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Re: Best Practices for Outsourcing (ACTION-47, ISSUE-49)

From: Vinay Goel <vigoel@adobe.com>
Date: Fri, 16 Mar 2012 06:14:33 -0700
To: Tracking Protection Working Group WG <public-tracking@w3.org>
Message-ID: <CB88B4C0.476F%vigoel@adobe.com>
Hi Jonathan,

This is a normative statement (and not a non-normative statement as you've
labeled it) and is inappropriate for inclusion in the spec.  It belongs
within a Best Practices document separate from the Compliance/Preferences
Specs that is best published by someone other than the WG.


-Vinay

___________________________________________________________________________
________
Vinay Goel | Privacy Product Manager | Adobe Systems | Office: 917.934.0867


On 3/14/12 8:08 PM, "Jonathan Mayer" <jmayer@stanford.edu> wrote:

>Here's some non-normative text on best practices for outsourcing.
>
>--------------------------------------------------
>
>I. Technical Precautions
>
>A. Siloing in the Browser
>
>Outsourcing services should use browser access control features so that
>stored data specific to one first party is never accessed or collected
>when the user visits another first party.
>
>i. Same-Origin Policy
>
>The same-origin policy silos stored data by domain name.  An outsourcing
>service can use a different domain name for each first party.
>
>Example: Example Analytics provides an outsourced analytics service to
>Example News and Example Sports, two unrelated websites.  Example
>Analytics stores its cookies for Example News at
>examplenews.exampleanalytics.com, and it stores its cookies for Example
>Sports at examplesports.exampleanalytics.com.
>
>An outsourcing service could also use the first party's domain.
>
>Example: Example Analytics stores its cookies for Example News at
>examplenews.com, and it stores its cookies for Example Sports at
>examplesports.com.
>
>ii. Cookie Path Attribute
>
>The HTTP cookie path can be used to silo data to a first party.
>
>Example: Example Analytics stores its cookies for Example News with
>"Path=/examplenews", and it stores its cookies for Example Sports with
>"Path=/examplesports".
>
>iii. Storage Key
>
>For key/value storage APIs, such as Web Storage and Indexed Database, an
>outsourcing service can use a different key or key prefix for each first
>party.
>
>Example: Example Analytics stores data for Example News at
>window.localStorage["examplenews"] and data for Example Sports at
>window.localStorage["examplesports"].
>
>B. Siloing in the Backend
>
>i. Encryption Keys
>
>An outsourcing service should encrypt each first party's data with a
>different set of keys.
>
>ii. Access Controls
>
>An outsourcing service should deploy access controls so that only
>authorized personnel are able to access siloed data, and only for
>authorized purposes.
>
>iii. Access Monitoring
>
>An outsourcing service should deploy access monitoring mechanisms to
>detect improper use of siloed data.
>
>C. Retention in the Backend
>
>An outsourcing service should retain information only so long as
>necessary to provide necessary functionality to a first party.  If a
>service creates periodic reports, for example, it should delete the data
>used for a report once it is generated.  An outsourcing service should be
>particularly sensitive to retaining protocol logs, since they may allow
>correlating user activity across multiple first parties.
>
>II. Business Precautions
>
>i. Policy
>
>An outsourcing service should establish a clear internal policy that
>gives guidance on how to collect, retain, and use outsourced data in
>compliance with this standard.
>
>ii. Training
>
>Personnel that interact with outsourced data should be familiarized with
>internal policy on compliance with this standard.
>
>iii. Supervision and Reporting
>
>An outsourcing service should establish a supervision and reporting
>structure for detecting improper access.
>
>iv. Auditing
>
>External auditors should periodically examine an outsourcing service to
>assess whether it is in compliance with this standard and has adopted
>best practices.  Auditor reports should be made available to the public.
>
>


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Received on Friday, 16 March 2012 13:15:26 UTC

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