- From: David Singer <singer@apple.com>
- Date: Thu, 02 Feb 2012 08:47:18 +0000
- To: Bryan Sullivan <blsaws@gmail.com>
- Cc: "public-tracking@w3.org (public-tracking@w3.org)" <public-tracking@w3.org>
On Feb 2, 2012, at 5:00 , Bryan Sullivan wrote: > "Records derived when DNT is on (1), MUST be held separately from other > data derived when DNT is not on (1).": By "MUST be held separately", you > are not intending to imply any particular technical or physical approach > to the "separation" are you? No, just that the two databases must be kept distinct (you, before you turned on DNT, and you, after you did). > > As noted in other threads, "research/market-analytics" and "product > improvement" are important exceptions that depend upon short-term > retention of data (typically not PII though) prior to analysis/aggregation. This is about separating records that are 'polluted' with full-on tracking, and records that are 'tunnel-vision'; they mustn't be mixed. > > Otherwise your definition looks very close. > > Thanks, > Bryan > > On 1/29/12 8:15 AM, "David Singer" <singer@apple.com> wrote: > >> This is a revision of my previous email, and a response to Action-77, >> which is one of 6 (?) actions related to Issue-5. Please ask questions >> as needed to clarify, and I will write a composite revised definition, so >> we can close Action-77, and (once that's been done for the other >> formulations) Issue-5. >> >> This is an alternative to restricting tracking via a 1st/3rd party >> distinction. I want to emphasize, I am doing this to explore and learn, >> not to 'promote' any particular direction. I hope people find it helpful. >> >> (All these definitions etc. rely on being able to define "site" or >> "party", by the way. I don't see how to escape that, as many have >> pointed out, since it's within a 'party' that information flows, and so >> on.) >> >> >> RULE >> >> Informally, we allow sites only to record what they do and learn >> *directly* about the interaction between themselves and the user. >> >> The formal rule is this: >> >> When DNT is on (1): >> Data records that both identify or could identify, a single USER, and >> also identify, or could identify, a single SITE (that is part of a Party), >> * MUST identify or be capable of identifying no other Party, or site that >> is part of any other Party; >> * MUST be derived only from transactions directly between the identified >> Party and the user, possibly combined with publicly available data, >> * MUST be available/accessible only to/by the identified Party, >> * MUST NOT contain user-specific non-public information derived or >> passed, directly or indirectly, from any other Party, >> >> If the data is held by another party on behalf of the identified party, >> that holding party MUST have no rights to use the data. >> >> Records derived when DNT is on (1), MUST be held separately from other >> data derived when DNT is not on (1). >> >> EXCEPTIONS >> >> not needed: >> >> Outsourcing exception: not needed, it's part of the rule in the first >> place. >> 1st-party exception: not needed: all sites/parties are allowed to >> remember the user's interactions with them. >> Unidentifiable data exception: not needed, as the definition here only >> concerns user-identifiable data in the first place (which can probably be >> true for all rule sets) >> Operational exceptions: >> frequency capping, story-boarding: not needed; the ad site is permitted >> to remember what IT served YOU, just not a lot of why (which 1st party >> you were on, etc.) >> financial logging: separate un-identified records can be kept on the >> number of impressions on a 1st-party site (why is this not true for all >> proposals?) >> 3rd party auditing: again, is it necessary to keep a record that >> identifies a specific user? >> >> potentially needed: >> >> Operational exceptions: >> security/fraud: an exception may be needed here, especially if >> cross-site fraud is to be detected >> research/market-analytics: we don't have a current formulation, and the >> title is broad enough to allow almost anything, so I can't tell >> product improvement: this is an issue, again with a serious risk of >> slippery slope >> debugging: yes, an exception may be needed for debugging >> Legal exception: tracking to the extent required by law >> >> Comments on TUNNEL-VISION >> >> If a user runs sometimes with DNT:0 and sometimes DNT:1, they will end up >> with two records at sites, one with a lot of other-site data, and the >> second record with tunnel-vision. Correlation by the site would enable >> merging these; this is the weakest aspect of this strawman, IMHO. Under >> the alternative 'cross-site' formulation, I think each site would keep >> N+1 records (1 for when DNT is off, and N for the number of 1st party >> sites 'seen' by this 3rd party for this user). >> >> Frequency capping and storyboarding by advertisers are now permitted; you >> ARE allowed to remember what ad you showed this (anonymous) user, since >> that was *your* transaction. You're limited in remembering only >> site-generic 'why' -- you cannot remember 'they visited Sears and so I >> showed a dishwasher advert'. >> >> If the user starts interacting with *you*, you can remember that also; we >> don't need language to make this an exception, or 'promotion' from 3rd to >> 1st party. >> >> Redirection services can remember basically only that the user was active >> on the web, since everything else they know (the original URL, the >> re-direct) either identify or could be used to identify another site. >> >> The attraction of this rule is that many fewer exceptions are needed. >> The downside of this formulation is that it relies on sites not to >> re-correlate the records, though there is still a lot of data that cannot >> be recorded. >> >> David Singer >> Multimedia and Software Standards, Apple Inc. >> >> >> > > David Singer Multimedia and Software Standards, Apple Inc.
Received on Thursday, 2 February 2012 08:47:53 UTC