- From: Shane M Wiley <wileys@oath.com>
- Date: Wed, 18 Oct 2017 16:09:03 -0700
- To: David Singer <singer@apple.com>
- Cc: "Aleecia M. McDonald" <aleecia@aleecia.com>, "public-tracking@w3.org (public-tracking@w3.org) (public-tracking@w3.org)" <public-tracking@w3.org>
- Message-ID: <CAEwb2ykYtJyfNKZB306FMz7kSg1JUV4gvZ+s4kn7emKNimhgEQ@mail.gmail.com>
David, I like the extension concept as I believe this gets pushed to the DNT header in the page request as well, correct? - Shane On Wed, Oct 18, 2017 at 4:03 PM, David Singer <singer@apple.com> wrote: > Hi Shane > > I wonder if we can solve this with an optional DNT-extension string after > each host name in the array when a site-specific grant is requested. > > So, I interact first with my partners, and I agree with each of them what > the DNT-extension string will mean. With xTremeAnalyitics, I agree that 1 > means basic user data, 2 means significant including residence zipc-code, > and 3 means total including blood type, ancestry, and so on. With > xTremeAdvertizer, I agree that A means abstract, only rough delineage of my > purchasing, Q means quantity and allows them to collect exactly what and > how much, and I means inspected meaning that they can collect things I only > looked at, or seemed to hover over. > > I register for the site-specific exception with an other-parties explicit > array > > xTremeAnalyitics.ru;2 > xTremeAdvertizer.cz;Q+I > > when the exception is registered, the UA record these strings and sends > them as DNT extensions, i.e. it send > > DNT:0;2 to xTremeAnalyitics.ru > and > DNT:0;Q+I to xTremeAdvertizer.cz > > Yes, life for the site gets easier if all these third parties use a common > grammar, but it’s not needed. It really helps if the first party can > register > > *;absolute > > and know that the extension ‘absolute’ will be understood (the same way) > by every third party conceivably embedded on it. > > > > On Oct 13, 2017, at 21:20 , Shane M Wiley <wileys@oath.com> wrote: > > > > David, > > > > The way this is likely going to work in the real-world, with or without > DNT, is that the publisher will be capturing the consent (by purpose) for > each ad tech vendor they work with. Imagine a consent dialogue that lists > 5 ad tech partners with 2 to 3 purposes below each partner that the user > must consent (thus far the mocks I've seen are not very pretty). > > > > Note - I'll avoid the pre-checked box debate here as there could be a > secondary unchecked box that confirms the user's choice prior to allowing > them to hit the "I Consent" button. > > Note 2 - I'll avoid the all-or-nothing discussion here (having that with > Rob on the same thread). > > Note 3 - I'll also avoid the pay-wall or tracking-wall debates (as those > are on-going in the ePR legislative process). > > > > The publisher will capture this consent and then need to convey it to > those 3rd parties in some manner. DNT is a nice solution as the browser > does this for the ad tech vendor (publisher -> browser -> ad tech vendor). > Similarly, the publisher could daisy chain through their 3rd party ad tech > vendor's domains (iFramed) so they each set a cookie with the appropriately > passed parameters for what level of consent has been provided. If the > consent is "web-wide" the publisher would need to follow a similar approach > anyway (site-wide does not require the iFrame daisy chain). The publisher > will of course record this themselves as any changes (new partners, new > purposes) will require they interact with the user again to gain consent > for the new elements. Net-net: EU users will be seeing A LOT of consent > dialogues going forward. > > > > In the publisher to ad tech vendor setup they will need to agree to the > purposes for which the ad tech vendor is seeking to gain consent to prior > to launching the consent experience with users on the publisher's site. Ad > Tech Vendors may agree to a single set of possible purposes such that > numbering is common across industry (1 = interest based ads, 2 = > cross-device mapping, 3 = probabilistic mapping, N...). In either case the > publisher and the ad tech vendor have to agree to this up front so they are > accurately conveying the appropriate consent for each purpose for that > vendor. > > > > - Shane > > > > On Fri, Oct 13, 2017 at 9:39 AM, David Singer <singer@apple.com> wrote: > > > > > >> On Oct 13, 2017, at 17:48 , Shane M Wiley <wileys@oath.com> wrote: > >> > >> David, > >> > >> The missing element in your assessment is that the user MUST be able to > consent (or not) to the options individually. We're not able to make it an > "all-or-nothing" proposition legally. If that was possible we wouldn't > need to have this conversation as then a single signal would cover our > needs. > > > > OK. Kinda weird. The site may not do the quid-pro-quo (e.g. free access) > unless you consent to it all. So ‘granular consent’ as I wrote below, and > possibly ‘changing purposes over time’ are both issues. > > > > It’s easy for the site to talk back to itself; cookies, or even as I > suggested using the DNT-extension. That covers the web-wide exception, and > the site itself for site-specific. > > > > How do you think a site should convey to the ads and its 3rd-parties, > for site-specific exceptions, which purposes they have consent for? > > > > “This user agreed to a non-vegetarian meal” “This user agreed to wearing > synthetic fibers during the night-time” and so on? > > > > > > > >> > >> - Shane > >> > >> On Thu, Oct 12, 2017 at 11:33 PM, David Singer <singer@mac.com> wrote: > >> > >> > >>> On Oct 13, 2017, at 0:20 , Shane M Wiley <wileys@oath.com> wrote: > >>> > >>> 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 > >> > >> I think I am confused. > >> > >> When consent is requested, the site manages the UI. It can certainly > ask: > >> > >> I need to be able to track you so that > >> * I serve you the breakfast that corresponds to your weird food fads > >> * I and my third parties can gather data about you that I will sell to > a foreign intelligence service, to cover my medical bills > >> > >> So, the dual purposes can be clearly expressed in the request. > >> > >> Likewise they can be expressed in the tracking status resource; we > could certainly have a list of purposes added here: > >> > >> object { > >> string tracking; // TSV > >> array { string; } compliance?; // hrefs > >> string qualifiers?; // compliance flags > >> array { string; } controller?; // hrefs > >> array { string; } same-party?; // domains > >> array { string; } audit?; // hrefs > >> string policy?; // href > >> string config?; // href > >> }*; > >> > >> So, as I see it, for an unchanging picture we seem to be covered, no? > >> > >> The tricky parts come in at least two ways: > >> * if the site offers granular consent, for each purpose separately, it > needs to know who consented to which purpose. > >> * if the site’s needs and hence purposes for tracking change over time, > it needs to remember “this user gave consent before I added purpose-Q, > whereas that user gave consent also to purpose-Q” > >> > >> Are these what we are struggling with? > >> > >> > >>> > >>> - 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 > >> > >> Dave Singer > >> > >> singer@mac.com > >> > >> > >> > >> > >> -- > >> - Shane > >> > >> Shane Wiley > >> VP, Privacy > >> Oath: A Verizon Company > > > > David Singer > > Manager, Software Standards, Apple Inc. > > > > > > > > > > -- > > - Shane > > > > Shane Wiley > > VP, Privacy > > Oath: A Verizon Company > > David Singer > Manager, Software Standards, Apple Inc. > > -- - Shane Shane Wiley VP, Privacy Oath: A Verizon Company
Received on Wednesday, 18 October 2017 23:09:30 UTC