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

On 2015-04-09 16:38, Justin Brookman wrote:
> Right, this is a different issue than the use of the term "tracking
> data."  Contractual agreements with third parties to not try to
> reidentify data sets are one way to ensure that deidentified data
> stays that way.  For example, the FTC's test for deidentification is
> (1) a reasonable belief that the data can't be reidentified, (2) a
> commitment not to reidentify, and (3) a commitment not to reidentify
> from everyone you give the data set to.
> 
> I personally would be fine adding language about this to this
> non-normative guidance --- would just adding "and agreements" to the
> second bullet do it?

Substitute "agreements" with safeguards and put in non-normative 
language that safeguards may be provided through agreements and we're 
closer to meaning and scope of the original text again.

Regards,

  Walter

Received on Thursday, 9 April 2015 14:49:11 UTC