Bob Wyman (
Fri, 25 Oct 1996 08:45:07 -0400

Michael Tchong <> wrote:
> Advertisers and site operators need data on both
> site-specific and cross-site activity. I/PRO is in a
> unique position to provide this information and believes
> that aggregating and dissecting information from various
> sites helps the entire industry. The more data points
> you have, the better off we all are.

The off-site aggregation of log files from multiple sites is
inherently accompanied by danger to the privacy of each site's
readers as well as introducing legal risk to the maintainers of the
sites. Site maintainers can be held responsible for security breaches
at off-site aggregators with whom they contract. At HealthGate, where
our focus is on medical information, we must be particularly
sensitive to the often expressed privacy concerns of our readers. We
must also being wary of potential legal responsibility for abuse,
whether or not authorized, of any site data which is provided to
external organizations -- for whatever purpose.

If we were simply in the business of selling CD's online, we might be
more relaxed about allowing outside organizations to "aggregate and
dissect" our data. After all, how much damage can be done by finding
out that someone likes country music? However, people come to
HealthGate to find answers to questions about their AIDS condition,
their approaching menopause, the best way to handle warts, and a host
of other similarly private problems. Some of our consumers are
concerned that insurance companies might discover their reading
patterns and act on them... Some doctors are concerned that
malpractice lawyers might exploit the knowledge that a doctor had
read about a "better" procedure but then failed to use it... Whether
or not these concerns are well founded, we are forced to ensure that
we take every action possible to ensure the appearance of propriety.
It has also been suggested that we could be held legally responsible
for damages arising from a security break at the site of an "auditor"
which inadvertently revealed data concerning our readers.

Given these concerns, I don't feel we can allow our log data to be
"aggregated and dissected" by any organization, much less one that
has a history of publishing research reports. Similarly, I don't feel
it is appropriate to experiment with ad banner serving technologies
that allow outside organizations to extract from this site any
information from which the usage patterns of individuals can be
derived. Thus, we are barred from providing data to organizations
like I/PRO and NetCount or from allowing a Focalink, DoubleClick or
BannerExchange to tap into our traffic.

Hopefully, this will explain why we are currently leaning most
heavily towards ABVS, a subsidiary of the non-profit Audit Bureau, as
the "proper" organization to audit our site. Given that they are ONLY
in the business of doing audits and have decades of experience in
protecting the confidentiality of publisher's records, they are the
least likely to cause us problems. If we wanted research, we would
handle that as a completely separate issue from auditing.

I suggest that folk read Walt Mossberg's recent WSJ column (10/24)
entitled "Threats to Privacy On-Line Become More Worrisome." In the
column, Mossberg suggests that "the Internet threatens to have such a
profound effect on our sense of privacy that this may be one of the
rare areas where new protective laws and regulations will be

I would suggest that the growing number of services that rely on
off-site aggregation of usage logs are a very likely target of any
attempt to create new "laws and regulations" concerning privacy. In
many countries, and even within the US federal government, there are
already many laws and regulations that prohibit or control the
aggregation of personal information from multiple databases. It won't
take long before the "Internet Freedom Fighters" realize that the log
files are "databases" that contain a tremendous amount of sensitive
personal information.

Once the battle for privacy begins, I want my audits done by a
company that focusses on auditing, not research, and certainly not a
company which is lobbying or fighting in court just so that it can
stay in business.

bob wyman


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