Re: tracking data (was Re: [TCS] comments on 17 Feb 2015 editors draft)

On 2015-04-08 21:50, Justin Brookman wrote:

> Walter had previously objected on the mailing list to removing
> "tracking data" from the non-normative discussion of
> de-identification.  However, participants on the call today didn't
> think the removal of the term weakened that provision.
> De-identification already requires technical processes to ensure that
> *no one* can re-identify the data; the non-normative language simply
> notes other prophylactic steps that can be taken to address the
> persistent possibility of reidentification in the future.

For the record: I do not object to the removal of  the term "tracking 
data". I specifically provided alternative wordings that would allow for 
its removal while retaining the intent and scope of the text. I have 
always been of the opinion that we can have a good spec without such a 
term, even though it might be helpful for getting there.

The core of my objection is that in the new text the obligation for 
having "business processes" that preven re-identification could be read 
narrowly and would not prevent sharing de-identified data with a 
non-compliant party for the purpose of that party re-identifying that 
data. All while being able to claim DNT-compliance.

Regards,

  Walter

P.S. in the IRC log I noticed " if I'm embedded in the NYT and remember 
the user's visit to the NYT, that's not by itself tracking, I think.". I 
think that is a clear-cut case of tracking. A DNT-compliant third party 
embedded on the NYT website should basically ignore any information of 
me being on that site (while sending DNT:1) unless necessary for and 
confined to a permitted use, let alone which article. Like Shane 
correctly pointed out, rate-limiting is a permitted use, but that is not 
dependent on me being on the NYT website.

Received on Thursday, 9 April 2015 12:47:38 UTC