colin_wallis at hotmail.com
Mon Jul 13 22:28:39 CDT 2015
I've (personally) commented <<inline>> below.
From: mark at smartspecies.com
Date: Mon, 13 Jul 2015 13:51:23 -0400
To: lc at kantarainitiative.org
CC: wilton at isoc.org
I have updated the comments a little with a couple of policy notes and some edits. Robin do you have any thoughts about these comments? ( There are many ways to address notice and consent issues. )
“We may use your information to: To provide you with personalized content.”
- Is there personalised content or ads? if not this should be removed. If this is true, this should arguably be a listed purpose and possibly reflected in a consent receipt.
<<CW: I don't believe there is, or has ever been, but was probably considered as 'future proofing' Kantara's website activity. I support removing this statement>>..
its not clear why personal information would be transferred to another country other than the US
why this would be done without explicit consent - seem to ambiguous and I suggest a review
If this is necessary, then this will require something like Safe Harbour or BCRS to make compliant, (or) adding more purposes and consent options.
<<CW: I don't know the background either, but I could imagine 2 possible intentions: 1) geographically distributed data centers for cloud based SaaS offerings like Confluence, 2) the opening of another (European?) office for Kantara which might require some transfer>>
Storing information in the US could be added to the consent receipt as a purpose and be explicitly agreed to in the join form.
Remove/change ,” may be transferred to other countries … “ unless Kantara is unaware, or does this without consent. If this is the case, then, Safe Harbour needs to be used.
<<CW: So working on my assumptions above, and the notion of another office has not gone away, I think we need to do both of these suggestions above>>.
We are starting to work on best practices for an implementation of a consent receipt, these can be found here
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