- From: Rob van Eijk <rob@blaeu.com>
- Date: Wed, 03 Jul 2013 21:25:42 +0200
- To: public-tracking@w3.org
- Message-ID: <ea3bfed1-3f93-4181-a1b2-9e8082691cf5@email.android.com>
Example of the linkability of hashed pseudonyms: https://blog.twitter.com/2013/experimenting-with-new-ways-to-tailor-ads, a nice use case that shows that the definition of de-identified in the DAA proposal may cause problems. Rob Rob van Eijk <rob@blaeu.com> wrote: > >Peter, > >We have gotten to the point that the only logical and responsible way >forward IMHO is to task industry to chop up the DAA proposal into >change proposals and include these in the wiki that Nick painstakingly >kept up to date. > >Next week, I hope that the group will want to dive deeper into the >discussion on de-identification, when Shane and Dan are back. Dan put >out a reasonable request on the mailing list, after having put in a lot >of work on the topic of de-identification. > >Rob > > >Dan Auerbach <dan@eff.org> wrote: > >>Hi Peter and everyone, >> >>I'm unfortunately on vacation next week and won't be available for >this >>call. I have given a lot of thought and energy to the >de-identification >>and unique id issues, so would like the opportunity to further discuss >>the following week once I'm back before any decisions are made. I will >>catch up with the minutes. I'd love to get to agreement on these >>issues, >>but they are tough and important, so we need to proceed carefully. >> >>Below are some quick comments addressing some of your questions: >> >>On 06/28/2013 02:56 PM, Peter Swire wrote: >>> >>> To the Working Group: >>> >>> >>> >>> W3C staff and I express appreciation for the hard and >>> high-quality work that so many of you have put into submitting >change >>> proposals to the June Draft. This email alerts you to the initial >>> work plan, for the coming week. We wanted to give you this >>> information as soon as possible, and plan to circulate as soon as we >>> can a more complete work plan through the end of July. >>> >>> >>> >>> For the call on Wednesday, July 3, we once again may go >>> for up to 120 minutes if ittakes that long to complete the agenda. >>We >>> will attempt to keep the call to the usual 90 minutes if we can. >>This >>> email sets forth the current plan for the Wednesday call. >>> >>> >>> >>> _De-identification._ >>> >>> >>> >>> Perhaps not surprisingly in light of all the work done >on >>> the issue, the first topic will be to examine and discuss the >>multiple >>> proposals on de-identification, as well as other provisions relating >>> to identification. >>> >>> >>> >>> For this discussion, and comments on the list before >>> Wednesday, we will address the change proposals, alphabetically >from: >>> Dan Auerbach, Rob van Eijk, Roy Fielding, and Thomas Schauf, as well >>> as the DAA group. >>> >>> >>> >>> For the discussion, and comments prior to Wednesday, it >>> would be helpful to comment on issues including: (1) how to choose >>> between two- and three-stage proposals; >>> >> >>I think the 2 stage proposal is simpler. If we move to a 3 stage >>proposal, the onus is on those advocating for this to (1) properly >>define the yellow stage, and (2) prove that it is useful to the group >>to >>have 3 stages. >> >>Regarding (1), I do not think it has been sufficiently defined. For >>example, what is a "suspect query string" in a URL? What are >>operational >>controls? What granularity is the geo information that supplants IP >>address? What rigorously defined properties does a yellow stage >possess >>with respect to risk towards privacy that a red stage lacks? These are >>hard questions, and I'm not sure we will be able to answer them >>rigorously enough. >> >>Regarding (2), I don't think adding a stage has reduced our >>disagreement, but rather just shifted it. Whereas in the two stage >>process, we disagreed about the definition of de-identification and >how >>it would apply to non-normative examples, with a three stage process, >>we >>now disagree with how much value the yellow stage has. Modulo >>definitional issues, I'm comfortable with a yellow stage as stated, >>provided it is used in an incredibly limited way and things move very >>quickly to green. I suspect that Shane disagrees with this, and thinks >>there is a lot of value in yellow. Given that we've just shifted >>disagreement, I'm not sure it's really a step forward. >> >>Also as a matter of politeness, since we agreed in Sunnyvale that we >>would come up with a new name for "yellow" given that both >>"de-identified" and "pseudonymous" were too contentious, I'd >appreciate >>it if we could avoid using the latter two terms when talking about the >>3 >>state proposal. Let's just use the placeholder "yellow" until we agree >>on what the state should be called. >> >>> (2) the pros and cons of the DAA proposed changed language, compared >>> to the longstanding focus on language similar to the FTC’s >three-part >>> test; (3) clarifying any similarities and differences between Rob’s >>> approach and the other two; and (4) how to think about the use of >>> non-normative text here inaddition to normative text. >>> >>On (4), I very much agree with Adrian's comment on a call that if we >>can't begin to see close to eye to eye with respect to non-normative >>examples, it would be unwise to fool ourselves into thinking we have >>agreement. We have a concrete use case that is in contention that >>doesn't strike me as an edge case: a browsing history tied together by >>unique identifiers that stretches over a long time span, and has some >>fields altered, for example IP->Geo. Is this de-identified or not? If >>we >>can't answer that question, we don't have a good idea of what we are >>trying to define by the term. >> >>> >>> >>> _Identification and Unique Identifiers._ >>> >>> >>> >>> Another issue on identification and de-identification >>> concerns the June Draft text that “Third parties MUST NOT rely on >>> unique identifiers for users or devices if alternative solutions are >>> reasonably available.” >>> >>> >>> >>> Amy Colando proposed a change to add “technically >>> feasible” after “reasonably available.” >>> >>> >>> >>> The DAA group proposed deleting this provision entirely. >>> >>> >>> >>> For this discussion, it would be helpful to have >comments >>> and discussion on issues including: (1) the clarity (or lack >thereof) >>> of “reasonably available” and “technically feasible”; (2) evidence >>> that such alternatives are available today or may soon be available; >>> and (3) reasons for or against shifting to alternatives if they >>become >>> “reasonably available” and/or “technically feasible.” >>> >>My biggest problem with this language is the lack of clarity regarding >>"technically feasible" and "reasonably available", and it's puzzling >>since no-unique-id solutions exist today. After discussion with >various >>people, I don't think that it's too high a bar to forego the use of >>unique ids for DNT:1 users, except in one-off situations. For example, >>large successful ad companies have existed which do not use unique >ids. >>I have yet to hear a compelling need, but for web companies that may >>have one that hasn't been raised in this working group, they are free >>to >>not implement this voluntary tracking standard. >> >>> >>> >>> _The DAA Group proposal._ >>> >>> >>> >>> After these discussions, the DAA group is invited to >>> explain to the group its overall proposal for a path forward to Last >>> Call. As I understand it, the DAA group has presented an >integrated, >>> overall proposal, where it would support what essentially is a >>package >>> of proposed changes to the June Draft. >>> >>> >>> >>> With a presentation of this integrated package, the >group >>> can ask questions to clarify the multiple proposed changes, and >begin >>> a process of identifying areas where others in the group may agree >to >>> the proposal, or an amended version of theproposal, or else >>articulate >>> reasons why they would not join a consensus on the proposal. >>> >>> >>> >>> In terms of work leading up to Wednesday’s call, please >>> make proposed language changes directly to the wikis, while >>explaining >>> the rationale for changes to the full list. >>> >>> >>> >>> Thank you, and information on other next steps will >>> follow. (I note, however, that I likely will have limited >>> connectivity this weekend.) >>> >>> >>> >>> Peter >>> >>> >>> P.S. Please feel free to be working on the other change issues as >>> well, as a way to move forward as effectively as possible. The >point >>> of this email is to highlight the group work in the coming days. >>> >>> >>> >>> >>> >>> >>> >>> >>> >>> Prof. Peter P. Swire >>> C. William O'Neill Professor of Law >>> Ohio State University >>> 240.994.4142 >>> www.peterswire.net >>> >>> Beginning August 2013: >>> Nancy J. and Lawrence P. Huang Professor >>> Law and Ethics Program >>> Scheller College of Business >>> Georgia Institute of Technology >>>
Received on Wednesday, 3 July 2013 19:26:12 UTC