Re: June Draft - Proposal for User Agent Compliance

Alan,

This is actually an important point.  We have been operating under an assumption that tracking could only occur by a "website", but really tracking could just as easily (perhaps even more easily) occur through a user agent.  It may be the case that this is not in fact widely occurring today, but it would seem very prudent to allow for this possibility particularly considering the potential sea change DNT is envisioned to have.

-Brooks


--

Brooks Dobbs, CIPP | Chief Privacy Officer | KBM Group | Part of the Wunderman Network
(Tel) 678 580 2683 | (Mob) 678 492 1662 | kbmg.com
brooks.dobbs@kbmg.com

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From: Alan Chapell <achapell@chapellassociates.com<mailto:achapell@chapellassociates.com>>
Date: Wednesday, June 26, 2013 1:36 PM
To: Alex Fowler <afowler@mozilla.com<mailto:afowler@mozilla.com>>, "public-tracking@w3.org<mailto:public-tracking@w3.org>" <public-tracking@w3.org<mailto:public-tracking@w3.org>>
Subject: Re: June Draft - Proposal for User Agent Compliance
Resent-From: <public-tracking@w3.org<mailto:public-tracking@w3.org>>
Resent-Date: Wednesday, June 26, 2013 1:36 PM

Sure.. In reviewing the June draft with colleagues, it occurred to me that some User Agents – technically speaking – could engage in tracking. My sense is that it is implicit that User agents would fall under the definition of third party under this spec and therefore would be subject to certain requirements. My goal was to make that more explicit. It may not be a big deal as both the DAA Code and the FTC consent order in the Sears case are generally in line with my proposed language.

I'm open to wording suggestions, or a debate on the merits.

Thanks,

Alan

From: Alex Fowler <afowler@mozilla.com<mailto:afowler@mozilla.com>>
Date: Wednesday, June 26, 2013 1:26 PM
To: <public-tracking@w3.org<mailto:public-tracking@w3.org>>
Subject: Re: June Draft - Proposal for User Agent Compliance
Resent-From: <public-tracking@w3.org<mailto:public-tracking@w3.org>>
Resent-Date: Wed, 26 Jun 2013 17:26:49 +0000

Alan -

I'm not sure I understand the intent of this proposed addition, Alan. Can you provide further info on what this means? My apologies if this is connected to a previous discussion that I missed.

Thanks,
Alex


On 6/26/13 8:49 AM, Alan Chapell wrote:
I propose adding the following:

A user agent MUST NOT track information related to the network interaction outside of the [Permitted Uses] and any explicitly-granted exceptions without consent.

Alan