Re: ISSUE 25: ACTION 415: Audience measurement research

We still have many concerns, some of which we included to this group.  We look forward to to our phone and subsequent conversation with the WG.

Jeff
Jeffrey Chester
Center for Digital Democracy
1621 Connecticut Ave, NW, Suite 550
Washington, DC 20009
www.democraticmedia.org
www.digitalads.org
202-986-2220

On Jul 2, 2013, at 1:27 PM, Rigo Wenning wrote:

> Dear all, 
> 
> based on the text attached at the end of this email, that I received 
> today from Kathy, and that was discussed during a call today, I withdraw 
> my requirement for a minimum bucket size of 812 people. I support the 
> new text suggested as attached: 
> 
> ====
> Information may be collected, retained and used by a third party for 
> audience measurement research where the information is used to 
> calibrate, validate or calculate through data collected from opted-in 
> panels, which in part contains information collected across sites and 
> over time from user agents.
> 
> 
> A third party eligible for an audience measurement research permitted 
> use MUST adhere to the following restrictions. The data collected by the 
> third party:
> 
> •     Must be pseudonymised before statistical analysis begins, and
> •     Must not be shared with any other party unless the data are de-
> identified prior to sharing, and
> •     Must be deleted or de-identified as early as possible after the 
> purpose of collection is met and in no case shall such retention, prior 
> to de-identification, exceed 53 weeks and
> •     Must not be used for any other independent purpose including 
> changing an individual’s user experience or building a profile for ad 
> targeting purposes. 
> •     In addition, the third party must be subject to an independent 
> certification process under the oversight of a generally-accepted market 
> research industry organization that maintains a web platform providing 
> user information about audience measurement research. This web platform 
> lists the parties eligible to collect information under DNT standards 
> and the audience measurement research permitted use and it provides 
> users with an opportunity to exclude their data contribution.
> 
> Non-normative: collection and use for audience measurement research
> 
> Audience measurement research creates statistical measures of the reach 
> in relation to the total online population, and frequency of exposure of 
> the content to the online audience, including paid components of web 
> pages. 
> 
> Audience measurement research for DNT purposes originates with opt-in 
> panel output that is calibrated by counting actual hits on tagged 
> content on websites. The panel output is re-adjusted using data 
> collected from a broader online audience in order to ensure data 
> produced from the panel accurately represents the whole online audience.
> 
> This online data is collected on a first party and third party basis. 
> This collection tracks the content accessed by a device rather than 
> involving the collection of a user’s browser history. Audience 
> measurement is centered around specific content, not around a user.
> 
> The collected data is retained for a given period for purposes of sample 
> quality control, and auditing.  During this retention period contractual 
> measures must be in place to limit access to, and protect the data, as 
> well as restrict the data from other uses. This retention period is set 
> by auditing bodies, after which the data must be de-identified.  
> 
> The purposes of audience measurement research must be limited to:
> 
> ·    Facilitating online media valuation, planning and buying via 
> accurate and reliable audience measurement.
> ·    Optimizing content and placement on an individual site.
> 
> The term “audience measurement research” does not include sales, 
> promotional, or marketing activities directed at a specific computer or 
> device.  Audience measurement data must be reported as aggregated 
> information such that no recipient is able to build commercial profiles 
> about particular individuals or devices. 
> 
> ===
> 
> As there is no other concrete text proposal, I would hope that we can 
> reach consensus on this proposal to be included as a permitted use in 
> the Compliance Specification and close ISSUE-25.
> 
> --Rigo
> 
> On Tuesday 02 July 2013 18:05:28 Kathy Joe wrote:
>> Following up on this action, as part of a series of calls, the two
>> most recent amendments to the normative text were discussed today in
>> a call with Rigo Wenning, Susan Israel, Richard Weaver and Adam
>> Phillips where it was clarified:
>> 
>> ŒCalibrate, validate or calculate through¹ Susan noted this was added
>> to more clearly express that the panel data is used to better
>> understand the census data, in addition to the census data being used
>> to calibrate the panel data so that each informs the other. This does
>> not radically change the process - it just describes it more clearly.
>> 
>> ŒMust not be used for any other independent purposes including
>> changing an individual¹s user experience or building a profile for ad
>> targeting purposes¹. This had already been added to cover concerns
>> like those that have been expressed on the list by Rigo and Jeff
>> Chester, which Rigo further explained to us on the call -- that an
>> audience measurement research permitted use would allow data to be
>> collected and used for another purpose, ie to change a piece of
>> advertising inflight or for addressability to particular, small
>> target groups based on user profiles, with the potential for abuse,
>> such as through redlining or offering different prices to users with
>> different profiles. This is not the purpose of, and is excluded from
>> the AMR permitted use, which is to provide a general measurement of
>> an audience (ie the number of viewers and general characteristics of
>> the audience that saw a piece of content).  The only use of AMR to
>> determine any pricing would be that a web site owner could charge an
>> advertiser or media buyer a higher rate based on traffic to a
>> website.
>> 
>> Comments are welcome and we will arrange additional calls with Justin
>> Brookman and Jeff Chester.
> 
>