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Web Analytics - US Federal Government Cookie Policy Under Review

By ()   Jun 17, 2009   

Over the last few months, there has been a great deal of activity at the most senior levels of the US Government discussing the use of persistent cookies on federal agency web sites. If you are a Federal Web Manager or Web Analyst, you are painfully aware of the constraints on using cookies and the limitations it causes to a more accurate definition of unique visitor, and some of the more advanced segmentation features available in web analytics solutions.

As part of a greater effort to open up policy discussions, the White House, Office of Science and Technology Policy is taking public comment on the Federal Policy on Cookies as well as other issues impacting use of the Web.

If you've been doing web analytics within the Federal government, I'd suggest you weigh in on this. To comment, go to: http://blog.ostp.gov/category/requests-for-comment/ (you'll need to register before commenting)

My comments are on the site and printed in entirety below. My recommendations for a new policy are fairly straightforward.

  • Allow the use of first party, persistent cookies for Web site measurement.
  • Prominently disclose how Web site measurement is used and how the data is collected and analyzed.
  • Provide instructions for how users may delete persistent cookies from their browser settings.
  • Combination of PII and unique visitor ID (persistent cookie ID) will not be used for analysis.

What is your take? This is a highly critical time regarding the use of cookies. If you read my post below, you'll see that there are those who are actually suggesting that information that has been used historically, such as IP addresses, be disallowed or severely constrained.

Privacy advocates have a very strong voice in this debate, and while I'm all for privacy protections (see my series of posts on privacy, I'm very concerned that the focus on privacy could hamper the effectiveness of Federal web site analysis, even while allowing for the use of persistent cookies. You can read a few of the positions being advocated at these sites:

Make your own determination, and use this opportunity to voice your opinion: http://blog.ostp.gov/2009/06/16/enhancing-online-citizen-participation-through-policy/.

Phil Kemelor's Comments:

The issue of whether and how to permit the use of persistent cookies on Federal agency Web sites is one that tends to be charged with emotion primarily around the concern over personal privacy as it relates to Web site data collection.

However, I believe this concern is based on misperceptions about persistent cookies, the nature of Personal Identifiable Information (PII) and how this data may be used.

A persistent cookie is a unique string of text that is placed on the visitor’s computer during his or her first visit and recorded by the site measurement tool in subsequent visits. Because the cookie is unique, any visit from that same computer is considered unique, and is defined as being a “unique visitor.” If the visitor registers on the site and provides personal information, that information can be associated to the specific computer. The visitor will be recognized as unique on all subsequent visits. However, unless the user voluntarily provides personal information, the persistent cookie simply records activity from the computer. For example, if a person has a computer at work and at home, and goes to a particular Web site, there will be a cookie issued for both computers. There is nothing to link that individual with activity on those Web sites.

 

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