- From: David Singer <singer@apple.com>
- Date: Tue, 09 Jul 2013 17:33:42 +0100
- To: "public-tracking@w3.org WG" <public-tracking@w3.org>
On Jul 9, 2013, at 17:18 , Rob van Eijk <rob@blaeu.com> wrote: > > 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. or we need to use de-identified in the way that it is commonly used? do we need more than one term? If we do, I'd rather use a new term for data that is identifiable but that takes some work (or access to keys) to be so, such as pseudonymized. So, in the DAA text, I'd change: de-identifed (where it is defined) to pseudonymized de-linked (where it is defined) to de-identified and leave the requirement that data must be de-identified (in the strong sense) to be out of scope. > > 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 wh! > en 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 > > This message and any attachments to it may contain PRIVILEGED AND CONFIDENTIAL ATTORNEY-CLIENT INFORMATION AND/OR ATTORNEY WORK PRODUCT exclusively for intended recipients. Please DO NOT FORWARD OR DISTRIBUTE to anyone else. If you are not an intended recipient, please contact the sender to report the error and then delete all copies of this message from your system. > > > > David Singer Multimedia and Software Standards, Apple Inc.
Received on Tuesday, 9 July 2013 16:34:10 UTC