RE: ISSUE-25 re 5.2 Audience measurement: ACTION 415 June change proposal:

John,

I am sympathetic to your position, but I'm not sure how we get there. What should happen to the organizational and industry opt-out mechanisms in place today?

JC

From: John Simpson [mailto:john@consumerwatchdog.org]
Sent: Tuesday, July 9, 2013 2:29 PM
To: JC Cannon
Cc: Shane Wiley; Justin Brookman; Kathy Joe; Justin@cdt.org; Peter Swire; Israel, Susan; Adam Phillips; public-tracking@w3.org
Subject: Re: ISSUE-25 re 5.2 Audience measurement: ACTION 415 June change proposal:

JC,

My vision on DNT is essentially what the FTC called for.  I quote from Page 53 of their Privacy Report:

"As industry explores technical options and implements self-regulatory programs, and Congress examines Do Not Track, the Commission continues to believe that in order to be effective, any Do Not Track system should include five key principles. First, a Do Not Track system should be implemented universally to cover all parties that would track consumers. Second, the choice mechanism should be easy to find, easy to understand, and easy to use. Third, any choices offered should be persistent and should not be overridden if, for example, consumers clear their cookies or update their browsers. Fourth, a Do Not Track system should be comprehensive, effective, and enforceable. It should opt consumers out of behavioral tracking through any means and not permit technical loopholes. Finally, an effective Do Not Track system should go beyond simply opting consumers out of receiving targeted advertisements; it should opt them out of collection of behavioral data for all purposes other than those that would be consistent with the context of the interaction (e.g., preventing click-fraud or collecting de-identified data for analytics purposes)"

I think there is a problem if the standard which should be "implemented universally"  and " comprehensive" cites other opt-out mechanisms.  That confuses consumers.  If industry wants  various opt outs, I suppose that's OK, but it's not part of Do Not Track in my view.

Regards,
John

On Jul 9, 2013, at 1:31 PM, JC Cannon <jccannon@microsoft.com<mailto:jccannon@microsoft.com>> wrote:


John,

Could you provide some clarity around your statement? Are you saying that companies should not have a separate opt-out mechanism, should not be integrated with an industry opt-out mechanism or something else?

Thanks,
JC

From: John Simpson [mailto:john@consumerwatchdog.org<http://consumerwatchdog.org>]
Sent: Tuesday, July 9, 2013 12:11 PM
To: Shane Wiley
Cc: Justin Brookman; Kathy Joe; Justin@cdt.org<mailto:Justin@cdt.org>; Peter Swire; Israel, Susan; Adam Phillips; public-tracking@w3.org<mailto:public-tracking@w3.org>
Subject: Re: ISSUE-25 re 5.2 Audience measurement: ACTION 415 June change proposal:

Sorry, Shane.  Not following you. Can you please expand a bit on what you mean?

On Jul 9, 2013, at 12:00 PM, Shane Wiley <wileys@yahoo-inc.com<mailto:wileys@yahoo-inc.com>> wrote:



And this does provide for the opt-out of "tracking" but leaves the option available to users to receive a personalized web experience and not have someone "track" their activities across web sites.

- Shane

From: John Simpson [mailto:john@consumerwatchdog.org<http://consumerwatchdog.org>]
Sent: Tuesday, July 09, 2013 7:57 PM
To: Shane Wiley
Cc: Justin Brookman; Kathy Joe; Justin@cdt.org<mailto:Justin@cdt.org>; Peter Swire; Israel, Susan; Adam Phillips; public-tracking@w3.org<mailto:public-tracking@w3.org>
Subject: Re: ISSUE-25 re 5.2 Audience measurement: ACTION 415 June change proposal:

Shane,

Sorry, I always understood the goal of DNT was to provide users with  one simple way to opt out of tracking...

I don't have it front of me, but check the FTC's privacy report language.

Regards,
John

On Jul 9, 2013, at 11:34 AM, Shane Wiley <wileys@yahoo-inc.com<mailto:wileys@yahoo-inc.com>> wrote:




John,

Your concern is that users have more than one choice?  You'd rather force all users into a singular choice and provide them no gradients or fine tuning to these choices?  That doesn't seem fair to users.

User surveys in aggregate appear to say conflicting things: 1) users like personalized experiences -but- 2) don't feel comfortable with the idea of someone retaining a record of their cross-site activities.  Providing users with a small degree of granularity here (2/3 choices) appears to find the desired balance.

- Shane

From: John Simpson [mailto:john@consumerwatchdog.org<http://consumerwatchdog.org>]
Sent: Tuesday, July 09, 2013 11:27 AM
To: Justin Brookman
Cc: Shane Wiley; Kathy Joe; Justin@cdt.org<mailto:Justin@cdt.org>; Peter Swire; Israel, Susan; Adam Phillips; public-tracking@w3.org<mailto:public-tracking@w3.org>
Subject: Re: ISSUE-25 re 5.2 Audience measurement: ACTION 415 June change proposal:

Justin is right I was referring to ESOMAR's opt-out... And he concisely states my concern.


On Jul 9, 2013, at 11:17 AM, Justin Brookman <jbrookman@cdt.org<mailto:jbrookman@cdt.org>> wrote:





Actually, I think John was referring to the separate ESOMAR opt out for audience measurement.  So we are talking about at least three separate processes here under a combined industry standard --- opting out of Audience Measurement, DAA opt out of behavioral advertising, and Do Not Track specific urls.

Hoo boy . . .

Justin Brookman
Director, Consumer Privacy
Center for Democracy & Technology
tel 202.407.8812
justin@cdt.org<mailto:justin@cdt.org>
http://www.cdt.org<http://www.cdt.org/>
@JustinBrookman
@CenDemTech



On Jul 9, 2013, at 1:39 PM, Shane Wiley <wileys@yahoo-inc.com<mailto:wileys@yahoo-inc.com>> wrote:





John,

I believe you're speaking to the "Aggregate Scoring" element on this point, correct?

This gives users choices - each of which should be easily exercised:

Do Not Track Me:  Do not retain the URLs of my activities across non-affiliated sites.
Do Not Profile Me:  Do not build or use a profile of my perceived interests assembled through my activities across non-affiliated sites.

Users can turn on both.  DNT will be in the web browser (along with cookie blocking and other privacy tools already in place today).  DNP is associated with the AdChoices icon that will be available on hopefully every ad displayed on the Internet (that's goal with some exceptions).  Or they can just turn on DNT and continue to receive personalized experiences with the confidence their activities (URLs) across non-affiliated sites will not be retained in a identifiable/linkable manner.

- Shane

From: John Simpson [mailto:john@consumerwatchdog.org<http://consumerwatchdog.org/>]
Sent: Tuesday, July 09, 2013 10:21 AM
To: Kathy Joe
Cc: Justin@cdt.org<mailto:Justin@cdt.org>; Peter Swire; Israel, Susan; Adam Phillips; public-tracking@w3.org<mailto:public-tracking@w3.org>
Subject: Re: ISSUE-25 re 5.2 Audience measurement: ACTION 415 June change proposal:

Kathy Joe,

I am still troubled by the idea that you have a separate opt-out through an industry website.  This is confusing for consumers and undermines the concept of Do Not Track .
Regards,
John

---------
John M. Simpson
Privacy Project Director
Consumer Watchdog
2701 Ocean Park Blvd., Suite 112
Santa Monica, CA, 90405
Tel: 310-392-7041
Cell: 310-292-1902
www.ConsumerWatchdog.org<http://www.consumerwatchdog.org/>
john@consumerwatchdog.org<mailto:john@consumerwatchdog.org>



On Jul 9, 2013, at 6:51 AM, Kathy Joe <kathy@esomar.org<mailto:kathy@esomar.org>> wrote:






Dear All,

In a call last week between Justin Brookman, Peter Swire, Adam Phillips and myself, we discussed audience measurement research and as agreed, here is our proposal (new text in red) drafted to clarify the principle of 'pseudonymized' in the normative section, without going into technical detail.

"A third party eligible for an audience measurement research permitted use MUST adhere to the following restrictions. The data collected by the third party:

Must be pseudonymized before statistical analysis begins, such that unique key-coded data are used to distinguish one individual from another without identifying them."

I attach Issue 25 with the new text inserted.

Susan Israel, Jeff Chester and I have a call scheduled today.

Time permitting, we hope that the amended text can be tabled in tomorrow's call.


Kathy Joe,
Director, International Standards and Public Affairs
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Atlas Arena, 5th floor<http://www.esomar.org/>

Hoogoorddreef 5
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<4 July 2013 DNT W3C Revised text Issue 25 Aggregated data collection and use for audience measurement research.doc>