Posted by Brendon Lynch
Chief Privacy Officer, Microsoft

Our customers expect strong privacy protections to be built into Microsoft technologies, so we make privacy a priority. Our inclusion of Do Not Track (DNT) in Internet Explorer 10 and Internet Explorer 11 is an example of how we strive to meet these expectations.

We believe DNT holds potential to help people better manage their privacy online. However, until stakeholders collectively agree on what DNT means and how websites should respond to the DNT signal, its promise will not be fully realized. Microsoft has been steadfastly committed to and engaged in the W3C's Tracking Protection Working Group’s efforts to define a DNT standard. Developing standards that work across an entire industry is often difficult, but the benefits make the effort worthwhile.

The W3C asked Tracking Protection Working Group members to respond to a public online poll by Wednesday. The purpose of the poll is to help the Working Group chairs determine how and whether to proceed with DNT standards work; members may vote for more than one option and submit comments for consideration by the chairs. Our public comments can be found below.

Microsoft supports continuing work toward a DNT standard and we hope the representatives of all the other parties that make up the Working Group will do the same. A final, meaningful DNT standard will help build greater trust across the Internet ecosystem, and we look forward to continue working together to achieve this goal.

Here are our public comments:

The Microsoft participants in the TPWG believe that Options 1 and 2 provide the best path forward for the TPWG, while being open to Option 3 as a practical measure given the current status of TPE and Compliance specifications. 

Microsoft’s customers expect strong privacy protections to be built into our technologies, and we believe that DNT holds potential to help them better manage their online privacy. However, until stakeholders collectively agree on what DNT means and how it should be implemented, its promise will not be fully realized.

From the beginning of this TPWG process, and now with all major browsers offering users the ability to send DNT signals, there has been broad consensus that it is important to be able to explain the meaning of DNT to users in a consistent manner. In order to accomplish this, the interdependencies between TPE and Compliance documents must be aligned. In practice, this means that they should progress to CR and the corresponding call for implementations simultaneously. This rules out option 4. Since the TPE document appears to be further along, Microsoft can live with an earlier Last Call for TPE (option 3) to give more time for comments. This will be more successful if the dependencies between the documents are more clearly articulated in the TPE spec first.

At Microsoft, our preference is to work through the issues following the (long established but rarely practiced) working group decision policy [1]. Members have already devoted substantial resources to identifying specific Change Proposals during the summer, and members have continued to submit specific text proposals more recently in alignment with the call to raise and document issues by mid-October. We should work through these Change Proposals via the decision policy. We felt that this process worked well in settling highly contentious issues in the HTML Working Group from which some of the principles were drawn. Further, we believe that it is important to adopt a predictable work schedule that also echoes the HTML WG style: once an issue enters the process for consideration and filing of counter proposals, there are clear predictable deadlines that avoid surprising members of the group. As part of that process, we acknowledge that members may identify issues that should be deferred to DNT 2.0, but we are concerned that attempting to identify topics for DNT 2.0 planning in advance will slow down substantive discussions.

Following the decision policy will be key to implementing the proposed plan (option 1) and it is important that everybody understands this process. In the HTML WG, there was the opportunity for people to raise issues and seek clarifications against the decision policy, and this helped to refine both the description of the process and its implementation. One recommendation we have is to invite the HTML WG chairs to a TPWG telcon to discuss their experience with the HTML WG process and to answer any questions members have.

A final, meaningful DNT standard will help build greater trust across the Internet ecosystem and we look forward to continue working together to achieve this goal.

[1] http://www.w3.org/2011/tracking-protection/decision-policy.html