Issue-233
*Normative:*
Data retained by a party for permitted uses MUST be [replace "limited" with
minimized] to the data reasonably necessary for such permitted uses. Such
data MUST NOT be retained any longer than is [replace proporationate with
proportionate] and reasonably necessary for such permitted uses.
*Justification:*
The term “limit” suggests a hard boundary whereas “minimize” suggests a
more flexible boundary that can be lowered as appropriate to provide
privacy gains.
In other words these terms operate in different directions. Limit is a cap
and minimize provides pressure to decrease, which is better for privacy
gains.
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*Jack L. Hobaugh Jr
*Network Advertising Initiative | Counsel & Senior Director of Technology
1634 Eye St. NW, Suite 750 Washington, DC 20006
P: 202-347-5341 | jack@networkadvertising.org