New Change Proposal: New text for definition of Shares (Issue-16)

Current text: "A party shares data if the party enables another party to receive or access that data."

Proposed new text: "A party shares data if the party enables another party to collect, retain or use that data."

Rationale: The introduction of 'receive or access' does not make sense nor define what receive or access means.  For example, a company is not 'using' data if it merely forwards it to another party.  Yet the company is then sharing the data since it is providing access to the data.  And, in the current text, there are no restrictions upon first parties sharing data (there is a restriction against 'passing' data).  I believe it would be better to use defined terms here of what we're actually trying to stop — a company from allowing another party from collecting, retaining or using data as a workaround to the DNT:1 signal.  This way, if a company receives a DNT:1 signal, it cannot have another party (who may or may not be complying with DNT) collect, retain or use data.

Draws upon: Issue-16

-Vinay

Received on Tuesday, 24 September 2013 14:55:50 UTC