Privacy/TPWG/Change Proposal Limitations on use in Third Party Context

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issue-219

Proposal 1: No change

Proposal from Rob Sherman

Existing text

If a third party receives a DNT: 1 signal, then:

  1. the third party MUST NOT collect, retain, share, or use data related to the network interaction as part of which it received the DNT: 1 signal outside of the permitted uses as defined within this recommendation and any explicitly-granted exceptions provided in accordance with the requirements of this recommendation;
  2. the third party MUST NOT use data about previous network interactions in which it was a third party, outside of the permitted uses as defined within this recommendation and any explicitly-granted exceptions, provided in accordance with the requirements of this recommendation.

Proposal 2: Prohibit use of data collected as any type of party

Proposal from Walter van Holst; issue-219

Text would replace existing text in third-party compliance section (striking third from the relevant clause).

New text

... the third party MUST NOT use data collected in another context about the user, including when that party was a first party.

Old proposals

Third party use outside first party context is tracking

Proposal from Alan Chapell

This text would be appended to the first paragraph in the ED.

New text

Use of this data outside the first party context is tracking and subject to third party rules for tracking, as outlined in Section 5.

Use of 1st Party Data in a 3rd Party Context (Transparency)

Proposal from Yianni Lagos

This text would be in addition to existing First Party Compliance requirements in the editors' draft.

New text

If a Party receives a network transaction to which a DNT:1 header is attached, during that network transaction, that Party must not use data it previously collected while a First Party to customize the experience of a user while operating as a Third Party, unless that Party’s identity is transparent to the user. For example, the use of prominent branding directly on or around the content or advertisement would create transparency.