Re: Next 2 calls canceled (Oct 09 and Oct 16)

I believe this is an over simplification of the issue.  If we want DNT to
meet the most basic needs of even small publishers that means they will
need to support at least one ad tech partner (assuming the goal of the
group is still to meet the original target of the standard).  Even the most
basic ad tech partner will participate in at least two distinct purposes
which lawyers are expressing need to be consented to separately:
interest-based advertising and cross-device mapping (all ad ecosystem
participants support these two common approaches in the EU marketplace
today).  If the DNT standard is unable to support even the most basic
consent scenario then there will likely be zero adoption - at least for the
most common use case and original target of the standard.  There may still
be hyper edge cases where a singular purpose consent will cover all needed
business cases.

- Shane

On Thu, Oct 12, 2017 at 2:47 PM, Aleecia M. McDonald <aleecia@aleecia.com>
wrote:

>
> > On Oct 12, 2017, at 11:16 AM, Shane M Wiley <wileys@oath.com> wrote:
> >
> […]
> > In either case, we'll need a purpose array for the ad industry to be
> able to leverage DNT as a lawful consent compliance approach in the EU (at
> least that's what EU lawyers are telling me).
> […]
>
> This sounds like an array of common purposes that also contains a purpose
> of other.
>
> I imagine a common set of purposes congruent with EU regs, and then
> “other” managed entirely by the publisher, which defines what it means,
> conveys it meaningfully to users, and records not only consent but what was
> consented to. I would expect any given publisher using “other” to change
> what it means over time (e.g. after an acquisition or new product launch,
> etc.) which is why a timestamp is going to matter.
>
> In an ideal world, Art 29 WP could issue guidance that turns the common
> set of purposes into something fairly self-serve. Perhaps there will be
> sample text akin to Safe Harbor guidance.
>
> For the complexities of Other, well, see your local DPA to have a
> discussion about that.
>
> Small sites should be able to do just fine with the common set. Large
> companies can get all the complexity they need from Other, which might need
> to be further defined as OtherA, OtherB, OtherC, on the backend, but that
> too is up to the publisher to manage.
>
> Early on we had the idea that straight-forward publishers should be able
> to implement DNT easily and those with complex practices would have a more
> complex implementation. I think we can still fulfill that goal.
>
> (I echo Rob’s concern about further delay and the ironies inherent in this
> discussion.)
>
>         Aleecia
>
>
>
>


-- 
- Shane

Shane Wiley
VP, Privacy
Oath: A Verizon Company

Received on Thursday, 12 October 2017 22:20:59 UTC