Re: Proposed friendly amendments to industry draft

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
> 
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> 
> 
> 

David Singer
Multimedia and Software Standards, Apple Inc.

Received on Tuesday, 9 July 2013 16:34:10 UTC