- From: Jeff Jaffe <jeff@w3.org>
- Date: Tue, 17 Sep 2013 10:39:02 -0400
- To: Ninja Marnau <nmarnau@datenschutzzentrum.de>
- CC: Peter Swire <peter@peterswire.net>, Lou Mastria <lou@aboutads.info>, "public-tracking@w3.org (public-tracking@w3.org)" <public-tracking@w3.org>
On 9/17/2013 10:32 AM, Ninja Marnau wrote: > Thank you for sharing your thoughts, Peter. > > I would like to ask what this departing means with regard to the DMA, > IAB and the IAB members that participate in the WG. Is the DAA's > decision independent from the DMA and IAB? What about Chris Meja's email > with feedback for the plan forward from the IAB, DAA, DMA and NAI? Matthias responded to Chris' input on a separate email today. In it, he noted where their input has improved the proposed plan. That was incorporated into his final plan which he also sent to the WG today. > > Ninja > > Am 17.09.2013 15:16, schrieb Peter Swire: >> >> >> To the Working Group: >> >> >> I note with sadness but not surprise the decision today by the Digital >> Advertising Alliance to withdraw from the Tracking Protection Working >> Group of the World Wide Web Consortium. In announcing their departure, >> they chose my actions as the most convenient excuse for leaving the >> process: “Unfortunately, these efforts were rejected out of hand by TPWG >> co-chair Peter Swire, who jettisoned the long-accepted W3C procedure in >> order to anoint his own way forward.” >> >> >> >> I share the frustration in the DAA message with the inability of the >> Working Group to achieve better results. I believe a fair review of the >> history, however, shows that the views of the DAA and its members were >> valued and included in months of hard work together in the Group: >> >> >> >> (1) I met individually with the leadership of each DAAmember during the >> “listening tour” in late 2012, after I was named co-chair. >> >> >> >> (2) A major part of the agenda at the February Face-to-Face, in >> Cambridge, was based on the DAA proposal concerning ways to limit access >> to a user’s lifetime browsing history. >> >> >> >> (3) DAA proposals and language were discussed in detail during weekly >> teleconferences for the next several months. Indeed, a repeated theme >> on the list during this period was the concern from consumer advocates >> that a disproportionateamount of time of the Group was being spent on >> DAA proposals. >> >> >> >> (4) In the lead-up to the May Face-to-Face in California, there were >> intensive negotiations on what became known as the Draft Framework, >> which became the agenda for our three-day meeting. The DAA was deeply >> enough involved in these negotiations that its General Counsel, Stu >> Ingis, presented the Draft Framework to the Group in one of its calls. >> >> >> >> (5) Coming out of the May meeting, the full group, including the DAA, >> issued a consensus document that enough progress had been made that we >> should continue to work toward the long-agreed Last Call deadline of the >> end of July. >> >> >> >> (6) As an effort to have one clear text that would be the focus of the >> Group’s efforts, we then had the summer process to create proposed >> language and then comments on a base text. Among the change proposals, >> by far the greatest amount of time on the Group calls was devoted to the >> text proposed by the DAA and those associated with it. >> >> >> >> (7) Both co-chairs, supported by W3C staff, then issued approximately 40 >> single-spaced pages of decision documents. These documents contained a >> massive number of footnotes and citations to the comments submitted by >> Working Group members. Based on the record developed by the full Group, >> these documents explained reasons why the June Draft would remain the >> base text rather than the proposal submitted by the DAA and those >> associated with it. In brief, the criteria for a standard that we >> discussed in Cambridge, based on the overall record, would not be met by >> the proposal submitted by the DAA and others. >> >> >> >> Based on this history, the DAA views were simply not rejected “out of hand.” >> >> >> >> My own view is that the Working Group does not have a path to consensus >> that includes large blocs of stakeholders with views as divergent as the >> DAA, on the one hand, and those seeking stricter privacy rules, on the >> other. I devoted my time as co-chair to trying to find creative ways to >> achieve consumer choice and privacy while also enabling a thriving >> commercial Internet. I no longer see any workable path to a standard >> that will gain active support from both wings of the Working Group. >> >> >> >> When participants don’t get the outcome they want on substance, they >> often blame the procedure. As an imperfect human being, and one working >> within the W3C processes for the first time, I am sure that I could have >> done better at various points on procedure. The actual procedure that >> led to the July decision came directly from my close discussions with >> W3C staff, and used the mechanism for resolving a disputed issue that >> the Working Group established and used before I became co-chair. >> >> >> >> I intensely share the frustration that all the hard work by members of >> the Working Group has not created a consensus path forward. I believe >> there is consensus in the Working Group that members have worked very >> hard, and I worked very hard, to find apath forward. I put almost all >> of my other professional work on hold, at financial cost to myself, to >> try to find a solution on Do Not Track. >> >> >> >> Going forward, there are cogent reasons for stakeholders to continue to >> work, inside and outside of W3C, to develop standards and good practices >> for commercial privacy on the Internet. >> >> >> >> We knew coming in that this was a hard problem. It remains a hard >> problem. The procedures at W3C this summer are not the reason that it >> became hard. >> >> >> >> With best wishes to all of you, >> >> >> >> Peter >> >> >> >> >> >> P.S. I expect to be generally off-line today and much of this week. >> >> >> >> >> >> Prof. Peter P. Swire >> Nancy J. and Lawrence P. Huang Professor >> Law and Ethics Program >> Scheller College of Business >> Georgia Institute of Technology >> >> 240.994.4142 >> www.peterswire.net >> >> >> From: Lou Mastria <lou@aboutads.info <mailto:lou@aboutads.info>> >> Date: Tuesday, September 17, 2013 5:17 AM >> To: Jaffe Jeff <jeff@w3.org <mailto:jeff@w3.org>>, >> "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: DAA departing & moving forward >> Resent-From: <public-tracking@w3.org <mailto:public-tracking@w3.org>> >> Resent-Date: Tuesday, September 17, 2013 5:17 AM >> >> >> Dear Mr. Jaffe: >> >> >> After serious consideration, the leadership of the Digital Advertising >> Alliance (DAA) has agreed that the DAA will withdraw from future >> participation in the World Wide Web Consortium (W3C) Tracking Protection >> Working Group (TPWG). After more than two years of good-faith effort >> and having contributed significant resources, the DAA no longer believes >> that the TPWG is capable of fostering the development of a workable “do >> not track” (“dnt”) solution. As we depart W3C and TPWG, DAA will focus >> its resources on convening its own forum to evaluate how browser-based >> signals can be used meaningfully to address consumer privacy. >> >> >> During more than two years since the W3C began its attempt at a dnt >> standard, the DAA has delivered real tools to millions of consumers. It >> has grown participation; enhanced transparency with more than a trillion >> ad impressions per month delivered with the DAA’s Icon making notice and >> choice information available within one-click of the ad; educated >> millions of consumers and provided browser-based persistent plug ins. >> <http://www.aboutads.info/PMC> The DAA has also succeeded in applying >> its principles to all of the participants in the digital ecosystem. >> Furthermore, we have expanded these consumer safeguards into 30 >> countries and clarified how the DAA’s Principles apply in the mobile Web >> and app environments. >> >> >> >> Going forward, the DAA intends to focus its time and efforts on growing >> this already-successful consumer choice program in “desktop,” mobile and >> in-app environments. The DAA is confident that such efforts will yield >> greater advances in consumer privacy and industry self-regulation than >> would its continued participation at the W3C. >> >> Despite extension after extension of its charter year after year by the >> W3C, the TPWG has yet to reach agreement on the most elementary and >> material issues facing the group. These open items include fundamental >> issues and key definitions that have been discussed by this group since >> its inception without reaching consensus, including: >> >> · Defining a harm or problem it seeks to prevent. >> >> · Defining the term “tracking”. >> >> · Identifying limitations on the use of unique identifiers. >> >> · Determining the effect of user choice. >> >> >> >> Concerned about the TPWG’s inability to resolve such basic issues, the >> DAA wrote a letter to you on October 2, 2012 >> <http://www.aboutads.info/blog/press-release-daa-issues-open-letter-w3c-actions-working-group-threaten-ad-supported-internet>, >> expressing its strong concern with the W3C’s foray into setting public >> policy standards. In particular, the letter noted that the W3C “has >> been designed to build consensus around complex technology issues, not >> complex public policy matters.” In response, despite the turmoil evident >> at that time, you personally assured us that appropriate procedures and >> policies would be applied to the process and the W3C’s retention of >> Professor Swire would settle and bring legitimacy to the process. >> >> >> In the ensuing eight months that led up to the July 2013 deadline >> imposed on the TPWG, the DAA worked in good faith with other >> stakeholders, supporting proposals consistent with recommendations from >> the U.S. Administration and the former chairman of the Federal Trade >> Commission. Unfortunately, these efforts were rejected out of hand by >> TPWG co-chair Peter Swire, who jettisoned the long-accepted W3C >> procedure in order to anoint his own path forward. As others in the >> working group have substantiated, as a result of Swire’s actions there >> is no longer a legitimate TPWG procedure. Jonathan Mayer, commenting on >> the working process >> <http://lists.w3.org/Archives/Public/public-tracking/2013Jul/0601.html>, >> stated, “We do not have clear rules of decision. And even if we were to >> have procedural commitments, they could be unilaterally cast aside at >> any time. This is not process: this is the absence of process.” Roy T. >> Fielding, Senior Principal Scientist at Adobe, highlighted >> the dictatorial approach taken by chairs >> <http://lists.w3.org/Archives/Public/public-tracking/2013Jul/0464.html> who >> have eschewed participant input and subrogated participants’ right to >> vote on issues. >> >> >> In recent weeks, you have indicated to TPWG participants that you have >> no intent to revisit acts or processes (or the lack thereof) that >> occurred leading up to July 2013, and instead plan to move forward. >> However, it is not possible to move forward without an accounting for >> the previous flagrant disregard for procedure. >> >> >> Today, parties on all sides agree that the TPWG is not a sensible use of >> W3C resources and that the process will not lead to a workable result. >> For example, Jonathan Mayer, in his recent letter of resignation from >> the TPWG, stated >> <http://lists.w3.org/Archives/Public/public-tracking/2013Jul/0601.html>: >> “Given the lack of a viable path to consensus, I can no longer justify >> the substantial time, travel, and effort associated with continuing in >> the Working Group.” John Simpson, the director of the Consumer >> Watchdog’s privacy project, commented on the news of the departure of >> TPWG co-chairman Professor Swire >> <http://www.law360.com/privacy/articles/468512?nl_pk=0c277e2d-1bd7-44e8-80c2-e6cfa8deb42a&utm_source=newsletter&utm_medium=email&utm_campaign=privacy>: >> “Peter Swire gave it a good shot, but I don’t think that he or anybody >> can get this group to a general consensus.” These participants and >> others who previously supported the TPWG now conclude that the process >> has devolved into an exercise in frustration on all sides without any >> meaningful increase in consumer choice or transparency. >> >> >> The DAA agrees with these parties on this matter. Therefore, rather than >> continue to work in a forum that has failed, we intend to commit our >> resources and time in participating in efforts that can achieve results >> while enhancing the consumer digital experience. The DAA will >> immediately convene a process to evaluate how browser-based signals can >> be used to meaningfully address consumer privacy. The DAA looks forward >> to working with browsers, consumer groups, advertisers, marketers, >> agencies, and technologists. This DAA-led process will be a more >> practical use of our resources than to continue to participate at the W3C. >> >> >> With the departure of the latest TPWG co-chair as well as a key staff >> member, and no definitive process to move forward, the DAA recommends >> that that the W3C should not attempt to resurrect a process that has >> clearly reached the end of its useful life. >> >> >> The DAA will continue to move forward in its own area of expertise, >> advancing consumer control, transparency, and other critical practices >> through its own program. >> >> >> >> Best, >> >> Lou Mastria >> P:+1 347 770 0322 >> E: Lou@AboutAds.info <mailto:Lou@AboutAds.info> >> Twitter: @lmastria / @daausa >> >> Did you know that DAA released new mobile guidance? >> >> Get the PDF here: http://bit.ly/DAAMobile
Received on Tuesday, 17 September 2013 14:39:16 UTC