Re: June Tracking Compliance and Scope Draft Change Submission

In addition to John's questions, it would be very helpful for us to understand the range of functionalities allowed for permitted uses in your proposed Tri-State.

For example, what would be included in frequency capping under the Raw Data state?  Would that enable, as I assume, targeted ad rotation and/or "in-flight" real-time changes to a user (or their representative personna) in any way?  Listing what is acceptable for frequency capping in this state by the stakeholders is very important.  So too is understanding precisely what financial and auditing activities are permitted (including real-time reporting, for example).

For De-identified data, what are the activities specifically permitted for "product improvement."   How would insights from a DNT:1 user be used in a product improvement category?  Is the "Market Research" category solely based on the Esomar proposal or would it include the wide range of other market research activities undertaken by the major brands, platforms, research companies, etc.  As we know, there are many and growing approaches to digital and cross-platform research--much aimed at targeting users "in-flight."  

Finally, what financial and audit services and products would be included in that state as well.

A list , as well as your collective thoughts would be helpful for public understanding of what is precisely being proposed.

Best,

Jeff





Jeffrey Chester
Center for Digital Democracy
1621 Connecticut Ave, NW, Suite 550
Washington, DC 20009
www.democraticmedia.org
www.digitalads.org
202-986-2220

On Jun 28, 2013, at 9:03 AM, John Simpson wrote:

> Colleagues,
> 
> I am trying to reconcile Shane's slides explaining data de-identification  with the advertising industry's rewrite of the June Draft and understand how they relate to each other.  As I understand the slides,  certain permitted uses would use more restricted data sets -- yellow instead of red, for example.
> 
> 
> I don't see where how that is spelled out in your re-written specification.  Could someone please explain  how what is suggested in the slides is actually included in your text.  You define the de-identification process, but it is not at all clear to me how that is supposed to relate to permitted uses.
> 
> As is often the case, I may be missing something, but could you please explain where the text ties the various types of data sets to a permitted use?
> 
> Thank you,
> John
> 
> 
> On Jun 27, 2013, at 6:47 AM, Marc Groman <mgroman@networkadvertising.org> wrote:
> 
>> Good Morning John, 
>> 
>> While I appreciate and understand your request, given the very limited time provided for pulling this together, a line by line commentary was not possible by noon yesterday.  This is not an 11th hour approach, but a response to the recently released June document as requested by the Co-Chairs.  Everyone (believe me - everyone) is frustrated by the aggressive timeline set by the Co-Chairs.  We look forward to working with everyone to both understand this document and consider the wide range of issues now before the group.  We also thought that Shane would have more time to discuss the details on yesterday's call and answer questions, but unfortunately we didn't have time. 
>> 
>> Thank you very much. 
>> 
>> Sincerely, 
>> 
>> Marc 
>> 
>> ---
>> 
>> Marc M. Groman
>> Network Advertising Initiative | Executive Director and General Counsel 
>> 1634 Eye St. NW, Suite 750 Washington, DC 20006
>> P: 202-835-9810 | mgroman@networkadvertising.org 
>> 
>> 
>> <logo_NAI.gif>
>> 
>> On Jun 27, 2013, at 9:16 AM, John Simpson wrote:
>> 
>>> Jack,
>>> 
>>> The redline is helpful, but there is another problem.  To me at least it is even more serious.  During the working group's deliberations various proposals on raised issues have been made. There has always been an accompanying explanation and justification for the proposal.  People might not have agreed with a proposal, but they at least understood the thinking behind it.  You've presented your changes with no context, background or explanation.  I find it difficult to take such an 11th-hour approach seriously.  Indeed, if I didn't have a thick skin, I'd be insulted.
>>> 
>>> Cheers,
>>> John 
>>> 
>>> On Jun 27, 2013, at 4:58 AM, Jack Hobaugh <jack@networkadvertising.org> wrote:
>>> 
>>>> <NAI-DAA-DMA June 26 draft compared to June 22 Tracking Compliance and Scope copy.pdf>
>>> 
>>> 
>> 
>