[Responder] David Singer
This definition has many problems. 1) It needs a definition of 'context', as noted. 2) It's probably not comprehensible to users, whereas the purpose of the definition is to reflect the users' general desires. Users' general objection is to 'keeping records about them' and this is more complex and rather different from that. 3) It talks about the symptom (tying contexts together) rather than the activity or problem (collection and retention of personal data). 4) It would appear to permit a great deal of recording; ad servers could record everything they see about a user 'in their context', for example. Indeed, it appears only to restrict connecting those records 'outside the ad server context', e.g. to the sites on which the ads appeared. That's permitting a lot of tracking and retention. If that is not the intent of the definition, it's misleading. 5) It appears to be a formal definition, but it's at odds with what the current compliance draft actually restricts (there is nothing in there about multiple contexts, for example).