- From: Rob van Eijk <rob@blaeu.com>
- Date: Wed, 04 Jun 2014 09:06:52 +0100
- To: "Jack L. Hobaugh Jr" <jack@networkadvertising.org>
- Cc: "Mike O'Neill" <michael.oneill@baycloud.com>, public-tracking@w3.org, Rigo Wenning <rigo@w3.org>, Vinay Goel <vigoel@adobe.com>, Walter van Holst <walter.van.holst@xs4all.nl>, John Simpson <john@consumerwatchdog.org>
Hi Jack, Leaves the question: why is the burden unfair? The TPE does not underpin that claim. The TPE is just about the buildingblocks describing how to respond to a user expression. Rob Jack L. Hobaugh Jr schreef op 2014-06-03 21:49: > HI Rob, > > Thanks for furthering the discussion. > > My thoughts are based on the following sections of the TPE: > > Section 4: > > +++++++++++++ > If the user's choice is DNT:1 or DNT:0, the tracking preference is > enabled; otherwise, the tracking preference is not enabled. > +++++++++++++ > > Section 5.1: > > ++++++++++ > > When enabled [2], a tracking preference is expressed as either: > > DNT > MEANING > > 1 > This user prefers not to be tracked on the target site. > > 0 > This user prefers to allow tracking on the target site. > > ++++++++++ > > Section 5.2: > > ++++++++++++++++ > > A user agent must generate a DNT [3] header field with a field-value > that begins with the numeric character "0" (%x30) if the user's > tracking preference is enabled [2] and their preference is for DNT:0, > or if an exception has been granted for the request target. > ++++++++++++++++ > > The TPE does not require that information be provided to the Origin > Server as to how the DNT:0 was set. > > Also, it is clear from Section 7.6 of the TPE that limiting use after > the reception of a DNT:0 signal, whether or not set by a UGE, was not > contemplated: > > +++++++++++++++++ > Furthermore, the named third party receiving the DNT:0 header acquires > at least the right to collect data and process it for the given > interaction and ANY OTHER USE UNLESS IT RECEIVES A DNT:1 header from > that particular identified user agent. (emphasis added.) > +++++++++++++++++ > > The suggested proposal would contradict the neutral position of the > DNT:0 signal as written in the TPE and place a new burden on the > Origin Server to determine whether the signal was set as a user > preference or a UGE. > > And even if the server could determine how the DNT:0 was set, the TPE > is also clear that after a DNT:0 signal is received by the origin > server, even if set through a UGE, the user has given the server the > right to “collect data . . . and any other use” until it receives > a DNT:1. > > Best regards, > > Jack > > Jack L. Hobaugh Jr > Network Advertising Initiative | Counsel > 1620 Eye St. NW, Suite 210 Washington, DC 20006 > P: 202-347-5341 | jack@networkadvertising.org > > The information contained in this e-mail is confidential and intended > for the named recipient(s) only. However, it is not intended as legal > advice nor should you consider it as such. You should contact a lawyer > for any legal advice. If you are not an intended recipient of this > email you must not copy, distribute or take any further action in > reliance on it and you should delete it and notify the sender > immediately. > > On Jun 3, 2014, at 3:03 PM, Rob van Eijk <rob@blaeu.com> wrote: > >> Jack, >> >> As this proposal is written it would unfairly place a burden on the >> origin server to determine whether or not the DNT:0 signal was set >> in response to a user granted exception. > > In my view, the requirements of Mike's proposal resembles a necessary > element to restore the balance between the user and the business need. > Could you please explain why the burden is unfair? > > Rob > > Jack L. Hobaugh Jr schreef op 2014-06-03 20:50: > >> Hi Mike, >> Thanks for your proposal. >> As I understand the second part of the proposal below, it implies >> that >> a DNT:0 signal is set through an explicitly-granted exception. >> But as I understand the TPE, a user granted exception is not >> required >> to set and send a DNT:0 signal. >> As this proposal is written it would unfairly place a burden on the >> origin server to determine whether or not the DNT:0 signal was set >> in >> response to a user granted exception. >> Also, there should not be a DNT:0 distinction between first and >> third >> parties as implied by the proposal below. >> Best regards, >> Jack >> Jack L. Hobaugh Jr >> Network Advertising Initiative | Counsel >> 1620 Eye St. NW, Suite 210 Washington, DC 20006 >> P: 202-347-5341 | jack@networkadvertising.org >> The information contained in this e-mail is confidential and >> intended >> for the named recipient(s) only. However, it is not intended as >> legal >> advice nor should you consider it as such. You should contact a >> lawyer >> for any legal advice. If you are not an intended recipient of this >> email you must not copy, distribute or take any further action in >> reliance on it and you should delete it and notify the sender >> immediately. >> On May 30, 2014, at 9:10 AM, Mike O'Neill >> <michael.oneill@baycloud.com> wrote: >> >>> -----BEGIN PGP SIGNED MESSAGE----- >>> Hash: SHA1 >>> Here is my text for Issue-170. >>> I have (hopefully friendly) amended John Simpsons Proposal by >>> referencing our definition of Tracking and taking out the >>> restriction in later data use as 3rd Party, as this is covered by >>> Walter’s Proposal for Issue-219 (which I support). I have also >>> incorporated the gist of Rigo’s Proposal about the use of DNT:0 >>> as >>> an e-privacy consent mechanism, and the bit in Vinay’s proposal >>> about service providers. >>> Proposal: >>> If a 1st Party receives a request with DNT:1 set then data >>> regarding >>> or identifying the user initiating the request MUST NOT be shared >>> between Parties outside the context of the request, other than >>> between the 1st Party and its service providers or for permitted >>> uses as defined within this recommendation. A 1st Party MAY elect >>> further restrictions on the collection or use of such data. >>> If, as a result of an explicitly-granted exception, a 1st Party >>> receives a request with DNT:0 set then data regarding the user MAY >>> be used or shared but only for the purposes that were clearly and >>> comprehensively explained when the exception was granted. >>> -----BEGIN PGP SIGNATURE----- >>> Version: GnuPG v1.4.13 (MingW32) >>> Comment: Using gpg4o v3.3.26.5094 - http://www.gpg4o.com/ [1] [1] >>> Charset: utf-8 >>> iQEcBAEBAgAGBQJTiINJAAoJEHMxUy4uXm2Jtt0H+gIwe89nW5akvK8M/WAU0hPx >>> Mhg07ZnsPgjyaLJO/gXrjO+V42K9sv2E3cteLz8aGqCNkxT2x+XXt9oXF+zA17gl >>> WCfIfrGQ6SE1Z6TJrAItgDYPhp19cnARRn1skQqd3xaZ/GPn3W7ayaMWc8wxm805 >>> tth/kRaiCf+i73zrE8LuE63Y83M1MHqgAzolsAS0eeMVHKJH3FOYYd4StHQKqJeG >>> 0k3HkagAkml9JAKDejz5opVJSbOAX07VWOWqSWSwUvHf5jGo5V9vMs6c/AgLaMru >>> AIY8Vq0oWatAzVZkGUFxAjXo4OTu0P3vxo9tIlFM1PJmOHihh1fmEeYG2hc/E+o= >>> =qa25 >>> -----END PGP SIGNATURE----- >>> <PGPexch.htm><PGPexch.htm.sig> >> Links: >> ------ >> [1] http://www.gpg4o.com/ [1] > > > > Links: > ------ > [1] http://www.gpg4o.com/ > [2] > http://www.w3.org/2011/tracking-protection/drafts/tracking-dnt.html#dfn-enabled > [3] > http://www.w3.org/2011/tracking-protection/drafts/tracking-dnt.html#dfn-dnt
Received on Wednesday, 4 June 2014 08:07:34 UTC