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Re: MRC Industry Standards for Data Retention = 1-year

From: Chris Mejia <chris.mejia@iab.net>
Date: Fri, 28 Sep 2012 11:08:45 +0000
To: Jonathan Mayer <jmayer@stanford.edu>, Ed Felten <ed@felten.com>
CC: W3C DNT Working Group Mailing List <public-tracking@w3.org>, Mike Zaneis <mike@iab.net>
Message-ID: <CC8B381C.24842%chris.mejia@iab.net>

Thanks for providing your interpretation of the MRC Standard.  You should probably vet that interpretation with the MRC directly, as I'm not in accord with your interpretation, and I serve on the digital audit committee for the MRC.

To clarify, the MRC, in it's standards and audits, is not particularly interested in the notion of "tracking" (as you commonly define it against industry); rather, it's focus is on verifying circulation counts and audience measurement for the purpose of validating advertising spends against advertising sales.  To do it's job for industry per it's Congressional mandate, the MRC and it's associated auditors look at "source data" (in the digital case, URL(s) that are associated with anonymous user profiles [not PII]) to determine if what's being sold (the delivery/count of a particular audience segment against an advertising spend), is actually what's being delivered.  The MRC standard requires that a company compliant with its standard hold this source data for at least 11-months past the month of collection (effectively 12-months) in case disputes arise and additional audits are required to resolve such disputes.  This mechanism keeps the industry honest, and has been in place since 1964.  If you'd like to challenge the MRC standard, I don't believe this is the appropriate forum— you'd have to take that up with the MRC directly.  I've simply provided this W3C forum the information requested of industry regarding one of it's data retention requirements.

Additionally, as I understand it, the DNT specification being contemplated by this W3C working group does not constitute an explicit "opt out".  Rather it is supposed to be a user-set "preference indicator".  Because the UI presented to users varies so greatly across platforms offering this DNT preference indicator (due to failure of this group to specify/lock down the specific UI), determining actual user intent is complicated.  For example, the meaning of (and intent of singling) "tell websites I don't want to be tracked" is subjective (as it's not been clearly defined, to the user, nor to the site receiving the indicator).  One can easily interpret this signal many ways.  In fact, this working group has failed to even define the word "tracking" for it's purpose.

The MRC standard for data retention is applied to ALL advertising sold against audience (audience are even those who have indicated a DNT:1 signal, as they still receive ads).  In contemplating compliance with the MRC standard, companies cannot simply "not count" the ads where user's have a) received an ad, but b) have expressed a preference against receiving interest based advertising (if that's even the user's intent).  Simply stated, the MRC requires that ALL ad delivery be counted, and such source data used to count be stored for  a minimum period of 12-months, for the reasons previously stated.

To clarify, your assertion below would seem to support the notion that DNT:1 = "do not delivery ads at all".  This emerging Do-Not-Track specification, as I understand it, is not intended to be a content/ad blocker.  As such, if the user "turns on" DNT:1, they are not indicating that they do not want to receive ads; rather it my understanding that the user would be indicating that they do not want to receive ads that are based on their past browsing experience.  Are we in accord?  If so, it would seem a bit funny to assume that the ads delivered (to any user) not be counted and held accountable for circulation and related billing purposes— such an assertion would fly in the face of the Harris Committee's intent to audit industry and hold it accountable.


C. Mejia

Chris Mejia | Digital Supply Chain Solutions | Ad Technology Group | Interactive Advertising Bureau - IAB

From: Jonathan Mayer <jmayer@stanford.edu<mailto:jmayer@stanford.edu>>
Date: Friday, September 28, 2012 2:18 AM
To: Ed Felten <ed@felten.com<mailto:ed@felten.com>>
Cc: Chris Mejia - IAB <chris.mejia@iab.net<mailto:chris.mejia@iab.net>>, W3C DNT Working Group Mailing List <public-tracking@w3.org<mailto:public-tracking@w3.org>>
Subject: Re: MRC Industry Standards for Data Retention = 1-year

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 . . . .

On Thursday, September 27, 2012 at 5:48 PM, Ed Felten wrote:

Chris, do you read the MRC document as requiring that tracking data be retained for one year?   Do you read it as requiring tracking data to be collected from opted-out users?

On Thu, Sep 27, 2012 at 7:39 PM, Chris Mejia <chris.mejia@iab.net<mailto:chris.mejia@iab.net>> wrote:
I believe it was Jeff Chester who asked if I would research this and come back to the working group with the results:

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

Chris Mejia | Digital Supply Chain Solutions | Ad Technology Group | Interactive Advertising Bureau - IAB
Received on Friday, 28 September 2012 11:09:45 UTC

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