W3C home > Mailing lists > Public > public-tracking@w3.org > September 2012

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

From: Alan Chapell <achapell@chapellassociates.com>
Date: Wed, 19 Sep 2012 11:42:01 -0400
To: <public-tracking@w3.org>
Message-ID: <CC7F6009.20F80%achapell@chapellassociates.com>
Good Morning,
Here is the language we came up with. I'm on a plane. I'll be on IRC, but
not the call until perhaps the end. Financial Logging and Auditing

Regardless of DNT signal, any information sent via the request may be
collected, retained and used as a record that the request occurred and that
the request met various criteria set forth by the contract or as terms of
more standard industry audits used to determine the quality of impressions,
clicks or actions.  This may include information used to verify:
* Number and quality of ad impressions
> * Basics of MRC audit and of all contracts
* Unique visitors receiving impressions
> * Typical contractual term
* Number and quality of clicks
> * Basic of MRC audit and of all contracts and vital to confidence in CPM
> pricing
* Unique visitors imparting clicks
> * Basics of MRC audit and all contracts
* Subsequent action(s) or conversion post click or impression
> * Key to entire CPA billing model
* Unique visitors engaging in post click or impression action or activity
> * Key to entire CPA billing model
* The degree to which ad ad was rendered
> * MRC audit IAB standard contracts
* Display time and user interaction with ad
> * Contracts
* Location on page where ad rendered
> * Contracts
* URL Location on which ad rendered
> * Contract and used to ensure that ads are delivered on "inappropriate" sites
> (per Alans' comments) Examples
This section is non-normative.

A snow tire manufacturer, BigSnowTire Co, enters into a contract to buy 1
billion ad impressions at $3 per thousand on BigPublisher to specific pages
on BigPublisher's site to viewers in certain Northern US sites at a given
time of day.  BigSnowTire Co uses a popular ad delivery tool to record IP
address, Ad Unit Served , URL on which it was served, Time it was served
(among other information) to ensure that the terms of its contract with
BigPublisher were met.  Absent this data BigSnowTire Co would have no
lasting record that significant financial outlay of $3million was correctly

A large law firm with a class action practice, DewyCheatim LLC, purchases
CPM based advertising at a rate of $50 a click for keyword
"classactionenoma" from a large search engine, BigSearch.  DewyCheatim uses
a popular 3rd party tool provider to record click information including
cookie, IP address, user agent and time stamp relating to the click to
ensure that contract terms with BigSearch were met by retaining the ability
to filter multiple clicks by the same end user, filter "low quality" clicks
coming from competing law firm "AndHow LLC" or clicks potentially coming
from BigSearch or its affiliates.

A large credit card agency, BigPlastic, offers a $100 bounty to all sites
who run display ads featuring BigPlastic credit card offers where within 24
hours of a user's view of such ad or click on such ad, user visits
BigPlastic.com and signs up for a card.  BigPlastic.com by contract retains
the right to hold back such bounty if user later fails to qualify or use
such card.  BigPlastic.com retains a 3rd party ad service provider who, on
BigPlastic's behalf, retains or supplies to BigPlastic, data which would
allow such correlation to occur including IP, ReferringURL and unique

An industry group called the Prescription Medicines Code of Practice
Authority (PCMCP) is charged with regulating certain aspects of  (among
other things) pharmaceutical advertising in the UK.  An Advertising Network
campaign was created and run for a U.S. based pharma company, Burtussion
Pharmaceuticals.  The site list for the campaign included ³News.co.uk² a
site that is widely viewed by people located across both the U.S. and
Europe. A user located in the UK who was served an at from Burtussion on
News.co.uk took a snapshot and filed a complaint with the PMCPA as it was
against the PMCPA Code for an American company to advertise an American
prescription / Rx product in the UK. However, if the ad network could
demonstrate that the User was a) located in the U.S. and b) had been
previously served a Burtussion ad on a U.S. based site as part of this
campaign, the likelihood of the PMCPA taking action would diminish greatly.
5000 UK impressions were served as part of a remarketing campaign. Six
months after the campaign had run, PMCPA contacted the ad network, the ad
agency and Burtussion as part of their investigation into the alleged breach
of their code and requested (among other items): demonstrable proof that
re-targeted viewers had to have seen the Burtussion Pharmaceuticals
advertisement previously on a US site before they could be served the same
advertisement on the UK based site. i.e. if the viewer saw the advertisement
on the News.co.uk website.  The ad network was asked to check its logs to
confirm that those applicable Users have viewed the advertisement
previously. The agency shared that the pharmaceutical company was facing
fines, and that there¹s was a high potential that the issue would be
escalated if the ad network didn¹t clarify the above points quickly.

Received on Wednesday, 19 September 2012 15:43:09 UTC

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