Re: June Change Proposal: Section 5

Critical to Section 5, both as written in the draft and as in the proposed change is non-normtive text that identifies some alternative solutions and what it means to be reasonably available and now "technically feasible."

If "alternative solutions" in fact represent a null set, then Section 5.1.2 does nothing at all and carries no obligation...



On Jun 26, 2013, at 6:59 AM, "Amy Colando (LCA)" <acolando@microsoft.com> wrote:

> SECTION 5: THIRD PARTY COMPLIANCE
> 
> We suggest modifying Section 5.1.2 as by adding text at the end of the sentence:  "Third parties MUST make reasonable data minimization efforts to ensure that only the data necessary for the permitted use is retained, and MUST NOT rely on unique identifiers for users or devices if alternative solutions are reasonably available AND TECHNICALLY FEASIBLE."
> 
> o	Rationale: This modification helps to flag for implementers the robust background discussion in TPWG on the feasibility of moving systems at scale to alternatives to unique identifiers for permitted uses.  Microsoft looks forward to continuing to engage with multiple stakeholders on this issue.
> 
> 
> We suggest modifying the last sentence of Section 5.1.4 by adding text at the end of the sentence to replace the word "auditable":  Third parties SHOULD ensure that the access and use of data retained for Permitted Uses is INTERNALLY VERIFIABLE.
> 
> o	Rationale: This modification helps to communicate to implementers that they do not need to allow access to data centers by third party auditors in order to implement DNT.
> 
> 
> 
> We support David Singer's proposed modifications to Section 5.3 on geolocation.
> 
>

Received on Wednesday, 26 June 2013 14:15:52 UTC