- From: John Simpson <john@consumerwatchdog.org>
- Date: Tue, 2 Jul 2013 12:33:14 -0700
- To: Rigo Wenning <rigo@w3.org>
- Cc: Kathy Joe <kathy@esomar.org>, Mailing List <public-tracking@w3.org>, "Susan_Israel@Comcast.com" <Susan_Israel@comcast.com>, Richard Weaver <rweaver@comscore.com>, "Adam I.C. Phillips Phillips" <adam.phillips@realresearch.co.uk>, Peter Swire <peter@peterswire.net>
By calling for a separate industry-based opt-out system, this proposal completely undermines the concept of Do Not Track. I cannot support it. If, indeed, the industry is willing to provide an opt out, then DNT should suffice and there is no reason whatsoever for this as a permitted use. On Jul 2, 2013, at 10:27 AM, Rigo Wenning <rigo@w3.org> 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: >> >> Calibrate, 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. >> >> Must 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. > >
Received on Tuesday, 2 July 2013 19:34:01 UTC