Re: Fw: New text Issue 25: Aggregated data: collection and use for audience measurement research

Thanks Kathy,

I want to add to the discussion that panel members are a form of out of band consent and can therefore be left out of scope for DNT.
For users who have not opted-in to audience measurement, my position is that DNT must be meaningful. A wide interpretation of audience measurement under a generic exception for aggregated reporting should not be the way forward.

Talking shortly to David Stark on this, he suggested to increase transparence by using a visible element on a page, instead of a hidden pixel. I think it is a great idea. It enables transparency, and is an important step towards convincing users to give consent to audience measurement.

I will add to that,  in the discussion here, that the pixel is not the right technology under DNT to fulfull the audience measurement need. My position is that if the technology is not capable of triggering an exception as suggested in the technical spec, the way forward should not be to allow for that limitation in technology throug an exception in the compliance spec.

In short, I raise severe concerns against the proposed text.

RobvE

Kathy Joe <kathy@esomar.org> wrote:

>Here below is the revised text for issue 25 discussed with Justin and
>others in the group with some modifications to take Justin's comments
>into account.
>
>Information may be collected to create statistical measures of the
>reach in relation to the total population, and frequency of exposure of
>the content to the online audience, including paid components of web
>pages. One such method is through using a panel of users who have
>affirmatively agreed to have their media consumption and web surfing
>behavior measured across sites.
>
>The panel output is calibrated by counting actual hits on tagged
>content and re-adjusting the results in order to ensure data produced
>from the panel accurately represents the whole audience. The counts
>must be pseudonomised. Counts are retained for sample, quality control,
>and auditing purposes during which time contractual measures must be in
>place to limit access to, and protect the data from other uses. A 53
>week retention period is necessary so that month over month reports for
>a one year period may be re-run for quality checking purposes, after
>which the data must be de-identified. The counted data is largely
>collected on a first party basis, but to ensure complete
>representation, some will be third party placement. This collection
>tracks the content rather than involving the collection of a user's
>browser history.
>
>The purposes 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.
>
>Audience measurement data must be reported as aggregated information
>such that no recipient is able to build commercial profiles about
>particular individuals or devices.
>
>To clarify a comment from Justin about auditing, note that  audience
>measurement systems (whether TV, radio, print or online) are usually
>managed or monitored by an independent body as
>guarantee of accuracy with various stakeholders in a joint industry
>body defining what is needed to provide a robust and impartial system. 
>
>MRC handles this in the US whilst the JICWEBs reporting standards of
>ABC handles this in the UK and AGMA  is the German audit body. Here is
>a longer list 
>http://www.i-jic.org/index.php?PHPSESSID=55143f172846ed39c7958cbeb837a85a
>and here is ABC 
>http://www.abc.org.uk/PageFiles/50/Web%20Traffic%20Audit%20Rules%20and%20Guidance%20Notes%20version2%20March%202013%20master.pdf
>
>Regards
>
>Kathy Joe
>ESOMAR