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Re: June Change Proposal, third party compliance

From: John Simpson <john@consumerwatchdog.org>
Date: Fri, 21 Jun 2013 06:23:06 -0700
Message-Id: <1871906C-02F8-42C7-880B-A4DE7222D10F@consumerwatchdog.org>
To: public-tracking@w3.org, David Singer <singer@apple.com>
David,

What is the definition of "tracking information you are using?  Is it from definitions in June draft, i.e.: "Tracking is the retention or use, after a network interaction is complete, of data records that are, or can be, associated with a specific user, user agent or device"?

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Problem

"If a third party receives a DNT: 1 signal, then:

	 the third party must not collect, retain, share, or use information related to the network interaction as part of which it received the DNT: 1 signal outside of the permitted uses as defined within this standard and any explicitly-granted exceptions provided in accordance with the requirements of this standard;
	 the third party must not use information about previous network interactions in which it was a third party, outside of the permitted uses as defined within this standard and any explicitly-granted exceptions, provided in accordance with the requirements of this standard."


1) We imply but nowhere say, that what third parties must do under DNT:1 is to reduce 'tracking', as defined.
2) We don't allow out-of-band-consent.
3) Exceptions don't need to be mentioned, as they cause DNT:0 to be sent, not DNT:1.

Proposal

Insert 'tracking' twice and remove exceptions:

If a third party receives a DNT: 1 signal, then, unless it has consent from the user:

	 the third party must not collect, retain, share, or use tracking information related to the network interaction as part of which it received the DNT: 1 signal outside of the permitted uses as defined within this standard;
	 the third party must not use tracking information about previous network interactions in which it was a third party, outside of the permitted uses as defined within this standard.


David Singer
Multimedia and Software Standards, Apple Inc.
Received on Friday, 21 June 2013 13:23:33 UTC

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