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

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