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Re: June Change Proposal, third party compliance

From: David Singer <singer@apple.com>
Date: Fri, 21 Jun 2013 09:02:11 -0700
Cc: public-tracking@w3.org
Message-id: <F2FAC726-C982-4AAE-94DC-15895636FCDC@apple.com>
To: John Simpson <john@consumerwatchdog.org>

On Jun 21, 2013, at 6:23 , John Simpson <john@consumerwatchdog.org> wrote:

> 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"?

yes, that's the intent -- to connect the proscription to the definition. it's implied but not actually stated.

> 
> --
> 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.
> 

David Singer
Multimedia and Software Standards, Apple Inc.
Received on Friday, 21 June 2013 16:02:40 UTC

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