Re: Call for proposals for ISSUE-194

Hi Matthias,

For me, the goal of ensuring that sites reliably receive valid DNT 
signals is connected with the communication between sites and users. The 
underlying problem for me is the ability to have a granular and valid 
DNT dialogue between a site and a user. The underlying problem is also 
connected to the defaults. My proposal starts with adressing the 
defaults and continues with a technical solution. I conclude with a text 
proposal.

Two weeks ago, I discussed DNT with DPAs in Prague. The consensus is 
that for DNT to be an effective instrument to provide user control, it 
is crucial that sites can be certain that the DNT signal which they 
receive is a true indication of the user’s wishes. The discussion on the 
defaults that was part of the DAAs proposal that was brought to the 
table on yesterday's call.

The DAA takes the position that DNT would be off by default. I strongly 
advise against this postion. The consensus amoungst DPAs is that in the 
absence of fully informed user choice a site must assume that a user is 
not aware of Web Tracking and therefore assume the default position as 
if they had received a DNT:1 signal, which indicates a wish from the 
user that this user prefers not to be tracked on the target site (TPE 
section 4.1).

To seperate the noise from the music, the subject of reliably receiving 
valid DNT signals contains an element of trust. Trust can be established 
by creating a chain of identity, in which the level of authentication 
determines the level of trust. As a vehicle for the level of 
authentication, a session key or token can used. The key or token can be 
stored temporarily in the cookie store or HTML5 local storage.

In lign with the imperative of privacy by design, the level of 
authentication must be adequate, relevant and not excessive in relation 
to the purpose. To maintain the level of trust, the expiry of the 
authentication is something to consider. In other words, the lifespan of 
trust is important. For the purpose of the communication between a site 
and a user, I would think the duration of a session is enough. A session 
is proportional to the amounth of time to maintain the level of trust.

What is considered a session is a level of detail we need to discuss 
further. For me there are a few elements that signal the end of a 
session, for example closing a browser, clearing the cookie, clearing 
the local storage, but also closing a browser tab. The latter is a 
invitation for the browser vendors to make expiry transparent to the 
user.

So in terms of concrete text, I propose the following:

<text proposal>
In the absence of a validated DNT signal, which indicates a fully 
informed user choice, a site MUST assume that a user is not aware of Web 
Tracking and therefore MUST assume the default position as if they had 
received a DNT:1 signal, which indicates a wish from the user that this 
user prefers not to be tracked on the target site.

Trust MAY be established by creating a chain of identity, in which the 
level of authentication determines the level of trust. As a vehicle for 
the level of authentication, sites MAY use a session key or token. The 
key or token MAY be stored temporarily in for example the cookie store 
or HTML5 local storage. The expiry of the key or token MUST be limited, 
and for a minumum MUST expire through automatic deletion when the 
Browser Tab closes.
</text proposal>

Looking forward to fruitful discussion at the forthcoming face 2 face,
Regards,
Rob



Matthias Schunter (Intel Corporation) schreef op 2013-04-30 09:38:
> Hi Team,
> 
> 
> 
> during the last TPE call, we discussed ISSUE-194. One goal of
> ISSUE-194 is to ensure that sites reliably receive valid DNT signals.
> Without such a mechanism, there is a risk that a multitude of things
> spray DNT;1 signals (antivirus, network devices, operating systems,
> ...; often without user interaction).
> As a consequence, sites can no longer reasonably by required to
> listen to those signals.
> 
> We agreed that separating noise from signals is a valid concern and
> there were concerns
> whether there exists any solution that satisfies our goals.
> 
> If we could reliably distinguish between valid user
> preferences/choice and noise from other entities on the net,
> then this allows sites to actually reliably act on user preferences
> while "D"isregarding the noise.
> 
> As part of discussing this further, I would like to issue a call for
> proposals. The question is
> what mechanisms are envisioned that allow sites to (more) reliably
> separate noise from preferences.
> 
> Any proposals (as responses) are welcome. My goal is to then discuss
> and compare thes proposals
> to understand whether they help sites with this concern.
> 
> 
> Regards,
> matthias

Received on Tuesday, 30 April 2013 10:22:53 UTC