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RE: ISSUE-262: guidance regarding server responses and timing

From: Shane M Wiley <wileys@yahoo-inc.com>
Date: Wed, 29 Oct 2014 20:01:38 +0000
To: Mike O'Neill <michael.oneill@baycloud.com>, 'Justin Brookman' <jbrookman@cdt.org>, 'Nicholas Doty' <npdoty@w3.org>
CC: 'Tracking Protection Working Group' <public-tracking@w3.org>, "'Roy T. Fielding'" <fielding@gbiv.com>
Message-ID: <DCCF036E573F0142BD90964789F720E3250D8E1C@GQ1-AM-M03-03.y.corp.yahoo.com>
Mike,

The Exchange would not be engaged in cross-site tracking if the data was used for assessment purposes only and then immediately purged or de-identified.

- Shane

-----Original Message-----
From: Mike O'Neill [mailto:michael.oneill@baycloud.com] 
Sent: Wednesday, October 29, 2014 12:50 PM
To: 'Justin Brookman'; 'Nicholas Doty'
Cc: 'Tracking Protection Working Group'; 'Roy T. Fielding'
Subject: RE: ISSUE-262: guidance regarding server responses and timing

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Justin,

The ad exchange cannot share DNT:1 browser ID with another party unless either:
a) it knows the other party has consent for this browser i.e. by that fact being communicated to it when consent was given to the other party (transitive UGE), or
b) it only passes the UID without any other kind of data i.e. it is passing a unique key which can have no meaning other than to a party that has already been given consent (naked UID).

In both cases it would have to be a service provider for the downstream parties (and also the first-party IMO).

If it did pass IDs with data it would be enabling/indulging in cross-context tracking (with DNT set).

Mike


> -----Original Message-----
> From: Justin Brookman [mailto:jbrookman@cdt.org]
> Sent: 29 October 2014 18:57
> To: Nicholas Doty
> Cc: Tracking Protection Working Group; Roy T. Fielding
> Subject: Re: ISSUE-262: guidance regarding server responses and timing
> 
> I’m not sure I understand how this would work in practice for the losing bidders.
> Presumably when the bid goes out, each bid recipient is able to 
> identify the unique browser (through matching to Exchange ID?) in 
> order to determine if it information with which to target the ad.
> 
> First, does TPE require the exchange to pass on a DNT:1 request to 
> bidders and other third parties? Should that be required as a 
> condition of sending the dynamic ? response?
> 
> As I read this proposal, even if the DNT:1 request is passed on, 
> bidders would not be required to honor (unless the exchange’s rules or 
> local law required it) and there would be no way for a losing bidder 
> to signal back to the user that it would not add information about the 
> lost bid to a user’s profile. Though if that party ever wanted to 
> serve an ad based on that data to a DNT:1 user, it would have to acknowledge that it engages in tracking in the TSV, right?
> 
> Also, I believe Shane indicated on a previous call that losing bidders 
> are typically prohibited from retaining (or using?) lost bid data.
> 
> And a particularly wary user agent could always deny access to cookies 
> or otherwise limit an exchange’s access to tracking resources when it receives a ?
> TSV . . .
> 
> Apologies if these questions are wildly off the mark; I am still 
> trying to wrap my head around this thorny issue.
> 
> On Oct 21, 2014, at 6:43 PM, Nicholas Doty <npdoty@w3.org> wrote:
> 
> > Our discussion last week of ISSUE-262 (guidance regarding server 
> > responses
> and timing) focused on a question of ad exchanges or other servers 
> that communicate with a number of other servers, for one of which it 
> acts as a service provider. The question was how the 
> exchange/real-time-bidding server should respond, for users that fetch 
> the tracking status resource. In some cases, if the exchange server 
> knows that all of its potential winning bidders/potential responders 
> have a common DNT policy, the server could just respond statically 
> with the tracking status resource that corresponds to the request and 
> those downstream servers. But what if the server's downstream servers 
> don't have a common DNT policy (some comply and some don't; some claim consent and some don't; etc.)?
> >
> > Based on IRC conversation, here is what I would suggest for that case:
> >
> > A server that doesn't know ahead of time what server will win the 
> > bid and
> where those downstream servers have varying/incompatible policies, the 
> exchange server can respond to any tracking status resource requests 
> with the tracking status value of "?", which we had previously defined 
> for any resources for which the tracking behavior is dynamic.
> >
> > 	http://www.w3.org/2011/tracking-protection/drafts/tracking-

> dnt.html#TSV-?
> >
> > In order to comply with the TPE, the exchange server would need to 
> > determine
> the appropriate tracking status from the downstream server that wins 
> the bid and supplies the response. And in the response to the resource 
> request (to load the ad, for example), the exchange server would send 
> a Tk response header with the appropriate value. The server might also 
> send a "status-id" field so that interested users could query the 
> tracking-status resource that could then be specific to that fulfilling server (links to privacy policy, etc.).
> >
> > Roy suggests that we might need to make a small change to the 
> > requirements
> about the cached life of these values to correspond to this case 
> (where the same URL might be fulfilled in different ways by different 
> servers within a 24 hour period). I believe we'd indicate that the Tk: 
> response value does not need to be valid for at least 24 hours, but 
> only for the request itself. That wouldn't change any of the expected 
> caching behavior of tracking status resources. I believe that would just be a clarification added to either 6.7.2 or 6.3.1.
> >
> > (The question also doesn't arise for advertising models where the 
> > user agent is
> redirected to another server to deliver the ad itself -- in that case 
> each server just responds to any tracking status resource requests 
> based on its individual
> policy.)
> >
> > Thanks,
> > Nick
> 
> 

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Received on Wednesday, 29 October 2014 20:03:33 UTC

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