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Re: Revised text issue 25: Aggregated data collection and use for audience measurement research: ACTION 415

From: Justin Brookman <jbrookman@cdt.org>
Date: Fri, 21 Jun 2013 11:07:25 -0400
To: "Kathy Joe" <kathy@esomar.org>
Cc: public-tracking@w3.org
Message-ID: <20130621150725.e49bb484@mail.maclaboratory.net>

 Also,  more specific information about why this calibration is necessary would be very  helpful.  The mental standard I've been using for permitted uses  is purposes that are strictly necessary for the web (including contextual  advertising) to work.  I don't feel you've made the case why calibration  of panels falls into that category, other than vague pronouncements that  "advertising will go away without it."  Chanin's powerpoint only  uses hypothetical figures and vague demands from Randall Rothenberg.  It  just doesn't seem intuitive given that other media seem to work without such  calibration; I think the burden is on your side especially given that you're  looking to supersede user's affirmative decision to opt out of your tracking.    

Answer: Research and  measurement have historically informed the process of understanding media reach  and exposure whether it is TV, print, radio or outdoor and for those media we  can work with panel data only because the universe of possible stations or  media vehicles is known. No panel can accurately or completely represent all  the traffic, including international, to a website. Panels may not include web  traffic from the workplace if panelists cannot download the software to the  work computers.    

The internet is  a much more fragmented and global medium than traditional media and growth and  usage worldwide are much more dynamic. For instance, many sites are too small  to generate a statistically robust audience from a panel. It may be impossible  to build a sample size large enough to fully represent internet traffic or  visitation activities with more than 33 billion web pages available.     

AMR helps advertisers  better plan their media campaigns and the panel foundation with broader data  for calibration ensures that larger sites are not overstated and smaller ones  ignored in online traffic numbers. The  data used by financial auditing bodies is based on metrics originating from  this research - just as with print, one looks at annual circulation figures and  the position of the ad to fix the rate. Core audience measurement metrics are  unique visits, site visits and page views, number of visitors to a given  website in a given period, and a general indication of geography.
    Kathy Joe, thanks for the helpful answer to this question.  I appreciate the description about why census data is useful to better understand long tail sites that a small group of panelists may not give reliable insight into.  However . . .


AMR counts  cookies and we do not believe that counting is tracking. There is no impact on an  individual. If users have to give their consent every time an ARM cookie is  placed, users would not be better protected but this would be the only medium  which cannot provide transparency and accountability for its advertisers.
This is not correct.  Logging page views tied to unique cookies is tracking --- that's why you are seeking a permitted use exception under the standard.  If you're not logging individualized data, you don't need this language.  I appreciate that you're not altering the user experience and that it's for societally beneficial audience measurement purposes.  But it's still tracking.

It's also not correct to say that we're asking you to get consent every time an ARM cookies is placed.  Under US law at least, you can probably place an ARM cookie on a user's computer in most cases with no consent whatsoever.  However, when a user goes out of their way to make a Do Not Track choice, the presumption should be that that turns off tracking unless data collection is strictly necessary.  Audience measurement companies will still get census data from non DNT:1 users, and can even count anonymous page views from DNT:1 devices.  Can you make a compelling case that that data won't be enough (along with the panels, of course) to accomplish what you accomplish today with minimal loss in functionality?

    From: Jeffrey Chester [mailto:jeff@democraticmedia.org]
To: Kathy Joe [mailto:kathy@esomar.org]
Cc: Ed Felten [mailto:ed@felten.com], <public-tracking@w3.org> [mailto:public-tracking@w3.org]
Sent: Wed, 19 Jun 2013 17:41:53 +0100
Subject: Re: Revised text issue 25: Aggregated data collection and use for audience measurement research: ACTION 415

Kathy Joe:

There is still insufficient detail here--nor a response as yet to Justin's very key critique.  Before any measurement permitted use should be permitted, more information must be provided.  It especially needs to address the current changes in market research used to collect and analyze users over multiple devices and also via diverse experiences (in-store, etc).  How can a spec be approved that look's at yesterday's market research paradigm?




Jeffrey Chester

Center for Digital Democracy
1621 Connecticut Ave, NW, Suite 550
Washington, DC 20009

On Jun 19, 2013, at 11:34 AM, Kathy Joe wrote:

Hi Ed,
Answers below in bold.

From: Ed Felten [mailto:ed@felten.com]
To: Kathy Joe [mailto:kathy@esomar.org]
Cc: <public-tracking@w3.org> [mailto:public-tracking@w3.org]
Sent: Wed, 19 Jun 2013 14:58:45 +0100
Subject: Re: Revised text issue 25: Aggregated data collection and use for audience measurement research: ACTION 415

As in the previous version, it seems that the "non-normative" text includes a bunch of normative requirements (e.g., "The purposes of audience measurement research must be limited to...", as well as the definition of the term "audience measurement research" itself) as well as some descriptive language that could be read as normative (e.g., "This collection tracks the content accessed by a device rather than involving the collection of a user’s browser history...")  It's important to be clear about what is required and what is not.We attempted to separate out the normative requirements from normative text and are happy to review this again for clarity. 
The normative text has a requirement of certification by some other body.  Which bodies exist that could provide the certification required by this language?  How do we know what standards those bodies would apply, and whether they would be consistent with the DNT standard?  And what rationale do we have for allowing those bodies to determine "the parties eligible to collect information under DNT standards and the audience measurement research permitted use"? 

This body is being set up to be consistent with the W3C DNT standard and parties eligible would need to abide by the audience measurement research permitted use in the DNT standards to provide transparency and choice.

research permitted use and it provides users with an opportunity to exclude their data contribution.

On Tue, Jun 18, 2013 at 2:57 PM, Kathy Joe <kathy@esomar.org> wrote:

 At the last meeting it was agreed that a group including Susan, Richard and Rigo, should review the text.
Here attached is the wording which has been adapted in the normative section to clarify what was meant by 'calibrate or otherwise support' to enable research companies to adjust the census data based on the general categories from the panel data to ensure accurate counts of reach and frequency for an ad., see slides 15 and 16 of the comScore presentation.

And if needed, this non-normative text to explain the use of panel data to calibrate census data can be inserted an additional sentence to paragraph 2 in the non-normative section.“ Aggregate results from the panel can also be applied to the hits counted for specific content to describe the general character of the audience for that content”.

Kathy Joe,
Director, International Standards and Public Affairs

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Received on Friday, 21 June 2013 15:07:56 UTC

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