Unknowing collection

http://www.w3.org/wiki/Privacy/TPWG/Change_Proposal_Unknowing

Problems:

The statement as provided focuses on unknowing collection, but should cover other unknowing non-compliance, and should require getting into compliance.

Qualifying 'MUST' with 'where reasonably feasible' makes it not a MUST at all; these are in conflict.

Proposal

If a party learns that it is not in compliance, including possessing information in violation of this standard, it MUST come into compliance at the earliest practical opportunity even if it was previously unaware of such information practices despite reasonable efforts to understand its information practices; when non-compliant data has been retained, this means it MUST  delete or de-identify that information at the earliest practical opportunity.


David Singer
Multimedia and Software Standards, Apple Inc.

Received on Wednesday, 3 July 2013 00:12:06 UTC