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further questions, 5.2 Audience measurement Issue 25: ACTION 415

From: Jeffrey Chester <jeff@democraticmedia.org>
Date: Fri, 28 Jun 2013 11:30:45 -0400
Cc: Mailing List <public-tracking@w3.org>
Message-id: <8A4CB5E0-21A9-4076-9F9B-DF5CF1157EDA@democraticmedia.org>
To: Kathy Joe <kathy@esomar.org>, Susan Israel <Susan_Israel@comcast.com>, Rigo Wenning <rigo@w3.org>
I spoke to some independent outside measurement experts (and shared the proposal with them).  Here are some questions they have.

1. Does the Esomar proposal only reflect a permitted use for panel-based research?  In other words, it does not seek an exemption for all the media/ market research techniques used today.

2.  How is the identification of online users to be included in the results determined?  Explain in the context of including DNT:1 users.

3.  How will publishers be able to use the data supplied, such as with their own data, that can further identify user-related behaviors?  In other words, can this information identify more than the number of users (such as details on the kinds of people who respond to various environments).

4.  Why is the online data, under non-normative, include First and Third party data.  What kind of Third party data is involved, and will it include behavioral data?

5.  Do the online users know they are being included in the audience measurement results?  Will they be asked to opt-in or opt-out?

6.  Will the proposed oversight body ensure that there is no malware involved as panels are created--so users fully understand about the data collection practices?

7.  Can the audience measurement research be used for any form of targeting (such as providing publishers with actuarial data that supplements their own data sets)?

8.  What data is available prior to the deidentified state?  What are the various products and how are they specifically used?



Jeffrey Chester
Center for Digital Democracy
1621 Connecticut Ave, NW, Suite 550
Washington, DC 20009

On Jun 21, 2013, at 10:12 AM, Kathy Joe wrote:

> Here is our change proposal to the TPC June Draft: text underlined indicates proposed amendments since the last f2f meeting
> Kathy Joe
> 5.2 Permitted Uses
> Current text: placeholder for audience measurement Issue 25
> Proposed text:
> Issue 25: Aggregated data collection and use for audience measurement research
> Normative:
> Information may be collected, retained and used by a third party for audience measurement research where the information is used to calibrate, validate or calculate through data collected from opted-in panels, which in part contains information collected across sites and over time from user agents.
> A third party eligible for an audience measurement research permitted use MUST adhere to the following restrictions. The data collected by the third party:
> •     Must be pseudonymised before statistical analysis begins, and
> •     Must not be shared with any other party unless the data are de-identified prior to sharing, and
> •     Must be deleted or de-identified as early as possible after the purpose of collection is met and in no case shall such retention, prior to de-identification, exceed 53 weeks and
> •     Must not be used for any other independent purpose including changing an individual’s user experience or building a profile for ad targeting purposes. 
> •     In addition, the third party must be subject to an independent certification process under the oversight of a generally-accepted market research industry organization that maintains a web platform providing user information about audience measurement research. This web platform lists the parties eligible to collect information under DNT standards and the audience measurement research permitted use and it provides users with an opportunity to exclude their data contribution.
> Non-normative: collection and use for audience measurement research
> Audience measurement research creates statistical measures of the reach in relation to the total online population, and frequency of exposure of the content to the online audience, including paid components of web pages.
> Audience measurement research for DNT purposes originates with opt-in panel output that is calibrated by counting actual hits on tagged content on websites. The panel output is re-adjusted using data collected from a broader online audience in order to ensure data produced from the panel accurately represents the whole online audience. Aggregate results from the panel can also be applied to the hits counted for specific content to describe the general character of the audience for that content
> This online data is collected on a first party and third party basis.  Audience measurement is centered around specific content, not around a user.
> The collected data is retained for a given period for purposes of sample quality control, and auditing.  During this retention period contractual measures must be in place to limit access to, and protect the data, as well as restrict the data from other uses. This retention period is set by auditing bodies, after which the data must be de-identified.  
> The purposes of audience measurement research must be limited to:
> ·    Facilitating online media valuation, planning and buying via accurate and reliable audience measurement.
> ·    Optimizing content and placement on an individual site.
> The term “audience measurement research” does not include sales, promotional, or marketing activities directed at a specific computer or device.  Audience measurement data must be reported as aggregated information such that no recipient is able to build commercial profiles about particular individuals or devices.
> Kathy Joe,
> Director, International Standards and Public Affairs
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Received on Friday, 28 June 2013 15:31:36 UTC

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