- From: Mike O'Neill <michael.oneill@baycloud.com>
- Date: Thu, 11 Sep 2014 17:25:09 +0100
- To: "'David \(Standards\) Singer'" <singer@apple.com>, "'Justin Brookman'" <jbrookman@cdt.org>
- Cc: "'Jeffrey Chester'" <jeff@democraticmedia.org>, <public-tracking@w3.org>
-----BEGIN PGP SIGNED MESSAGE----- Hash: SHA1 You are not off base, but it shows up the transparency/machine visibility issue. If a third-party uses a cookie (or gets a 1st party cookies placed and uses that) to recognise the user in multiple transactions for in-context frequency counting how can the UA/extension/regulator/user tell if tracking is going on? They would have to rely on trust that "administrative procedures" or tunnel vision glasses were being used. Mike > -----Original Message----- > From: David (Standards) Singer [mailto:singer@apple.com] > Sent: 11 September 2014 17:12 > To: Justin Brookman > Cc: Jeffrey Chester; public-tracking@w3.org (public-tracking@w3.org) > Subject: Re: Remove profiling prohibition for frequency capping (ISSUE-236) > > Unless I misunderstand the definition of tracking, we might not need a permitted > use at all. It just works. > > If an ad site remembers what ads IT has served to ME only, it’s not tracking me > across contexts. This is something I pointed out when I first floated ‘tunnel > vision’ — that neither first nor third parties need special language to handle their > interactions directly with me. > > In fact, the first/third distinction is not needed in tunnel vision, as I see it. I think > Roy may have been saying the same thing. > > Now, the site may be able to remember “I served this dishwasher ad to Dave > thrice up to now, ’tis sufficient”, but it cannot remember “it was on Sears.com > that I first served that ad, and on HomeDepot.com the second, but lo! or the > third I cannot recall who asked it of me”. That’s remembering data across > contexts. > > Or am I off base? > > On Sep 11, 2014, at 7:15 , Justin Brookman <jbrookman@cdt.org> wrote: > > > We are not reopening a discussion on whether there will be a permitted use > for frequency capping. That has been stable in the TCS for years. Anyone who > wanted to remove such a permitted use could have opened an issue on this at > any time up to October of last year; no one did. > > > > This issue raised by Jack is an editorial one. The frequency capping rules are > already subject to the Data Minimization and No Personalization language in > Sections 3.3.1.3 and 3.3.1.4; Jack has made the argument that the last sentence > in the frequency capping paragraph is thus superfluous. > > > > Companies retaining data for frequency capping alone can only collect and use > the data minimally necessary for that purpose, and cannot use that data for > secondary purposes. There is no basis for retaining web browsing history for > frequency capping (unless a cap is tied to showing a number of ads on a > particular site), and companies will not be able to target ads based on the nature > of frequently shown ads. However, keep in mind that companies are likely to > retain web browsing history despite a DNT:1 setting for other purposes, > including attribution and fraud prevention. Of the permitted uses, I would think > frequency capping would be the least concerning to advocates. > > > > On Sep 11, 2014, at 9:58 AM, Jeffrey Chester <jeff@democraticmedia.org> > wrote: > > > >> Thanks for reminding me that in-flight and associated ad changes are labeled > as OBA/data driven targeting. I believe this debate is a useful one, because > frequency capping needs to be vetted taking into consideration EU and other > data protection policies. > >> > >> > >> Jeffrey Chester > >> Center for Digital Democracy > >> 1621 Connecticut Ave, NW, Suite 550 > >> Washington, DC 20009 > >> www.democraticmedia.org > >> www.digitalads.org > >> 202-986-2220 > >> > >> On Sep 11, 2014, at 6:53 AM, Shane M Wiley <wileys@yahoo-inc.com> > wrote: > >> > >>> Jeff, > >>> > >>> We agreed as a group that any "in flight" changes were deemed behavioral > targeting, not frequency capping, so we already removed that use case from > consideration (such as sequential ads) at the Oct 2013 Sunnyvale meeting. The > use case here is the most simple one imaginable -- not showing the same user > the same ad more than X times in a Y given time frame - nothing more. > >>> > >>> - Shane > >>> > >>> -----Original Message----- > >>> From: Jeffrey Chester [mailto:jeff@democraticmedia.org] > >>> Sent: Thursday, September 11, 2014 3:50 AM > >>> To: Shane M Wiley > >>> Cc: Walter van Holst; public-tracking@w3.org > >>> Subject: Re: Remove profiling prohibition for frequency capping (ISSUE-236) > >>> > >>> Walter is correct. In addition, Frequency capping is now also connected to > real-time "in-flight" changes to targeted personalized campaigns. In-flight is ad > biz term for such ad technique changes done during a campaign, which can also > involve "creative versioning," that is new campaign dynamic elements that > reflect how a person is responding. Capping connected to these and similar > changes to a users experience should not be permitted under DNT:1 > >>> > >>> Jeff > >>> > >>> Jeff Chester > >>> Center for Digital Democracy > >>> Washington DC > >>> www.democraticmedia.org > >>> Jeff@democraticmedia.org > >>> > >>>> On Sep 11, 2014, at 6:38 AM, Shane M Wiley <wileys@yahoo-inc.com> > wrote: > >>>> > >>>> 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 > >>>> > >>>> > >>>> > >>> > >>> > >> > > > > David Singer > Manager, Software Standards, Apple Inc. > -----BEGIN PGP SIGNATURE----- Version: GnuPG v1.4.13 (MingW32) Comment: Using gpg4o v3.3.26.5094 - http://www.gpg4o.com/ Charset: utf-8 iQEcBAEBAgAGBQJUEczlAAoJEHMxUy4uXm2JAj8H/iS1ghWCQ4m+THOdwLFK6mYo 4ChiHzhokfWid9nBxWaOXYDSUMCrIatrT0ug+ilCJUPDr8kTVcdPdsqEYQjlvm0h 6MJ4qB9hbCMbr/DOSdr0eXIFjfrzw3tcaMpaqT6uVzYIrxebwJC5vh5bN5AxIjWv 9YayL1BBjpVITiCLMFxQ9IqWmYbiOvfgwlmj42jh3TG8lNUXJgy2Lx2WyW4Eb9yg lXFWuDMgutg+Z+2DgNTAhQsw2quIGYK47TdUx86ydPZFHsxOtuZ2/6mPEObioeVY c3V5bcXYLueEwxE0DMvak3nzWXu82fIy7atANAGdYoIWmW5IKsuBY7PZjG38TOI= =b/zN -----END PGP SIGNATURE-----
Received on Thursday, 11 September 2014 16:26:45 UTC