Re: ISSUE-25 on the agenda for the October 02 call

I'd like to offer a change proposal to the ISSUE-25 text that Kathy supplied:  In the bullet on secondary uses, I would suggest that we specify that the data "Must not be used for any purpose not otherwise permitted under this specification" rather than to say that it can't be used for an independent purpose, including profiling individual browsing behavior for advertising purposes.  There are two thoughts behind this:

(1) It is generally not permitted to build ad profiles of DNT:1 browsers' individual browsing histories.  Saying this here seems to imply that it might be okay under other permitted uses, which I don't think is the intention.
(2) I'd imagine that most parties that do audience measurement would also need to use data they collect for other permitted uses — particularly, for technical purposes (making sure the system is working) or for security.  Likewise, everyone has to comply with legal obligations, as our draft reflects.  I don't think that this permitted use necessarily should be invalidated just because a company might engage in another permitted use or have to comply with legal obligations.

I don't think this is a change in the general intention of the draft, but I believe this change is helpful to avoiding any unintended consequences.

Rob Sherman
Facebook | Manager, Privacy and Public Policy
1299 Pennsylvania Avenue, NW | Suite 800 | Washington, DC 20004
office 202.370.5147 | mobile 202.257.3901

From: Kathy Joe <kathy@esomar.org<mailto:kathy@esomar.org>>
Date: Friday, October 4, 2013 2:52 AM
To: Rob Sherman <robsherman@fb.com<mailto:robsherman@fb.com>>, Matthias Schunter <mts-std@schunter.org<mailto:mts-std@schunter.org>>, "(public-tracking@w3.org<mailto:public-tracking@w3.org>)" <public-tracking@w3.org<mailto:public-tracking@w3.org>>, "Edward W. Felten" <felten@CS.Princeton.EDU<mailto:felten@CS.Princeton.EDU>>
Cc: David Stark <david.stark@gfk.com<mailto:david.stark@gfk.com>>, "'Weaver, Richard'" <rweaver@comscore.com<mailto:rweaver@comscore.com>>, Ronan Heffernan <ronan.heffernan@nielsen.com<mailto:ronan.heffernan@nielsen.com>>, "Berkower, Elise" <elise.berkower@nielsen.com<mailto:elise.berkower@nielsen.com>>, "George.Pappachen@kantar.com<mailto:George.Pappachen@kantar.com>" <George.Pappachen@kantar.com<mailto:George.Pappachen@kantar.com>>, 'Adam Phillips' <adam.phillips@realresearch.co.uk<mailto:adam.phillips@realresearch.co.uk>>, Susan Israel <Susan_Israel@Comcast.com<mailto:Susan_Israel@Comcast.com>>
Subject: ISSUE-25 on the agenda for the October 02 call

Hi Rob,

Many thanks for your note.

Whilst there might be a range of audience measurement techniques, Issue 25 is specifically in connection with calibrating data obtained via opted-in panels.

The key point is that since Issue 25 requires that only aggregated data be provided to clients, and that there is no release of PII collected for AMR for other purposes, we believe there needs to be independent oversight to check that companies claiming the AMR exemption are complying, with consistent application worldwide, also providing consumer information to provide an additional level of transparency and education for users.

We would be willing to move the paragraph on the ‘independent certification process’ to the non-normative section, especially as it was pointed out that the W3C standards do not include other compliance requirements. We also remain open to further discussion as the standard evolves in practice.
Kathy Joe,
Director, International Standards and Public Affairs
<https://urldefense.proofpoint.com/v1/url?u=http://www.esomar.org/&k=ZVNjlDMF0FElm4dQtryO4A%3D%3D%0A&r=Z08z%2F0RKK7k0ZWnWkl%2FVHThU6eMXcoJl9ldvo4wGeN0%3D%0A&m=Q6HBWsbihgDbba%2BNHrZDNK92Y0PFBIKKaaKFZWjx1HI%3D%0A&s=98c5c0f473b70d482eb8531b4b0729feedaff5f11d7b4c25c73a6913b7e47916>
To: Kathy Joe [mailto:kathy@esomar.org], Matthias Schunter (Intel Corporation) [mailto:mts-std@schunter.org], (public-tracking@w3.org<mailto:public-tracking@w3.org>) [mailto:public-tracking@w3.org], Edward W. Felten [mailto:felten@CS.Princeton.EDU]
Cc: David Stark [mailto:david.stark@gfk.com], 'Weaver, Richard' [mailto:rweaver@comscore.com], Ronan Heffernan [mailto:ronan.heffernan@nielsen.com], Berkower, Elise [mailto:elise.berkower@nielsen.com], George.Pappachen@kantar.com<mailto:George.Pappachen@kantar.com> [mailto:George.Pappachen@kantar.com], 'Adam Phillips' [mailto:adam.phillips@realresearch.co.uk], Israel, Susan [mailto:Susan_Israel@Comcast.com]
Sent: Thu, 03 Oct 2013 04:56:37 +0100
Subject: Re: ISSUE-25 on the agenda for the October 02 call

Kathy,

I apologize that I missed the call today and wasn't able to participate in the discussion, but I do have a question about the last point that Ed raised below:  I understand that AMR members have a particular framework in mind, but it seems most sensible to develop a permitted use for audience measurement that would apply to any party that wanted to engage in that practice, regardless of whether it was a member of a particular association or had a particular auditor.  Would you consider modifications to the proposal that would make an association membership/auditing component optional but that would enable other parties to comply even if they were not eligible to or chose not to join the association?

I think this comes up most significantly in the last bullet of your normative text, but there may be aspects of the non-normative text that are helpful for explanation within this group as we decide on what is the right path forward but that so specifically describe particular companies' business models that they're less helpful in a specification.

Thanks.

Rob

Rob Sherman
Facebook | Manager, Privacy and Public Policy
1299 Pennsylvania Avenue, NW | Suite 800 | Washington, DC 20004
office 202.370.5147 | mobile 202.257.3901

From: Kathy Joe <kathy@esomar.org<mailto:kathy@esomar.org>>
Date: Wednesday, October 2, 2013 7:21 AM
To: Matthias Schunter <mts-std@schunter.org<mailto:mts-std@schunter.org>>, "(public-tracking@w3.org<mailto:public-tracking@w3.org>)" <public-tracking@w3.org<mailto:public-tracking@w3.org>>, "Edward W. Felten" <felten@CS.Princeton.EDU<mailto:felten@CS.Princeton.EDU>>
Cc: David Stark <david.stark@gfk.com<mailto:david.stark@gfk.com>>, "'Weaver, Richard'" <rweaver@comscore.com<mailto:rweaver@comscore.com>>, Ronan Heffernan <ronan.heffernan@nielsen.com<mailto:ronan.heffernan@nielsen.com>>, "Berkower, Elise" <elise.berkower@nielsen.com<mailto:elise.berkower@nielsen.com>>, "George.Pappachen@kantar.com<mailto:George.Pappachen@kantar.com>" <George.Pappachen@kantar.com<mailto:George.Pappachen@kantar.com>>, 'Adam Phillips' <adam.phillips@realresearch.co.uk<mailto:adam.phillips@realresearch.co.uk>>, Susan Israel <Susan_Israel@Comcast.com<mailto:Susan_Israel@Comcast.com>>
Subject: ISSUE-25 on the agenda for the October 02 call
Resent-From: <public-tracking@w3.org<mailto:public-tracking@w3.org>>
Resent-Date: Wednesday, October 2, 2013 7:23 AM

Hi there

We note that ISSUE-25 is on the agenda for today and wanted to provide the group with answers to Ed Felten’s questions:

http://www.w3.org/wiki/Privacy/TPWG/Change_Proposal_Audience_Measurement/Open_Questions<https://urldefense.proofpoint.com/v1/url?u=http://www.w3.org/wiki/Privacy/TPWG/Change_Proposal_Audience_Measurement/Open_Questions&k=ZVNjlDMF0FElm4dQtryO4A%3D%3D%0A&r=Z08z%2F0RKK7k0ZWnWkl%2FVHThU6eMXcoJl9ldvo4wGeN0%3D%0A&m=USaqxvSAORpYWvXL2C1%2BWQlYOQ8ufziCvnLYqum9G1U%3D%0A&s=37f5e9388d38afb5b415030c81d90bd2f556cef97013d1ba0b55cb4da45467d1>

Regards

Kathy Joe

Ed Felton’s questions:
1.   What does "identifying" mean in this text? (One might read "without identifying" as requiring that data be "de-identified" according to the definition that appears elsewhere in the spec. But if the data qualifies as de-identified then no permitted use is required here because the general safe harbor for de-identified data already applies. Alternatively, if "identifying" means something different here, then that should be spelled out.)
2.   What does "unique key-coded data" mean? Is the text about "unique key-coded data ..." meant to serve as a definition of "pseudonymized"? If so, it seems overly prescriptive, requiring one particular method that (purportedly) qualifies as pseudonymized. Alternatively, this text might be read as requiring a particular (purported) pseudonymization method. If so, why require this particular method?

Answer: The controls regarding the census data include assigning a random number to the record and obfuscating the last three digits of the IP address. These are the current minimum requirements. Different companies may adopt further pseudonymization practices for technical reasons and these may change with technology or with national law eg in Germany it is required that the IP address is hashed as well.
If there is future agreement at international level on pseudonymization standards or definition, we will adhere to these if they are higher than our standards as they become available. The census data is held securely, as is all audience research data, and deleted within the maximum time period for validation and auditing.

We note that the wording is open to misinterpretation because the data is pseudonomized during processing, and then aggregated (ie de-identified ) data is provided to clients as statistical reports. Therefore without specifying the method used for pseudonomization, alternative wording could describe a testable outcome:

CURRENT TEXT: The data collected by the third party:
Must be pseudonymized before statistical analysis begins, such that unique key-coded data are used to distinguish one individual from another without identifying them.

NEW PROPOSAL: The data collected by the third party:
Must be pseudonymized before statistical analysis begins, such that it is possible to distinguish one individual from another but the data by itself, cannot be attributed to a specific device.

Ed Felton’s question
3.   Why allow pseudonymization to be delayed until "statistical analysis begins"? Why not require pseudonymization to be done promptly when data is initially collected?
Answer: This data first needs to be filtered on a continuous basis to detect fraudulent activity such as web bots. As the campaign progresses, you may detect additional doubtful elements and then need to re-process the data again to check that they are removed. Once it is certain that the data is clean, it is pseudonymized before analysis.

Ed Felton questions
The "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 ..."

4.   The authors appear to have a specific organization in mind. Which organization is  that, and who runs it?

5.      What is the rationale for giving a particular organization control over the certification process and the ability to declare who is eligible to exercise this permitted use?

Answer:The proposal for Issue 25 has been developed by the major global providers of AMR. This paper is intended to provide clarity about why the proposal has been written in the way it has and to help people who are not familiar with this kind of market research understand how our industry works to protect consumers’ personal information, ensure that advertising money is spent efficiently and encourage effective competition and good innovation by media publishers. We have tried to incorporate sufficient protections in the specification to provide reassurance to the members of W3C that this is in fact the case, but we remain willing to discuss further issues of clarification or amendment which will provide additional clarity and reassurance.

As noted, explanations and opt-outs are currently offered by AMR providers separately and there are various self-regulatory mechanisms already in place. The intention in Issue 25 is to provide an additional level of transparency and education for users, noting that this use case is not immediately apparent even for experts in this W3C group. We think that a common AMR explanation and opt-out will help users understand the purpose, and ensure that this permitted use remains with the boundaries specified by the W3C standard. The body would be set up with the participating research companies as founder members with expert oversight and all companies operating in this field are welcome to join. We remain open to moving this into the non normative section of Issue 25 and further discussion as the standard evolves in practice.

Kathy Joe,
Director, International Standards and Public Affairs
<https://urldefense.proofpoint.com/v1/url?u=http://www.esomar.org/&k=ZVNjlDMF0FElm4dQtryO4A%3D%3D%0A&r=Z08z%2F0RKK7k0ZWnWkl%2FVHThU6eMXcoJl9ldvo4wGeN0%3D%0A&m=USaqxvSAORpYWvXL2C1%2BWQlYOQ8ufziCvnLYqum9G1U%3D%0A&s=4e112aea4afc7c444b0d34cfdfd4c8387233ec1d34b260d07c2cd86a1a7ccac3>
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From: "Matthias Schunter (Intel Corporation)" <mts-std@schunter.org<mailto:mts-std@schunter.org>>
Date: Tuesday, October 1, 2013 5:34 PM
To: "public-tracking@w3.org<mailto:public-tracking@w3.org> (public-tracking@w3.org<mailto:public-tracking@w3.org>)" <public-tracking@w3.org<mailto:public-tracking@w3.org>>
Subject: Agenda for the October 02 call (V01)
Resent-From: <public-tracking@w3.org<mailto:public-tracking@w3.org>>
Resent-Date: Tue, 01 Oct 2013 15:34:30 +0000

Hi Team,


enclosed is the first draft of an agenda for next Wednesday.
Feedback/comments are welcome.

By end of October 02, we have now concluded Phase 1 (collection of issues and publishing a working draft) and are now transitioning to Phase 2 (addressing all issues one-by-one). We start with the issues where no input will be provided anymore (5, 10, 24, 25, ...). The documentation for new issues can still be enhanced until October 16.

Re-Reminder: Note that Wednesday is the last day where new issues can be raised.....

Note that we are now starting to prepare 4 issues for determining the corresponding change proposal to determine consensus.
The goal is to identify one change proposal for each of them that emerges as consensus.


Regards,
matthias

------------------------------

1. Confirmation of scribe.  Volunteers welcome

2. Offline-caller-identification (see end for instructions)

3. Our perspective on how to shape change proposals (Carl/Matthias)

4. Survey of newly raised issues if any (authors of issues)
    - If you have added an issue, I would like to learn about the new issue
      by means of its author explaining the issue and the proposed resolution

----  Processing of issues ---

7.  ISSUE-10 [Justin]
     http://www.w3.org/2011/tracking-protection/track/issues/10<https://urldefense.proofpoint.com/v1/url?u=http://www.w3.org/2011/tracking-protection/track/issues/10&k=ZVNjlDMF0FElm4dQtryO4A%3D%3D%0A&r=Z08z%2F0RKK7k0ZWnWkl%2FVHThU6eMXcoJl9ldvo4wGeN0%3D%0A&m=USaqxvSAORpYWvXL2C1%2BWQlYOQ8ufziCvnLYqum9G1U%3D%0A&s=4cc17ecdfe7e1638c9d34b0dc239c9268dd5258221845e5c190fb6f36cfbaf87>
     http://www.w3.org/wiki/Privacy/TPWG/Change_Proposal_Party_Definitions<https://urldefense.proofpoint.com/v1/url?u=http://www.w3.org/wiki/Privacy/TPWG/Change_Proposal_Party_Definitions&k=ZVNjlDMF0FElm4dQtryO4A%3D%3D%0A&r=Z08z%2F0RKK7k0ZWnWkl%2FVHThU6eMXcoJl9ldvo4wGeN0%3D%0A&m=USaqxvSAORpYWvXL2C1%2BWQlYOQ8ufziCvnLYqum9G1U%3D%0A&s=f25286fe2f2361fd8acbd820b9fe7d69da295253fd1080de86bb5b848bc5cda3>
     As indicated in our plan, ISSUE-10 will now be resolved in the coming weeks according to the plan below.

    On October 02, we will to issue the "call for final change proposals" (deadline: October 09).

8. ISSUE-5  [Matthias]
     http://www.w3.org/2011/tracking-protection/track/products/5<https://urldefense.proofpoint.com/v1/url?u=http://www.w3.org/2011/tracking-protection/track/products/5&k=ZVNjlDMF0FElm4dQtryO4A%3D%3D%0A&r=Z08z%2F0RKK7k0ZWnWkl%2FVHThU6eMXcoJl9ldvo4wGeN0%3D%0A&m=USaqxvSAORpYWvXL2C1%2BWQlYOQ8ufziCvnLYqum9G1U%3D%0A&s=a3894444d87488cf5fc412d306b6d1c07ee3c6b8e7954944047e73d310ab8503>
     http://www.w3.org/wiki/Privacy/TPWG/Change_Proposal_Tracking_Definition<https://urldefense.proofpoint.com/v1/url?u=http://www.w3.org/wiki/Privacy/TPWG/Change_Proposal_Tracking_Definition&k=ZVNjlDMF0FElm4dQtryO4A%3D%3D%0A&r=Z08z%2F0RKK7k0ZWnWkl%2FVHThU6eMXcoJl9ldvo4wGeN0%3D%0A&m=USaqxvSAORpYWvXL2C1%2BWQlYOQ8ufziCvnLYqum9G1U%3D%0A&s=31a344d8f06fa50fec6292df28600c85f48e719a9909a7e692d188bcea5582f6>
   As indicated in our plan, this issue will now be resolved in the coming weeks according to the plan below.

    On October 02, we will to issue the "call for final change proposals" (deadline: October 09).

9. ISSUE-24 [Carl]
     http://www.w3.org/2011/tracking-protection/track/issues/24<https://urldefense.proofpoint.com/v1/url?u=http://www.w3.org/2011/tracking-protection/track/issues/24&k=ZVNjlDMF0FElm4dQtryO4A%3D%3D%0A&r=Z08z%2F0RKK7k0ZWnWkl%2FVHThU6eMXcoJl9ldvo4wGeN0%3D%0A&m=USaqxvSAORpYWvXL2C1%2BWQlYOQ8ufziCvnLYqum9G1U%3D%0A&s=5e8390634dddd23d97d2a6608b6f5557a3602550103e78d88ced5bd438cf0f62>
     http://www.w3.org/wiki/Privacy/TPWG/Change_Proposal_Security<https://urldefense.proofpoint.com/v1/url?u=http://www.w3.org/wiki/Privacy/TPWG/Change_Proposal_Security&k=ZVNjlDMF0FElm4dQtryO4A%3D%3D%0A&r=Z08z%2F0RKK7k0ZWnWkl%2FVHThU6eMXcoJl9ldvo4wGeN0%3D%0A&m=USaqxvSAORpYWvXL2C1%2BWQlYOQ8ufziCvnLYqum9G1U%3D%0A&s=1ae5231f634165379c92cf86c8d94f7c73bd1acef1d4e10c2b128e6c2cc29de8>
   As indicated in our plan, this issue will now be resolved in the coming weeks according to the plan below.

    On October 02, we will review the current change proposals and will issue a "call for draft change proposals"
    to ensure that all draft change proposals for this issue are submitted by October 09.


10. ISSUE-24 [Justin]
     http://www.w3.org/2011/tracking-protection/track/issues/25<https://urldefense.proofpoint.com/v1/url?u=http://www.w3.org/2011/tracking-protection/track/issues/25&k=ZVNjlDMF0FElm4dQtryO4A%3D%3D%0A&r=Z08z%2F0RKK7k0ZWnWkl%2FVHThU6eMXcoJl9ldvo4wGeN0%3D%0A&m=USaqxvSAORpYWvXL2C1%2BWQlYOQ8ufziCvnLYqum9G1U%3D%0A&s=6dc6f47ea1bf7a506b553035abb9d6d7dbc5a119349fdf2ec61aca2339e85db8>
     http://www.w3.org/wiki/Privacy/TPWG/Change_Proposal_Audience_Measurement<https://urldefense.proofpoint.com/v1/url?u=http://www.w3.org/wiki/Privacy/TPWG/Change_Proposal_Audience_Measurement&k=ZVNjlDMF0FElm4dQtryO4A%3D%3D%0A&r=Z08z%2F0RKK7k0ZWnWkl%2FVHThU6eMXcoJl9ldvo4wGeN0%3D%0A&m=USaqxvSAORpYWvXL2C1%2BWQlYOQ8ufziCvnLYqum9G1U%3D%0A&s=783b1bebae6d870cf2ca0b5b6e3f550ce311c66ec3bb06b705db80a0ef519205>
   As indicated in our plan, this issue will now be resolved in the coming weeks according to the plan below.

    On October 02, we will review the current change proposals and will
    issue a "call for draft change proposals" to ensure that all draft change
    proposals for this issue are submitted by October 09.

-----------------------------------------
Reminder: Generic plan to resolve each individual issue
M0 (announcement): Initial call for change proposals; All change proposals should be drafted
M1 (discussion): Initial change proposals have been submitted; Discussion on change proposals; Call for final list of change proposals
M2 (discussion): List of change proposals is frozen; Discussion whether clear consensus emerges for one change proposal
M3 (announcement): Call for objections to validate / determine consensus
M5 (deadline): Deadline for inputs to call for objections (2 weeks after M3); Analysis starts
M7 (announcement): Results are announced

Note: Each issue requires 2 discussions in the group: One for discussing initial change proposals and one for discussing final change proposals and
   understanding whether a consensus has emerged.

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