>> >>>> On Tuesday, October 23, 2012 at 6:58 AM, Dobbs, Brooks wrote: >>>> >>>>> Microsoft Word - MRC Minimum Standards, December 2011 added A,7,d.doc >>>>> Jonathan, >>>>> >>>>> Did you really just accuse someone of creating a straw man and >>>>> then raise this as an example? >>>>> >>>>> Let's go back and add the actual words left out by your ellipsis: >>>>> >>>>>17. >>>>> Each rating service shall maintain, for at least eleven months >>>>> from the end of the period covered by the report, all diaries >>>>> and interviews (or a complete facsimile thereof), tape records >>>>> and/or other primary sources of audience data. These shall >>>>> include material actually used in the preparation of published >>>>> rating reports as well as material collected but not used. In >>>>> addition, each service shall maintain records of: >>>>> B) All unsuccessful attempts to obtain information, including- >>>>> but not limited to - refusals, not at home, cases requiring >>>>> further discussion and/or correspondence (e.g., with another >>>>> member of the household), busy signals (phone), and returns >>>>> from postal authorities. >>>>> >>>>> It is pretty clear from reading this in full context that this has >>>>> nothing to do with web measurement (diaries, interviews, tape >>>>> records were conveniently redacted). Even the language about >>>>> unsuccessful attempts is unrelated. DNT ad calls are real ad >>>>> calls that result in ad responses – there is nothing >>>>> "unsuccessful" about them. >>>>> >>>>> So none of that is meant to defend or degrade the MRC. I have no >>>>> idea if they are secretly plotting to disenfranchise the hispanic >>>>> community. Maybe they are and that should be dealt with outside >>>>> this group. I do know they provide measurement validation >>>>> services that allow the entire ad economy to work (not just >>>>> Behavioral). Per my previous post – and to mix metaphors – if no >>>>> one trusts the scales no one is paying for advertising. It has >>>>> been said before, but is obviously worth repeating, upsetting core >>>>> measurement of a multi-tens of billion dollar ecosystem doesn't >>>>> seem consistent with the charter and is not an acceptable outcome. >>>>> >>>>> -Brooks >>>>> >>>>> >>>>> -- >>>>> >>>>> *Brooks Dobbs, CIPP *| Chief Privacy Officer |*KBM Group*| Part of >>>>> the Wunderman Network >>>>> (Tel) 678 580 2683 | (Mob) 678 492 1662 | *kbmg.com >>>>> <http://kbmg.com/>* >>>>> _brooks.dobbs@kbmg.com <x-msg://290/brooks.dobbs@kbmg.com> >>>>> >>>>> <image[67].png> >>>>> _ >>>>> This email – including attachments – may contain confidential >>>>> information. If you are not the intended recipient, >>>>> do not copy, distribute or act on it. Instead, notify the sender >>>>> immediately and delete the message. >>>>> >>>>> From: Jonathan Mayer <jmayer@stanford.edu >>>>> <mailto:jmayer@stanford.edu>> >>>>> Date: Tuesday, October 23, 2012 1:41 AM >>>>> To: Kimon Zorbas <vp@iabeurope.eu <mailto:vp@iabeurope.eu>> >>>>> Cc: Jeffrey Chester <jeff@democraticmedia.org >>>>> <mailto:jeff@democraticmedia.org>>, "Amy Colando (LCA)" >>>>> <acolando@microsoft.com <mailto:acolando@microsoft.com>>, Brooks >>>>> Dobbs <brooks.dobbs@kbmg.com <mailto:brooks.dobbs@kbmg.com>>, >>>>> "Richard Weaver (Comscore)" <rweaver@comscore.com >>>>> <mailto:rweaver@comscore.com>>, "John Simpson ," >>>>> <john@consumerwatchdog.org <mailto:john@consumerwatchdog.org>>, >>>>> "public-tracking@w3.org <mailto:public-tracking@w3.org>" >>>>> <public-tracking@w3.org <mailto:public-tracking@w3.org>> >>>>> Subject: Re: Proposed Text for Local Law and Public Purpose >>>>> >>>>> This is our second trip through the purported MRC justification. >>>>> In our last visit, I pointed out that the MRC guidelines >>>>> anticipate that not all users will have data collected. >>>>> >>>>> On Thursday, September 27, 2012 at 6:18 PM, Jonathan Mayer wrote: >>>>> >>>>>> The MRC document explicitly accommodates consumers opting out of >>>>>> data collection. Page 8: >>>>>>> Each rating service shall maintain, for at least eleven months >>>>>>> from the end of the period covered by the report, all . . . >>>>>>> primary sources of audience data. These shall include material >>>>>>> actually used in the preparation of published rating reports as >>>>>>> well as material collected but not used. In addition, each >>>>>>> service shall maintain records of: >>>>>>> . . . >>>>>>> b. All unsuccessful attempts to obtain information, including- >>>>>>> but not limited to - refusals . . . . >>>>> Until a working group member can furnish an MRC or MRC-like >>>>> *requirement* that users have their browsing histories collected, >>>>> this entire conversation seems moot. >>>>> >>>>> Jonathan >>>>> >>>>> >>>>> On Monday, October 22, 2012 at 11:33 AM, Kimon Zorbas wrote: >>>>>> In Europe, we have Jics, industry committees, that run >>>>>> measurement in (as far as I know) each country. >>>>>> There is no agreed standard across Europe. >>>>>> Sometimes they use their own technology (less often) sometimes >>>>>> partner with companies such as Nielsen, comscore, Gemius, spring, >>>>>> etc. I am by no means as expert on Jics. Unlike the MRC, Jics do >>>>>> not certify but mandate / run the measurement, which de facto >>>>>> becomes THE standard in those countries. >>>>>> >>>>>> Colleagues from comscore / Nielsen might be better placed to respond. >>>>>> >>>>>> Kimon >>>>>> >>>>>> ----- Reply message ----- >>>>>> From: "Jeffrey Chester" <jeff@democraticmedia.org >>>>>> <mailto:jeff@democraticmedia.org>> >>>>>> To: "Kimon Zorbas" <vp@iabeurope.eu <mailto:vp@iabeurope.eu>> >>>>>> Cc: "Amy Colando (LCA)" <acolando@microsoft.com >>>>>> <mailto:acolando@microsoft.com>>, "Dobbs, Brooks" >>>>>> <Brooks.Dobbs@kbmg.com <mailto:Brooks.Dobbs@kbmg.com>>, "Richard >>>>>> Weaver (Comscore)" <rweaver@comscore.com >>>>>> <mailto:rweaver@comscore.com>>, "John Simpson ," >>>>>> <john@consumerwatchdog.org <mailto:john@consumerwatchdog.org>>, >>>>>> "public-tracking@w3.org <mailto:public-tracking@w3.org>" >>>>>> <public-tracking@w3.org <mailto:public-tracking@w3.org>> >>>>>> Subject: Proposed Text for Local Law and Public Purpose >>>>>> Date: Mon, Oct 22, 2012 8:22 pm >>>>>> >>>>>> >>>>>> >>>>>> Kimon: Our measurement companies in US are not congressional >>>>>> chartered. Can you send the names of the organizations you have >>>>>> in mind? >>>>>> >>>>>> >>>>>> Jeffrey Chester >>>>>> Center for Digital Democracy >>>>>> 1621 Connecticut Ave, NW, Suite 550 >>>>>> Washington, DC 20009 >>>>>> www.democraticmedia.org <http://www.democraticmedia.org/> >>>>>> www.digitalads.org <http://www.digitalads.org/> >>>>>> 202-986-2220 >>>>>> >>>>>> On Oct 22, 2012, at 2:08 PM, Kimon Zorbas wrote: >>>>>> >>>>>>> I also would like to point out that measurement in Europe works >>>>>>> somehow different with respect to organisational setup. We would >>>>>>> like those entities,not setup by the equivalent of European or >>>>>>> national Congress, to be reflected in the text. Would anyone >>>>>>> have an issue? >>>>>>> >>>>>>> Kind regards, >>>>>>> Kimon >>>>>>> >>>>>>> >>>>>>> ----- Reply message ----- >>>>>>> From: "Amy Colando (LCA)" <acolando@microsoft.com >>>>>>> <mailto:acolando@microsoft.com>> >>>>>>> To: "Dobbs, Brooks" <Brooks.Dobbs@kbmg.com >>>>>>> <mailto:Brooks.Dobbs@kbmg.com>>, "Jeffrey Chester" >>>>>>> <jeff@democraticmedia.org <mailto:jeff@democraticmedia.org>>, >>>>>>> "Richard Weaver (Comscore)" <rweaver@comscore.com >>>>>>> <mailto:rweaver@comscore.com>> >>>>>>> Cc: "John Simpson ," <john@consumerwatchdog.org >>>>>>> <mailto:john@consumerwatchdog.org>>, "public-tracking@w3.org >>>>>>> <mailto:public-tracking@w3.org>" <public-tracking@w3.org >>>>>>> <mailto:public-tracking@w3.org>> >>>>>>> Subject: Proposed Text for Local Law and Public Purpose >>>>>>> Date: Mon, Oct 22, 2012 6:30 pm >>>>>>> >>>>>>> >>>>>>> >>>>>>> You beat me to it Brooks. I'll just add my own analogy that MRC >>>>>>> accreditation is a way of ensuring accurate and consistent >>>>>>> counting methodologies of clicks and impressions, which form the >>>>>>> basis for calculating the amount that advertisers are billed and >>>>>>> sites are paid. The analogy that springs to mind is the state >>>>>>> agencies that certify that gas stations are measuring gallons of >>>>>>> gas accurately and billing consumers accordingly. >>>>>>> >>>>>>> The reason that you see so many companies on the MRC >>>>>>> accreditation page is that this certification as to accuracy of >>>>>>> measurement is vitally important for providing online >>>>>>> advertising services, whether targeted or untargeted. I believe >>>>>>> your reference to Hispanic measurement refers perhaps to >>>>>>> demographics in relation to TV geo advertising markets; if so, I >>>>>>> don't understand the relevance to our discussion. >>>>>>> >>>>>>> Sent from my Windows Phone >>>>>>> ------------------------------------------------------------------------ >>>>>>> From: Dobbs, Brooks >>>>>>> Sent: 10/22/2012 9:12 AM >>>>>>> To: Jeffrey Chester; Weaver, Richard >>>>>>> Cc: John Simpson ,; Amy Colando (LCA); public-tracking@w3.org >>>>>>> <mailto:public-tracking@w3.org> >>>>>>> Subject: Re: Proposed Text for Local Law and Public Purpose >>>>>>> >>>>>>> Jeff, >>>>>>> >>>>>>> I think you are missing the MRC's role in the ecosystem here. >>>>>>> We may even need to do a 101 on the ad serving economy as >>>>>>> compared to a more tangible industry - say pork bellies in the >>>>>>> commodities market. If this is obvious, please forgive the >>>>>>> review, but I think an analogy is helpful here. >>>>>>> >>>>>>> If I spend $150k on 200k lbs of frozen pork bellies at 75 cents >>>>>>> a pound a huge tractor trailer(s) show up and I see frozen pork >>>>>>> bellies. I can further weigh them on an NTEP certified scale, >>>>>>> and if it turns out that only 180k lbs are there I can negotiate >>>>>>> a $15k discount. We can agree on this because even though the >>>>>>> bellies were weighed at my facility, they scales where certified >>>>>>> by an organization both buyer and seller trust. >>>>>>> >>>>>>> If alternatively, I spend $150k on 10k CPMs of advertising on >>>>>>> Big1stParty.com <http://Big1stParty.com/> at $15/CPM targeted to >>>>>>> IP addresses in the Spokane WA area from 4pm to 7pm local time – >>>>>>> where's the beef? I live in Atlanta. If the ad buy was >>>>>>> delivered correctly, I should see exactly ZERO of the ads. How >>>>>>> then does the purchaser have confidence that all 10k CPMs >>>>>>> occurred? Advertisers have this confidence because they >>>>>>> traditionally pay on numbers that their system records, a log of >>>>>>> "quality" deliveries. But the obvious question is then – what >>>>>>> about the seller? How does he have confidence in the buyer's >>>>>>> numbers? Couldn't the buyer have just thrown away 5k >>>>>>> impressions as invalid so as to avoid paying for them? MRC is >>>>>>> the answer here. MRC will give both parties confidence that >>>>>>> they have a common frame of reference from which to conduct >>>>>>> business. The buyer (and/or seller) will have his system MRC >>>>>>> certified and there is an agreed upon counting standardto use as >>>>>>> a basis for payment. >>>>>>> >>>>>>> If you are suggesting that accommodating MRC audits shouldn't >>>>>>> play a role in these discussions, the argument is akin to saying >>>>>>> no one should certify scales in the commodities market. >>>>>>> >>>>>>> -Brooks >>>>>>> -- >>>>>>> >>>>>>> *Brooks Dobbs, CIPP *| Chief Privacy Officer |*KBM Group*| Part >>>>>>> of the Wunderman Network >>>>>>> (Tel) 678 580 2683 | (Mob) 678 492 1662 | *kbmg.com >>>>>>> <http://kbmg.com/>* >>>>>>> _brooks.dobbs@kbmg.com <x-msg://290/> >>>>>>> >>>>>>> <image[50].png> >>>>>>> _ >>>>>>> This email – including attachments – may contain confidential >>>>>>> information. If you are not the intended recipient, >>>>>>> do not copy, distribute or act on it. Instead, notify the >>>>>>> sender immediately and delete the message. >>>>>>> >>>>>>> From: Jeffrey Chester <jeff@democraticmedia.org >>>>>>> <mailto:jeff@democraticmedia.org>> >>>>>>> Date: Saturday, October 20, 2012 4:49 PM >>>>>>> To: "Weaver, Richard" <rweaver@comscore.com >>>>>>> <mailto:rweaver@comscore.com>> >>>>>>> Cc: John Simpson <john@consumerwatchdog.org >>>>>>> <mailto:john@consumerwatchdog.org>>, Amy Colando >>>>>>> <acolando@microsoft.com <mailto:acolando@microsoft.com>>, >>>>>>> "public-tracking@w3.org <mailto:public-tracking@w3.org>" >>>>>>> <public-tracking@w3.org <mailto:public-tracking@w3.org>> >>>>>>> Subject: Re: Proposed Text for Local Law and Public Purpose >>>>>>> Resent-From: <public-tracking@w3.org >>>>>>> <mailto:public-tracking@w3.org>> >>>>>>> Resent-Date: Saturday, October 20, 2012 4:50 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 <http://www.democraticmedia.org/> >>>>>>> www.digitalads.org <http://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 >>>>>>>> <mailto:rweaver@comscore.com> >>>>>>>> ........................................................................................................... >>>>>>>> >>>>>>>> >>>>>>>> >>>>>>>> *Introducing Mobile Metrix 2.0 - The next generation of mobile >>>>>>>> behavioral measurement >>>>>>>> *www.comscore.com/MobileMetrix >>>>>>>> <http://www.comscore.com/Products_Services/Product_Index/Mobile_Metrix_2.0> >>>>>>>> >>>>>>>> >>>>>>>> >>>>>>>> *From:* John Simpson [mailto:john@consumerwatchdog.org] >>>>>>>> *Sent:* Wednesday, October 17, 2012 5:14 PM >>>>>>>> *To:* Amy Colando >>>>>>>> *Cc:* public-tracking@w3.org <mailto: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 <http://www.ConsumerWatchdog.org/> >>>>>>>> john@consumerwatchdog.org <mailto: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 <mailto: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 <http://www.ConsumerWatchdog.org/> >>>>>>>> john@consumerwatchdog.org <mailto: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. >>>>>>>>> >>>>>>>>> >>>>>>>> >>>>>>>> >>>>>>>> >>>>>>>> >>>>>>> >>>>>> >>>>> >>>> >>> >>> <image[74].png><image[67].png> >> > -- Dan Auerbach Staff Technologist Electronic Frontier Foundation dan@eff.org 415 436 9333 x134
Received on Wednesday, 24 October 2012 00:38:59 UTC