- From: Ninja Marnau <nmarnau@datenschutzzentrum.de>
- Date: Mon, 01 Jul 2013 10:23:11 +0200
- To: mts-std@schunter.org, public-tracking@w3.org
Thanks for forwarding this letter to the group.
Just to make sure we are on the same page regarding the Google Analytics
agreement: The Data Protection Commissioner of Hamburg negotiated in
2011 with Google to allow German web site owners (data controllers) to
use Google Analytics in a lawful way. According to our compliance spec
Google Analytics would be a service provider (not a third party).
Therefore, we talk about additional requirements for first parties and
their service providers here: (These additional requirements result
mainly from the facts that 1) the Safe Harbor self-certification alone
is deemed insufficient by German DPA for a legal ground for data
transfer to the US, 2) Google is a huge party and a siloing of data from
different customers and separation of first party services and service
provider services could not be verified.)
- Opt-out option for users (data subjects) regarding the use of service
providers like Google Analytics
- "De-identification" (by deleting the last IP address segment)
immediately before any data transfer to the US occurs
ninja
Am 28.06.2013 01:30, schrieb mts-std@schunter.org:
>
>
> Dear Team,
>
>
> Peter and I have received the enclosed letter from Dr. Dix as input for
> our consideration.
>
> It contains
> - a cover letter,
> - a position statement on web-tracking outlining
> the requirements of the International Working Group
> on Data Protection in Telecommunications ("the Berlin Group"),
> - and a press statement in German.
>
>
> Regards,
> matthias
>
> PS: My (non-normative) translation of the Press statement:
>
> The Press statement says that Google and the German DPA have agreed on
> guidelines how how to adjust Google Analytics in a way that is in line
> with the German DPA requirements. Basically (no guarantee for correct
> translation) these requirements have been fulfilled:
> 1. Opt-out for users
> 2. Ability to enterprise users to ask Google to anonimize the
> IP addresses collected (by dropping the last part)
> 3. Contracts between Google and Enterprises using Analytics
> that satisfy the requrements of Google acting as Data Processor.
>
>
> ---------------------------- Original Message ----------------------------
> Subject: Web Tracking
> Date: Thu, June 27, 2013 11:28
> --------------------------------------------------------------------------
>
> Dear Prof. Swire,
> Dear Mr. Schunter,
>
> please find attached a letter of Dr. Dix and the enclosures.
>
> Yours sincerely,
>
> Sandra Ließmann
>
--
Ninja Marnau
mail: NMarnau@datenschutzzentrum.de - http://www.datenschutzzentrum.de
Telefon: +49 431/988-1285, Fax +49 431/988-1223
Unabhaengiges Landeszentrum fuer Datenschutz Schleswig-Holstein
Independent Centre for Privacy Protection Schleswig-Holstein
Received on Monday, 1 July 2013 08:24:04 UTC