Re: ISSUE 25: ACTION 415: Audience measurement research

Rob, I think you are asking for far too little here.  I am trying hard to keep an open mind on Audience Measurement though I still believes it defies the spirit of DNT as a universal opt-out.  However, pulling interest categories for profiling when DNT:1 is turned on is a non-starter.  You may as well be negotiating away Marketing and Advertising as permitted uses.

Rob van Eijk , 7/3/2013 3:22 AM:
 
Peter, 
 
After talking to Rigo last night, I see the progress on the normative  
language and specifically in purpose limitation and not applying the  
audience measurement data to individuals, a computer of device. I see  
the right mindset in terms of privicy by design: changing data from a  
site visitor into data about a site object. 
 
Since we are negotiating here: if Audience Measurement becomes a  
permitted use, than Shane's proposal to allow the collection of intrest  
categories before de-identification needs to go off the table. 
 
Rob 
 
Rigo Wenning schreef op 2013-07-02 19:27: 
> 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.