June Draft - Change Proposal to Sec 3 "User Agents"

Section 3: "User Agents" sets requirements for user agents but confusingly includes websites.  I think the intent is to set the same standard for turning DNT on (user agent) as for turning DNT off (website exception).  But, because the two interactions are different, the section ends up being very confusing.

For instance, the current draft reads:  "That text MUST indicate that:
1) If the tracking preference is communicated, it limits collection and use of web viewing data for certain advertising and other purposes;
2) when DNT is enabled, some data may still be collected and used for certain purposes, and a description of such purposes; and
3) if a user affirmatively allows a particular party to collect and use information about web viewing activities, enabling DNT will not limit collection and use from that party."

Points 1 and 2 do not apply to websites requesting an exception because those describe the effects of turning DNT on.  I'm not sure if it is possible to tackle both of these concepts in one section although I'm open to suggestions.  For the time being, I propose deleting "websites" from this section and creating a new section to describe what websites should do when requesting an exception.


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