Re: Proposed friendly amendments to industry draft

David,
I support the proposed change of wording.

s/de-identified/pseudonymized/ 
AND 
s/de-linked/de-identified/

Rob



David Singer <singer@apple.com> wrote:

>
>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.