RE: Parties and First Party vs. Third Party (ISSUE-10)

I will echo Clay's point based on my personal experience working at both Coca-Cola and Microsoft that a single company with multiple brands has many shared systems to manage data and sites. To require a company to break these apart to form fictional "brand entities" would be extremely difficult or impossible for many reasons including the excellent ones listed below by Clay.

Jeff, this exclusive focus on "per brand" even in the context of a single company seems to be returning us to the "per domain" debate on which (I thought) we previously had consensus was too narrow of an approach. (Please see text in FPWD)


Sent from my Windows Phone
________________________________
From: Jeffrey Chester
Sent: 4/5/2012 4:15 PM
To: Clay Webster
Cc: Tracking Protection Working Group WG
Subject: Re: Parties and First Party vs. Third Party (ISSUE-10)

Clay:

It is not an interrogation, and I am sorry you took it that way.  It's about an informed discussion of what a user/consumer needs to understand to make their choice of DNT on or off meaningful.  The technical and business operations--and privacy issues--are all linked.  CBS should be able to answer whether it engages in the same set of data collection practices on each of its diverse brands.


Jeffrey Chester
Center for Digital Democracy
1621 Connecticut Ave, NW, Suite 550
Washington, DC 20009
www.democraticmedia.org<http://www.democraticmedia.org>
www.digitalads.org<http://www.digitalads.org>
202-986-2220

On Apr 5, 2012, at 7:02 PM, Clay Webster wrote:


Jeffrey,

The detailed example I provided is not an invitation for an interrogation.  I may be able to answer technical infrastructure questions which an example business with independent brands could encounter if DNT defined first parties by brands and not easy discover-ability.

--cw


On Thu, Apr 5, 2012 at 6:32 PM, Jeffrey Chester <jeff@democraticmedia.org<mailto:jeff@democraticmedia.org>> wrote:
We need to consider the different data collection strategies used by CBS Interactive brands, which users know little about.  For example, CNET Direct uses OBA;  CNET itself relies on "rich mobile and location-based programs."  Gamespot appears to use viral and video-based social media marketing ("addictive eye candy"); Maxpreps targets teens using "advergames," "Immersive environments," "video-in ad units," etc.

Does CBS use OBA on all its sites, including the one targeting teens?  Are all the sites using "immersive" techniques?  How many use advergames?  Perhaps we could have clarification from CBS that each site/brand engages in the same exact set of data collection practices, and that such data collection practices commonly deployed are easily discoverable.  For those wanting to look at the handy pdf descriptions of CBS Interactive, see links below

More at: http://www.cbsinteractive.com/our_brands.php?tag=main_wrap;sidebar
http://www.cbsinteractive.com/advertise/media-kit/