Re: ACTION-415 Provide text proposal regarding limitations on using a Potential Consent signal

Hi Team,


as expressed in the call, I would like to ensure that
  (a) The "P" flag only relaxes the requirements on 
transparency/notification.
  (b) The "P" flag does not give you any extra leeway/permisson to 
collect or track

As a consequence, I suggest to split this text into two orthogonal pieces:
  (A) A "P" flag that allows delayed notification (without any 
additional permitted use)
  (B) A permitted use for keeping data for "48h" (or some other 
short-term retention).

Text proposals for (A):

Normative: "A tracking status value of P indicates that a site is 
following third party rules ("3"), except for users who have given prior 
consent. Unlike /*C*/, the origin server does not know, in real-time, 
whether it has received prior consent for tracking this user, user 
agent, or device. Since this status value does not itself indicate 
whether consent has been received for a specific user, an origin server 
that sends a |P| tracking status value /must/ provide an |edit 
<http://www.w3.org/2011/tracking-protection/drafts/tracking-dnt.html#dfn-edit>| member 
in the corresponding tracking status representation that links to a 
resource for obtaining consent status."

Non-Normative: The |P| tracking status value is specifically meant to 
address audience survey systems for which determining consent at the 
time of a request is either impractical, due to legacy systems not being 
able to keep up with Web traffic, or potentially "gamed" by first party 
sites if they can determine which of their users have consented. The 
data cannot be used for the sake of personalization. If consent can be 
determined at the time of a request, the |C 
<http://www.w3.org/2011/tracking-protection/drafts/tracking-dnt.html#dfn-c>|tracking 
status should be used. *If an origin server subsequently determines that 
it does not have prior consent to track a user, the origin server may 
not then disregard the user's DNT:1 signal; rejections of DNT:1 signals 
must be made in real-time, using the tracking status value of D defined 
in 5.2.8.*


Text proposal for (B):
(SOME FLAG) This permitted use allows third parties to temporarily keep 
data for 48h. After this time (unless consent has been obtained), the 
third party compliance rules
     must be satisfied.


Opinions/Feedback?

Matthias


On 12/06/2013 17:02, Justin Brookman wrote:
>
>
>         I propose to add the bolded sentence to 5.2.7 of the TPE on
>         Potential Consent.
>
>
>         5.2.7 Potential Consent (P)
>
> A tracking status value of P means that the origin server does not 
> know, in real-time, whether it has received prior consent for tracking 
> this user, user agent, or device, but promises not to use or share any 
> |DNT:1| data until such consent has been determined, and further 
> promises to delete or de-identify within forty-eight hours any 
> |DNT:1| data received for which such consent has not been received.
>
> Since this status value does not itself indicate whether a specific 
> request is tracked, an origin server that sends a |P| tracking status 
> value /must/ provide an |edit 
> <http://www.w3.org/2011/tracking-protection/drafts/tracking-dnt.html#dfn-edit>| member 
> in the corresponding tracking status representation that links to a 
> resource for obtaining consent status.
>
> The |P| tracking status value is specifically meant to address 
> audience survey systems for which determining consent at the time of a 
> request is either impractical, due to legacy systems not being able to 
> keep up with Web traffic, or potentially "gamed" by first party sites 
> if they can determine which of their users have consented. The data 
> cannot be used for the sake of personalization. If consent can be 
> determined at the time of a request, the |C 
> <http://www.w3.org/2011/tracking-protection/drafts/tracking-dnt.html#dfn-c>|tracking 
> status is preferred. *If an origin server subsequently determines that 
> it does not have prior consent to track a user, the origin server may 
> not then disregard the user's DNT:1 signal; rejections of DNT:1 
> signals must be made in real-time, using the tracking status value of 
> D defined in 5.2.8.*
>

Received on Wednesday, 12 June 2013 20:54:31 UTC