June Draft - Change Proposal to definition of "share"

I propose changing the definition of "share" in Section 2.  Currently, it reads "A party shares data if the party enables another party to receive or access that data."

This current definition would leave 1st parties in violation of this standard by simply allowing a 3rd party to collect data on their site.  Even if the 3rd party was only collecting data for one of the Permitted Uses, the 1st party would be in violation simply because it allowed the 3rd party access.  So, I am proposing the following change.

"A party shares data if it transfers data to another party for use outside of the exceptions for service providers or other than the permitted uses for 3rd parties. "


Chris Pedigo
VP, Government Affairs
Online Publishers Association
(202) 744-2967