Re: Proposed friendly amendments to industry draft

I am considering to formally object to the term de-identified in the DAA proposal.

The reasoning is that it has been used as synonym with 'the data it is not about a person anymore'. We need another word. 

I am proposing to simply use the term linkable.

Rob


"Israel, Susan" <Susan_Israel@Comcast.com> wrote:

>his document and how they may be used elsewhere, it may help to
>introduce the definitions by saying, "For purposes of this
>specification, ...." 
>
>Substantive:  To clarify one of the differences between the
>de-identified and de-linked categories as I understand them, it may be
>helpful to add language that indicates that the de-identified category
>permits reliance on operational controls in addition to technical
>controls, which I believe is consistent with the ideas Thomas Schauf
>presented.  
>
>Thus, the definition would read, "Data is de-identified when a party
>
>1. has taken reasonable steps to ensure that the data cannot be
>reasonably re-associated or connected to a specific user, computer, or
>device without the use of additional data that is subject to separate
>and distinct technical and organizational controls to ensure such
>non-attribution, or when such attribution would require a
>disproportionate amount of time, expense and effort; ...." 
>
>I also support adding the audience measurement language that has been
>discussed and revised with  several participants and submitted by
>Esomar to the permitted uses section, 5.2. 
>
>
>
>
>Susan Israel
>Comcast Cable
>215.286.3239
>215.767.3926 mobile
>917.934.1044 NY
>susan_israel@comcast.com
>
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