Re: June Draft - Change Proposal to definition of "share"

Hi Chris,

Amy Colando has raised a similar concern regarding the definition of "share" and proposed a definition based on "transfers or provides a copy":
http://www.w3.org/wiki/Privacy/TPWG/Change_Proposal_Transience_Collection#Shares_as_transfers

Is it possible that you would accept that definition? I believe your definition also tries to include exceptions for permitted uses and service providers, but by putting that into the definition itself, it would be impossible by definition for a party to share data with a service provider.

Thanks,
Nick

On Jun 26, 2013, at 6:36 AM, Chris Pedigo <CPedigo@online-publishers.org> wrote:

> 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
>