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Re: tracking-ISSUE-215: data hygiene approach / tracking of URL data and browsing activity [Compliance June]

From: Justin Brookman <jbrookman@cdt.org>
Date: Wed, 10 Jul 2013 14:28:22 -0400
Cc: Shane Wiley <wileys@yahoo-inc.com>, Rigo Wenning <rigo@w3.org>, "public-tracking@w3.org" <public-tracking@w3.org>
Message-Id: <BB80627E-D986-49D4-916C-4278ADCDE132@cdt.org>
To: Rob van Eijk <rob@blaeu.com>
As I read the (as-amended) DAA proposal, data enrichment would be OK.  Third parties can collect PII from a publisher (or otherwise) and then append demographic/other data to that profile.  Or they could sync attributes/scores with other ad networks.  All that is out of scope, because tracking is limited to retention and use of precise domains/urls.

OTOH, I believe that practice would be prohibited under Section 5 of the June draft.

Justin Brookman
Director, Consumer Privacy
Center for Democracy & Technology
tel 202.407.8812

On Jul 10, 2013, at 2:20 PM, Rob van Eijk <rob@blaeu.com> wrote:

> Shane,
> How does DNT interact with data exchanges? Are they allowed to enrich the combination of an <ID,scoring>, or is that out of scope because it is not tracking?
> Rob
> Shane Wiley <wileys@yahoo-inc.com> wrote:
> Rigo,
> Incorrect - no permitted use is needed as aggregate scoring is "not tracking" in that there is no retention of a user's cross-site browsing history in this case.  DNT compliance is removing the linkage between browsing activity and a user/device.
> - Shane
> -----Original Message-----
> From: Rigo Wenning [mailto:rigo@w3.org] 
> Sent: Wednesday, July 10, 2013 6:22 PM
> To: public-tracking@w3.org
> Cc: Shane Wiley; Rob van Eijk
> Subject: Re: tracking-ISSUE-215: data hygiene approach / tracking of URL data and browsing activity [Compliance June]
> On Wednesday 10 July 2013 16:23:45 Shane Wiley wrote:
> Activate the profiling opt-out (available via industry opt-out pages, 
> AdChoices icon, Chrome "K!
>  eep My
> Opt-Outs", industry persistency tools, 
> TACO, etc.).
> Opt-outs are great, please use mine! :) So you need a permitted use to ignore the DNT signal and only listen to other opt-outs. But why would you claim compliance to DNT here in the first place? I don't understand the goal of the permitted use here within the DNT concept. 
> --Rigo

Received on Wednesday, 10 July 2013 18:28:46 UTC

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