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

OK.  I think everyone is agreed with what the service provider language does and does not do.  We still haven't had an objection to this language for several weeks, so we will accept the change as previously stated.
On Jun 11, 2014, at 11:56 AM, Roy T. Fielding <> wrote:

> Yep, what Vinay said.  Compliance doesn't change the meaning of DNT:1.
> Likewise, the service provider definition doesn't change the ability of
> a first party or the set of sites that party owns -- it only allows the
> service provider to act on behalf of that first party without being
> considered a third party (for that data collected as a first party).
> A service provider to a third party is still going to be a third party.
> ....Roy
> On Jun 11, 2014, at 8:23 AM, Vinay Goel wrote:
>> Hi Mike,
>> Can't a clause like that turn a service provider into a "data controller"
>> by taking actions or making decisions about the data?  I'd rather we not
>> add clauses in to the definition of service provider that requires the
>> service provider to make decisions on the use of customer's data.  It also
>> conflicts with "(2) ensures that the data is only retained, accessed, and
>> used as directed by the contractee".
>> Justin - in your example, are all of those sites, including, all
>> part of the same publisher/first-party?  If not, what Roy is saying below
>> is that would be engaged in tracking if it collected data on
>> to serve an interest-based ad on
>> -Vinay
>> On 6/11/14, 11:11 AM, "Mike O'Neill" <> wrote:
>>> 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 []
>>>> 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 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  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 Monday, 16 June 2014 20:39:27 UTC