Re: "Must be pseudonymized before statistical analysis begins, such that unique key-coded data are used to distinguish one individual from another without identifying them". Questions about this:
- What does "identifying" mean in this text? (One might read "without identifying" as requiring that data be "de-identified" according to the definition that appears elsewhere in the spec. But if the data qualifies as de-identified then no permitted use is required here because the general safe harbor for de-identified data already applies. Alternatively, if "identifying" means something different here, then that should be spelled out.)
- What does "unique key-coded data" mean? Is the text about "unique key-coded data ..." meant to serve as a definition of "pseudonymized"? If so, it seems overly prescriptive, requiring one particular method that (purportedly) qualifies as pseudonymized. Alternatively, this text might be read as requiring a particular (purported) pseudonymization method. If so, why require this particular method?
- Why allow pseudonymization to be delayed until "statistical analysis begins"? Why not require pseudonymization to be done promptly when data is initially collected?
Re: the "independent certification process under the oversight of a generally-accepted market research industry organization that maintains a web platform providing user information about audience measurement research. This web platform lists the parties eligible to collect information under DNT standards and the audience measurement research permitted use ..."
- The authors appear to have a specific organization in mind. Which organization is that, and who runs it?
- What is the rationale for giving a particular organization control over the the certification process and the ability to declare who is eligible to exercise this permitted use?