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HomeHomeUsing DNN Platf...Using DNN Platf...Administration ...Administration ...DNN and SEC's "Internet Availability of Proxy Materials" RulesDNN and SEC's "Internet Availability of Proxy Materials" Rules
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6/25/2014 2:24 PM
 
Andy Hintze


Joined: 10/23/2007
Posts: 3

Has anyone dealt with the SEC's "Internet Availability of Proxy Materials" Rules on a DNN site? I am trying to decipher if the typical cookies DNN sets would violate the rules. Here is a link to the document I am referencing: http://www.sec.gov/rules/final/2007/34-55146.pdf (specifically pages 22 & 23).

 My initial thought is that cookies set by DNN would not be considered "tracking cookies". I would also guess that including Google Analytics on the page would violate the rules.

I am hoping to avoid creating a stand-alone similarly skinned HTML page for this.

 Any thoughts would be appreciated!

Thanks
 
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6/25/2014 4:30 PM
 
cathal connolly


cathal connolly's Avatar

www.cathal.co.uk
Joined: 4/9/2003
Posts: 9676
I haven't read that exact document but we've had similar requests primarily around the EU legislation on cookie consent so I created a wiki page on cookie usage @ http://www.dnnsoftware.com/wiki/page/... and another on EU cookies at http://www.dnnsoftware.com/wiki/page/... that should be of interest. I can't answer the question on whether google analytics is a tracking cookie as different legislation interprets it differently (i.e. from a technical point of view it's tracking a user, but some legislation exempts it, whereas others doesnt as google uses the information gained for it's adverts/use of doubleclick)
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6/27/2014 10:40 AM
 
Andy Hintze


Joined: 10/23/2007
Posts: 3
Cathal, thanks much for the reply. Your thoughts and the DNN Cookie Wiki page is valuable information.

To wrap up my thoughts: I do not see how any of the default DNN cookies could be considered "tracking" cookies as outlined in the SEC document, but when dealing with rules such as those, the only safe solution would be to create a stand-alone HTML page for "Proxy Material" content that has no associated cookies.

Does anyone have any thoughts on alternative solutions?
 
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6/27/2014 3:36 PM
 
cathal connolly


cathal connolly's Avatar

www.cathal.co.uk
Joined: 4/9/2003
Posts: 9676
your issue is that cookies are automatically sent by the browser when a request is made for a domain that cookies exist for - if you wish to have a separate page with no associated cookie you need a separate full-qualified domain i.e. a parent and not a child so existing cookies don't "flow" - however this would also need to exist outside DNN as a static page
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