RE: Allowed uses of protocol data in first N weeks (ACTION-190)

IMO, any specific number of weeks ends up being arbitrary as it cannot consider the contextual relevance of the info for specific purposes, and also as we cannot reasonably limit purposes to a finite/detailed list.

Thanks,
Bryan Sullivan

From: Ian Fette (イアンフェッティ) [mailto:ifette@google.com]
Sent: Thursday, May 03, 2012 10:42 AM
To: John Simpson
Cc: public-tracking@w3.org Group WG
Subject: Re: Allowed uses of protocol data in first N weeks (ACTION-190)

I thought in the DNT f2f people were going between 2-6, and Matthias raised the question of whether it mattered? I picked 6 as something that seemed reasonably short but ought to be enough for the vast majority of workflows that I know of. Personally, I don't really have a vested interest here...

-Ian
On Wed, May 2, 2012 at 12:38 PM, John Simpson <john@consumerwatchdog.org<mailto:john@consumerwatchdog.org>> wrote:
Thanks, Ian. Interesting text. A clarifying question:  Why six weeks; why not four or conversely eight?  What's significant about six?
Regards,
John

On May 2, 2012, at 8:47 AM, Ian Fette (イアンフェッティ) wrote:


On last week's call, I took an action to write a proposal for protocol data in the first N weeks (ACTION-190 and ISSUE-142).

My proposed text would be as follows, comments welcome:

Protocol data, meaning data that is transmitted by a user agent, such as a web browser, in the process of requesting content from a provider, explicitly including items such as IP addresses, cookies, and request URIs, MAY be stored for a period of 6 weeks in a form that might not otherwise satisfy the requirements of this specification. For instance, the data may not yet be reduced to the subset of information allowed to be retained for permitted uses (such as fraud detection), and technical controls limiting access to the data for permitted uses may not be in place on things like raw logs data sitting on servers waiting for processing and aggregation into a centralized logs storage service.

Within this six week period, a data collector MUST NOT share data with other parties in a manner that would be prohibited outside of the six week period. Similarly, a data collector MUST NOT use the data to build any profile, or associate the data to any profile, of a user used for purposes other than would be allowed outside of the the six week period. As examples, a data collector MAY use the raw data within a six week period to debug their system, a data collector MAY use the raw data within the six week period to build a profile of a user fraudulently or maliciously accessing the system for purposes such as blocking access to the system by that user, but the data collector MUST NOT build a profile to serve targeted advertisements based on the user's past six weeks of browsing activity.

After the six week period has passed, only the subset of data necessary to accomplish the permitted exceptions in this specification may be retained, and the data must be controlled in such a way that only access to the data for these permitted exceptions is allowed.

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John M. Simpson
Consumer Advocate
Consumer Watchdog
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