Re: [ISSUE-206] Service Provider (and related ISSUE-219 question)

Hi Mike,

Canıt a clause like that turn a service provider into a Œdata controllerı
by taking actions or making decisions about the data?  Iıd rather we not
add clauses in to the definition of service provider that requires the
service provider to make decisions on the use of customerıs data.  It also
conflicts with '(2) ensures that the data is only retained, accessed, and
used as directed by the contracteeı.

Justin - in your example, are all of those sites, including News.com, all
part of the same publisher/first-party?  If not, what Roy is saying below
is that News.com would be engaged in tracking if it collected data on
Shoes.com to serve an interest-based ad on News.com.


-Vinay

On 6/11/14, 11:11 AM, "Mike O'Neill" <michael.oneill@baycloud.com> wrote:

>-----BEGIN PGP SIGNED MESSAGE-----
>Hash: SHA1
>
>Roy,
>
>Thinking about Justin's concern, would you accept a friendly amendment to
>your service provider definition making it clear that data should not be
>shared outside the context in which it occurred (i.e. our definition of
>tracking), i.e. even if it is only acting at the behest of its
>contractee. 
>
>
>(5) ensures that data about a user's activity collected in a context when
>DNT is set will not be shared with parties in other contexts.
>
>
>
>mike
>
>> -----Original Message-----
>> From: Justin Brookman [mailto:jbrookman@cdt.org]
>> Sent: 11 June 2014 15:32
>> To: Roy T. Fielding
>> Cc: W3C DNT Working Group Mailing List
>> Subject: Re: [ISSUE-206] Service Provider (and related ISSUE-219
>>question)
>> 
>> 
>> 
>> On Jun 6, 2014, at 2:42 PM, Roy T. Fielding <fielding@gbiv.com> wrote:
>> 
>> > On Jun 5, 2014, at 11:59 AM, Justin Brookman wrote:
>> >
>> >> That is Ad X could collect and store data on behalf of Sites 1-300,
>>and then
>> serve targeted ads based on any one of those 300 silos when a user
>>visits Sites
>> 301?  As long as the contracts allow this and prohibit use of blended
>>data across
>> silos?
>> >
>> > I don't understand how "serve targeted ads based on" some other site
>>would
>> > be allowed unless both sites are owned by the same first party.
>> > Otherwise, that is tracking: "use of data derived from that activity
>>outside
>> > the context in which it occurred".  Note that the definition of
>>tracking
>> > doesn't care whether the tracker is a service provider; it only cares
>> > about the context in which that data was collected.
>> >
>> > ....Roy
>> >
>> 
>> It's used outside the context the data was collected, but it's not
>>necessary cross-
>> site tracking data if it's just held on behalf of a publisher, right?
>>So if ADNET is a
>> service provider to Shoes.com, Diapers.com, Hats.com, Social.com, and
>>dozens
>> of other publishers, it can collect target ads on News.com based on any
>>one of
>> those silos (say a retargeted ad for a shoe that the user looked at, or
>>something
>> based on the user's activity on Social.com).  Assuming that we adopt
>>your
>> definition of service provider and resolve ISSUE-219 to allow first
>>party data to
>> be used in other contexts.
>> 
>> Or am I misinterpreting the service provider language?
>
>-----BEGIN PGP SIGNATURE-----
>Version: GnuPG v1.4.13 (MingW32)
>Comment: Using gpg4o v3.3.26.5094 - http://www.gpg4o.com/
>Charset: utf-8
>
>iQEcBAEBAgAGBQJTmHGxAAoJEHMxUy4uXm2JFTMH/2NzXijICkyoiAvFy53TqY9s
>6S4sVmC3tQtyxKn4Xd7kC0rPnUW1PhNtArwMMJvADPhg+2/XlXoIAMr3JOgaN6Py
>kDUTBOrWLbnTqaYMh48ZSH8o/N4dnoh+UK1l51ckCALnH8Q4GKeuBXIx3Rszcjm/
>KVjaXiJaS/o8PWqE+0SoikZxpkMPGGsVGi9VXzhcI/rKOdBJl/SrWdXQB7Dc4eif
>rCAqWvSZuqw/QRe3obgEKG0fw88UVaqAZqcDP5wJ42GUQ4FvmH0PNB/wSYZJLA8k
>EugPIAo4aY5HnrJAZnpKynqcWQLH/MmFVa9m38D1jvvtQqe2wnl9XEo78NEtbwo=
>=QhkD
>-----END PGP SIGNATURE-----
>
>

Received on Wednesday, 11 June 2014 15:24:14 UTC