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Re: Proportionate Response for Fraud Prevention and Security (ISSUE-24)

From: Haakon Bratsberg <haakonfb@opera.com>
Date: Thu, 15 Mar 2012 23:55:25 +0100
Cc: Rigo Wenning <rigo@w3.org>, Tracking Protection Working Group WG <public-tracking@w3.org>
Message-Id: <A810C574-EC0D-41DF-8028-483943698853@opera.com>
To: "Roy T. Fielding" <fielding@gbiv.com>
On Mar 15, 2012, at 8:37 PM, Roy T. Fielding wrote:

> On Mar 15, 2012, at 2:19 AM, Rigo Wenning wrote:
> 
>> Roy, Jonathan, Shane, 
>> 
>> On Wednesday 14 March 2012 11:39:55 Shane Wiley wrote:
>>> Please understand these activities are to PROTECT users and businesses alike
>>> (depends on the attack).  I'm hopeful we don't purposely create real risk
>>> of harm to users in our attempts to "lock down" the DNT standard.
>> 
>> Security vs Privacy is a big classic in data protection. Our forefathers of 
>> data protection in the seventies said that good data protection is requiring 
>> more secure systems to protect also against abuse of personal information. So 
>> they tried to harmonize security and data protection. 
>> 
>> On the one hand, I have a lot of sympathy with Roy warning us to open that can 
>> of worms. I would be very reluctant to include security-related provisions 
>> into the two Specifications. On the other hand, I also have a lot of sympathy 
>> for the suggestion to use the present expertise to have some privacy 
>> suggestions for the fraud-fighters in the Web's payment channel. 
>> 
>> Because PROTECT is relative. I'm pretty sure that Assad claims to PROTECT 
>> Syria. So only saying "protect" as a use limitation doesn't save our live 
>> here.  A best practices document on fraud protection for ad companies would be 
>> cool. This could determine unnecessary data collection and identify doubtful 
>> sharing practices that would allow to abuse the data collected for fraud 
>> protection. In one word, make fraud protection for the web smarter to some 
>> extend, privacy wise.. And I think that in a second generation, we could have 
>> a framework where a service agrees to back down a bit because the users have 
>> decided (via DNT) not to be as highly secured because they favor privacy in a 
>> given context.
> 
> That's all true, Rigo, but it has nothing to do with DNT.  DNT does not exist
> to solve all privacy problems.  User preferences cannot solve security problems.
> There is a continual tug of war between security and privacy, yes, but it is
> not our war to resolve.  As I said, I strongly encourage regulators to take this
> on directly, if they have not done so already, since it is not a matter that
> user preferences/consent can resolve.  Fraud control is not about consent.
> 
> Data retention for the sake of fraud control should be limited regardless of
> the DNT signal because it should be assumed that the user has not consented
> (they are usually not given a choice).  I don't know how they should be limited.
> I am certain that this working group is incapable of reaching consensus on
> how fraud control must be limited, since it depends on the nature of the
> fraud, the nature of what is being protected, and the nature of the
> organization doing the protection.
> 
> In short, we have neither the time, nor the expertise, nor the authority to
> address this problem in general, other than to say that:
> there exists an exemption for fraud control and data collection/retention/use
> under that exemption must be limited to what is necessary for that fraud control.

Couldn't agree more. 

Haakon
Received on Sunday, 18 March 2012 20:48:30 UTC

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