[Responder] Jack Hobaugh
In general, I object to the porting of a TCS compliance definition into the TPE. I feel strongly that the TPE should remain a pure protocol and technical specification document. Some have contended that some TCS definitions are needed in the TPE in order for the user to understand the choice that the user is making regarding the DNT signal. This is simply not the case. A technical specification need only specify the requests and responses necessary for a DNT protocol to be implemented in a scalable and implementable solution across all browsers and the servers called. A technical specification should not inform the user regarding a policy or compliance choice but instead should inform the technical community on how to implement a technical solution. The compliance specification for the DNT signal should be left to the compliance regime, whether it is a national compliance regime, a W3C-based compliance regime or an industry-based compliance regime. Porting definitions from a particular compliance regime into the TPE only serves to provide an incomplete and confusing picture to those attempting to implement the technical protocol. Porting an overly broad or unclear definition of Tracking into the TPE does nothing to help the user understand his or her DNT choice. The user preference that should be supported within the scope of the TPE is fairly simple - to send or not send a DNT signal. Such a preference choice is easily supported by the TPE without importing definitions from the TCS. Specifically, I object to this definition of tracking to the extent that it contains words and phrases that are yet to be fully explored and defined within the TPWG. For example, it is already admitted that “context” is an undefined term. Also, “Data Controller” and “multiple distinct contexts” are not defined. In the non-normative text offered with this proposal, there is a proposed definition for context. But this definition has not been vetted within the TPWG. This highlights the process issues with attempting to define a crucial compliance term without first defining or at the same time defining the necessary terms contained in the proposed definition. If the co-chairs dismiss Option C, although I have serious objections against both Option A and Option B, I would prefer Option A over Option B.