ACTION-255: Work on financial reporting text

Hi all,

I'm not sure if Alan will have power/Internet access in New York at the moment, so I'm sending the proposal for this action to the group. Suggested text is:

> Financial reporting and auditing
> Operators may retain data related to a communication in a third-party context to use for billing and auditing of concurrent transactions. This may include counting ad impressions to unique visitors, verifying positioning and quality of ad impressions and auditing compliance with this and other standards.

This text would be one of the enumerated permitted uses, replacing the current editors' draft section

I suggested additional text, that might just be non-normative or explanatory, but I don't believe that Alan thinks it's necessary, so consider this part just from me:
> Note that (as described above/below) these requirements do not prohibit retention and use of data required by law or regulation, but the existence of a contractual requirement to retain data does not take precedence over compliance with these requirements.
> This permitted use is intended to provide for recording, reporting and verifying delivery of and interaction with online advertising and similar activities. It is not intended to cover retaining a user's ad impression to combine with later browsing activity, subsequent conversion, frequency capping or ad sequencing. Note that when a user meaningfully interacts with an ad or widget, such interaction is likely in a first-party context (and therefore not restricted by these third-party requirements).

This proposal is a new attempt at a replacement for existing text on financial reporting, an update from a past proposal based on financial reporting law. The limiting factor of the "concurrent transaction" is an attempt to enable the transactional billing (and related audits) while not allowing any type of data collection required by a contract, as I believe is the common intent of the group. We believe this might also help with the ongoing discussion about MRC and other self-regulatory regimes; where those systems are auditing for financial reporting, then this permitted use might be more focused and perhaps address concerns we've heard on that thread.

A version of this text is present in my updated draft on permitted uses, here:

Please let us know what you think.

Received on Tuesday, 30 October 2012 16:06:26 UTC