RE: Remove profiling prohibition for frequency capping (ISSUE-236)

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Shane,

I also have a problem with frequency capping, or any permitted use based on profiling, because it could be used as a Trojan horse for other purposes. That is why there is text about not using UIDs unless absolutely necessary, and why I think this should be made more explicit.

There are many ways frequency capping for contextual ads could be done without profiling like sectioning IP ranges as Walter suggests or using low-entropy cookies or ETag value, but if it requires profiling of individuals it would conflict with the whole point of DNT in my opinion.

I also agree with Walter that many of the permitted uses we are contemplating would be ruled out in a significant portion of the developed world. There should be some mention in the introductory text on  permitted uses about the overriding requirement in Europe for a legal basis for processing personal data.

Mike


> -----Original Message-----
> From: Shane M Wiley [mailto:wileys@yahoo-inc.com]
> Sent: 11 September 2014 11:39
> To: Walter van Holst; public-tracking@w3.org
> Subject: RE: Remove profiling prohibition for frequency capping (ISSUE-236)
> 
> Walter,
> 
> Then we disagree on the merits here.  Removing frequency-capping will have
> fairly negative repercussions on users seeing the same ads over-and-over-and-
> over driving them to turn off DNT.  The group on both sides agreed to this carve-
> out long ago due to the perverse disincentives created in this scenario (I believe
> only 2 or 3 people out of ~70 ever had an issue here).  Your technical solution is
> simply unworkable.  Looking forward to the Call for Objections.
> 
> - Shane
> 
> -----Original Message-----
> From: Walter van Holst [mailto:walter.van.holst@xs4all.nl]
> Sent: Thursday, September 11, 2014 3:30 AM
> To: public-tracking@w3.org
> Subject: RE: Remove profiling prohibition for frequency capping (ISSUE-236)
> 
> On 2014-09-11 12:18, Shane M Wiley wrote:
> 
> > We've always agreed the frequency-capping would be a permitted use in
> > situations where a DNT=1 is received.  Are you suggesting we now
> > remove that permitted use or are you simply commenting on this
> > specific language?
> 
> I am perfectly fine with frequency-capping, as long as it doesn't require profiling
> at an individual level. It cannot result in collection of data by a third-party if the
> UA is setting a DNT:1 flag. The mere fact that this particular purpose of tracking
> is beneficial both to the user and the advertiser does not justify in itself an
> override of a
> DNT:1 preference. And I can think of several methods to prevent saturation of a
> particular user with a particular ad, for example progressively dropping least-
> significant bits of IP-addresses to mask out groups of users that an ad should not
> be shown to.
> 
> I do not recall a broad consensus about this particular permitted use.
> 
> Regards,
> 
>   Walter
> 

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Received on Thursday, 11 September 2014 11:32:50 UTC