W3C home > Mailing lists > Public > public-geolocation@w3.org > April 2009

Re: geolocation privacy statement strawman

From: Andrei Popescu <andreip@google.com>
Date: Wed, 8 Apr 2009 12:13:27 +0100
Message-ID: <708552fb0904080413m5ff67e5ei98a439c3f08c7bae@mail.gmail.com>
To: Alissa Cooper <acooper@cdt.org>
Cc: public-geolocation <public-geolocation@w3.org>
Hi Alissa,

Thanks a lot for the comments!

On Sat, Apr 4, 2009 at 12:19 PM, Alissa Cooper <acooper@cdt.org> wrote:
>> Privacy considerations for implementers of the Geolocation API:
>>
>> User Agents must not send location information to websites without
>> express permission of the user. Browsers should acquire permission
>> through a user interface which will include the URI of the document
>> origin. All permissions should be revocable, and User Agents should
>> respect revoked permissions.
>
> FWIW, I agree with Angel that the "shoulds" above should be "musts." If the
> whole section is going to be non-normative anyway, what's the harm?
>

I thought about this more and I'd like to propose that these sections
remain normative and, hence, use RFC 2119 terminology. What do you
think? Also, in such a case, is the current usage of "shoulds" vs
"musts" reasonable to you?

>>
>>
>> Some User Agents will have prearranged trust relationships that do not
>> require such user interfaces.
>
> To ensure that the sentence above doesn't swallow the considerations for
> implementers entirely, I would say something like, "In limited
> circumstances, certain User Agents will have. . .." Otherwise every UA could
> claim to have "prearranged trust relationships."
>

Agreed.

>> For example, a Web browser will present
>> a user interface when a Web site performs a geolocation request.
>> However, a voip telephone may not present any user interface when
>> using location information to perform an E911 function.
>>
>> Privacy considerations for recipients of location information:
>>
>> The two primary concerns regarding recipients of location information
>> are retention and retransmission.
>
> I'm not so sure that this is true. A design decision was made within Geopriv
> to include default privacy rules about retention and retransmission, but
> that decision was based on several factors, with level of "concern" being
> only one of them. As the rest of this paragraph explains, there are other
> privacy considerations besides retention and retransmission (use,
> disclosure, etc.), so I'm not sure how much value is added by declaring that
> two of these are "primary." I would drop this sentence.
>

Here I have the same question as Doug.

> Before getting into use limitation as the next sentence does, it might make
> sense to say something about limiting collection, such as:
>
> Web sites must only request location when necessary.
>
> This might seem really obvious, but a surprising amount of data collection
> goes on "just because" (look at how much data most Facebook apps collect
> compared to what they need to deliver their services). This trend has made
> collection limitation a pretty standard privacy principle.
>

Sounds good to me (+ same question as Doug, especially if this section
stays normative).

>> Recipients must only use the
>> location information for the task for which it was provided to them
>> and must dispose of it once completed, unless expressly permitted to
>> do so.
>
> Nit: It is unclear what the phrase "to do so" refers to in the above
> sentence -- using the information for other tasks, or retaining it beyond
> the completion of a task? Suggestion:
>
> Recipients must only use location information for the task for which it was
> provided to them. Recipients must dispose of location information once that
> task is completed, unless they are expressly permitted to retain it by the
> user.
>

Sounds good.

>> Recipients must also take measures to protect this information
>> against unauthorized access. If location information is stored, users
>> should be allowed to update and delete this information. The recipient
>> of location information should not retransmit the location information
>> without the userís consent.
>
> To stay consistent with the rest of this text, the sentence above should say
> "user's express consent." Also, both of the "shoulds" in the above should be
> "musts."
>

I think these should be "shoulds" if the section stays normative?

>> Care should be taken when retransmitting
>> and use of HTTPS is encouraged. Furthermore, a clear and accessible
>> privacy policy should be made available to all users that details the
>> usage of location data.
>
> This disclosure suggestion is a little limiting if the words "privacy
> policy" are interpreted to mean the usual long privacy statement linked at
> the bottom of a Web site. It might make sense to leave some room for
> disclosure in other places. It could also be more clear about what needs to
> be disclosed -- there is a pretty standard set of items that are usually
> disclosed in notices like this. Suggestion:
>
> Recipients must clearly and conspicuously disclose the fact that they are
> collecting location data, the purpose for the collection, how long the data
> is retained, how the data is secured, how the data is shared if it is
> shared, how users may access, update and delete the data, and any other
> choices that users have with respect to the data. This disclosure must
> include an explanation of any exceptions to the guidelines listed above.
>

Sounds good (+ same question as Doug).

Again, thanks for the contribution, it is great we are making progress on this.

All the best,
Andrei
Received on Wednesday, 8 April 2009 11:14:04 GMT

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