Re: June Draft of the DNT compliance spec

Hi Alan,

On Jun 10, 2013, at 6:30 AM, Alan Chapell <achapell@chapellassociates.com> wrote:

> Thanks Peter. I'm still generally uncomfortable that DNT doesn't place requirements on First Parties. 
> 
> One item of particular concern that seems to have fallen off the radar is the scenario where a party collects data in a first party context and attempts to use it in a third party context when DNT is enabled. I thought there was agreement on this issue. However, I keep raising it, and it doesn't seem to make it into the drafts. Perhaps its implied in the language "… customize the content, services, and advertising in the context of the first party experience." However, it is not clear enough, IMHO.
> 
> To address, I offer the following language to Section 4 (First Party Compliance). The new language is below.
> 
> First Parties must not use data collected while a First Party when acting as a Third-Party when DNT = 1. 
> 
> Nick – if I need to open up another issue on this, please let me know. Thanks!

We have ISSUE-170: "Definition of and what/whether limitations around data append and first parties" open as the issue tracking this question. I believe the group does not have agreement on this issue, which is why it is one of the several OPEN issues post our recent cleanup.

Thanks,
Nick