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

Hi Justin,

Ah, got it.  Roy will correct me if I’m wrong, but I believe using Roy’s
proposed definition, the service provider would take on the same party as
what is when interacts/serves an ad on  The
fact that the service provider is a service provider to both and is irrelevant.  It’s because the service provider can only
retain, access and use the data as directed by the contractee (per
subclause (2) in Roy’s definition).  So, it can’t use data for unless directed by  It’s not data, so the
service provider will have to look to for direction.

I know there’s another debate on whether is allowed to engage in
this activity when DNT:1 is set; but that’s separate from the service
provider issue.

That help clarify it?


On 6/11/14, 11:28 AM, "Justin Brookman" <> wrote:

>On Jun 11, 2014, at 11:23 AM, Vinay Goel <> wrote:
>> Hi Mike,
>> Can¹t a clause like that turn a service provider into a Œdata
>> by taking actions or making decisions about the data?  I¹d rather we not
>> add clauses in to the definition of service provider that requires the
>> service provider to make decisions on the use of customer¹s data.  It
>> conflicts with '(2) ensures that the data is only retained, accessed,
>> used as directed by the contractee¹.
>> Justin - in your example, are all of those sites, including,
>> part of the same publisher/first-party?  If not, what Roy is saying
>> is that would be engaged in tracking if it collected data on
>> to serve an interest-based ad on
>No, in my example, they're all different companies.  But could **
>collect data about the user on, use ADNET as a service
>provider, and then use ADNET to show a Shoes ad on  That
>is, it's not whether is engaged in tracking --- they only use
>ADNET to show ads on their site, not to collect data.  But if ADNET can
>use data on's behalf . . .
>I'm not saying this is a bad result, just trying to make sure I understand
>what can happen.
>> -Vinay
>> On 6/11/14, 11:11 AM, "Mike O'Neill" <>
>>> Hash: SHA1
>>> Roy,
>>> Thinking about Justin's concern, would you accept a friendly amendment
>>> your service provider definition making it clear that data should not
>>> 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
>>> DNT is set will not be shared with parties in other contexts.
>>> mike
>>>> -----Original Message-----
>>>> From: Justin Brookman []
>>>> 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 <> 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,,,, and
>>>> dozens
>>>> of other publishers, it can collect target ads on based on
>>>> one of
>>>> those silos (say a retargeted ad for a shoe that the user looked at,
>>>> something
>>>> based on the user's activity on  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?
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Received on Wednesday, 11 June 2014 15:40:24 UTC