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Re: definition of "unlinkable data" in the Compliance spec

From: Grimmelmann, James <James.Grimmelmann@nyls.edu>
Date: Sun, 23 Sep 2012 23:00:59 +0000
To: "public-tracking@w3.org wg" <public-tracking@w3.org>
Message-ID: <32B31F1A-CE38-405A-9425-83D932027BD4@nyls.edu>
The distinction between "ad network data" and "1st party declared information and stored at the user's request" isn't meaningful in the context of a discussion about identifiability.  Whether data is "unlinkable" is a property of the data, not of the context in which it was obtained, the purposes for which it is used by the provider, or the consent given by the user.  The data doesn't care whether it's first-party or third-party.  Hence my emphasis on real-world harms from linkable IP addresses.

I thought your earlier comments in the thread, about industry practices involving rotating and deleting salts and about various forms of access control, were quite helpful.  It would be useful to hear more from you about them.  
It seems plausible, to me at least, that some of the technical measures already in widespread use in the industry would indeed satisfy everyone's goals for unlinkability.  It will be easier to write a definition blessing certain practices if there is a shared understanding of what they are.

James

--------------------------------------------------
James Grimmelmann   	          Professor of Law
New York Law School                 (212) 431-2864
185 West Broadway       james.grimmelmann@nyls.edu
New York, NY 10013    http://james.grimmelmann.net

On Sep 23, 2012, at 3:01 PM, Shane Wiley <wileys@yahoo-inc.com> wrote:

> James,
> 
> This has absolutely nothing to do with the current debate or focus of DNT.  The issue you highlight below was 1st party user declared information and stored at the user's request.  Please feel free to join us in the DNT debate when you're ready to more meaningfully contribute to progress.
> 
> - Shane
> 
> -----Original Message-----
> From: Grimmelmann, James [mailto:James.Grimmelmann@nyls.edu]
> Sent: Sunday, September 23, 2012 11:32 AM
> To: Shane Wiley
> Cc: Jeffrey Chester; Ed Felten; public-tracking@w3.org
> Subject: Re: definition of "unlinkable data" in the Compliance spec
> 
> Two words: Shi Tao.  And two more: Wang Xiaoning.
> 
> I understand that it was not "ad network data" that was used to sentence these men to ten years each in prison for criticizing the Chinese government.  But it was identifying data held by Yahoo!, which has a deep involvement in providing online advertising.  In Tao's case the IP address was used to tie him to specific messages.  When governments ask, and the data exists, the industry has a history of turning it over.  Understandably, participants in the DNT process would like to ensure that when data is said to be "unlinkable" it really is technically unable to be reidentified, and not just as a matter of ""strict access controls, policies, and employee education," which could all be reversed as a result of legal process or corporate policy change.
> 
> James
> 
> --------------------------------------------------
> James Grimmelmann              Professor of Law
> New York Law School                 (212) 431-2864
> 185 West Broadway       james.grimmelmann@nyls.edu<mailto:james.grimmelmann@nyls.edu>
> New York, NY 10013    http://james.grimmelmann.net
> 
> On Sep 23, 2012, at 1:23 PM, Shane Wiley <wileys@yahoo-inc.com<mailto:wileys@yahoo-inc.com>> wrote:
> 
> Jeff,
> 
> The assertions are fair but were not intended to attack anyone personally and simply call out the very real divide between classroom scenarios and real-world ones.
> 
> As for "data", could you please first provide the data of situations where 3rd party ad network data has been requested via subpoena and/or breached in a manner that there was some harm to a user?  This would allow us to have a more balanced conversation as to the appropriate measures to anonymize data in proportion to the real-world threat it exposes consumers to.
> 
> Thank you,
> Shane
> 
> From: Jeffrey Chester [mailto:jeff@democraticmedia.org<http://democraticmedia.org>]
> Sent: Sunday, September 23, 2012 10:19 AM
> To: Shane Wiley
> Cc: Ed Felten; Grimmelmann, James; <public-tracking@w3.org<mailto:public-tracking@w3.org>>
> Subject: Re: definition of "unlinkable data" in the Compliance spec
> 
> Can I suggest we refrain from making broad (and unfounded) assertions about what is "a highly simplified response...for a classroom" versus so-called real world.  I am sure you didn't mean it in a personal way, but it could be interpreted as dismissive of one of the leading experts in the field.
> 
> We simply haven't had the data presented to us from the online marketing industry about theiractual practices so as a collective group within the W3C we can make informed decisions.  I would hope we would all recognize that the "truth" so to speak lies somewhere in between the artificial rhetorical poles we have set up here.  Amsterdam, and the coming weeks after, is a place to finally ensure that information is placed on the table so both Internet users and online ad companies can have a informed discussion.
> 
> Jeff
> 
> On Sep 23, 2012, at 1:05 PM, Shane Wiley wrote:
> 
> 
> Ed,
> 
> I believe your approach makes inaccurate assumptions (IPv4 only) and requires the salt up-front which wouldn't occur in the real-world.  This also fails to consider more advanced approaches to keyed one-way hashing/salting such as multi-permutator passes which is where most corporations are at today.
> 
> Again, a highly simplified response which is absolutely appropriate for a classroom or small lab setting but completely misses the mark in the real-world.
> 
> - Shane
> 
> From: Ed Felten [mailto:ed@felten.com]
> Sent: Saturday, September 22, 2012 12:53 PM
> To: Shane Wiley
> Cc: Grimmelmann, James; <public-tracking@w3.org<mailto:public-tracking@w3.org>>
> Subject: Re: definition of "unlinkable data" in the Compliance spec
> 
> Reversing salted IP hashes requires 9 lines of code.
> 
> def reverseIpHash(salt, target):
>   trialString = copy.copy(salt)
>   trialString.extend(bytearray(4))
>   for ip in range(256*256*256*256):
>       trialIp = bytearray([(ip>>24)&0xff,(ip>>16)&0xff,(ip>>8)&0xff,ip&0xff])
>       trialString = copy.copy(salt)
>       trialString.extend(trialIp)
>       if hashlib.sha1(trialString).digest()==target:
>           return ip
> 
> 
> On Sat, Sep 22, 2012 at 12:42 PM, Shane Wiley <wileys@yahoo-inc.com<mailto:wileys@yahoo-inc.com>> wrote:
> Ed,
> 
> Not "easy" if the salt/key is strongly protected and/or rotated/destroyed on a regular basis.  A dictionary attack requires either the raw data or access to the salt key - neither of which should be made easy/possible.  I tend to see the IP Address issue through the lens of IPv6 these days which further creates barriers to what you position as "easy to recover".
> 
> The advocacy side of the group tends to lean towards absolutist terms and solutions - the real world isn't that easy even if it feels that way in a classroom or a small lab.
> 
> - Shane
> 
> From: Ed Felten [mailto:ed@felten.com<mailto:ed@felten.com>]
> Sent: Saturday, September 22, 2012 5:30 AM
> 
> To: Shane Wiley
> Cc: Grimmelmann, James; <public-tracking@w3.org<mailto:public-tracking@w3.org>>
> Subject: Re: definition of "unlinkable data" in the Compliance spec
> 
> It's easy to recover hashed IP addresses if they're hashed as a whole (and not per-octet).   An straightforward dictionary attack will work against all IPv4 addresses.  Even a dumb brute-force search over the entire 32-bit space is feasible.  IPv6 is a bit more complicated--some will be recoverable and some won't, depending on details of address allocation.
> 
> On Fri, Sep 21, 2012 at 1:16 PM, Shane Wiley <wileys@yahoo-inc.com<mailto:wileys@yahoo-inc.com>> wrote:
> Ed,
> 
> I disagree with the concept of "easy to recover" as I'm not suggesting hashing the individual octets but rather the entire IP Address (not a single octet or individualized octet hashing) - especially as you apply this to IPv6.  With the appropriate level of access to raw and hashed datasets, the necessary tools, and the intent, some anonymization schemes can be hacked (dictionary attacks being the most straight forward).  I don't believe the goal here is an absolutist one (aka "completed destruction of identifiers") and that is why "commercially reasonable" is the appropriate outcome.
> 
> - Shane
> 
> From: Ed Felten [mailto:ed@felten.com<mailto:ed@felten.com>]
> Sent: Friday, September 21, 2012 10:01 AM
> To: Shane Wiley
> Cc: Grimmelmann, James; <public-tracking@w3.org<mailto:public-tracking@w3.org>>
> 
> Subject: Re: definition of "unlinkable data" in the Compliance spec
> 
> By the way, hashing IP addresses (with or without salting) does not render them unlinkable.   After hashing, it's easy to recovery the original IP address.  The story is similar for other types of unique identifiers--there are ways to get to unlinkability, but hashing by itself won't be enough.
> 
> On Fri, Sep 21, 2012 at 12:01 PM, Shane Wiley <wileys@yahoo-inc.com<mailto:wileys@yahoo-inc.com>> wrote:
> <Ed - apologies for not getting back to you sooner - I was on vacation for the past week.>
> 
> James,
> 
> I like your approach the best and it was this perspective I was intending when writing the text that Ed is questioning.
> 
> The goal is to find the middle-ground between complete destruction of data and an unlinkable state that still allows for longitudinal consistency for analytical purposes BUT CANNOT be linked back to a production system such that the data could be used to modify a single user's experience.
> 
> For example, performing a one-way secret hash (salted hash) on identifiers (Cookie IDs, IP Addresses) and storing the resulting dataset in a logically/physically separate location from production data with strict access controls, policies, and employee education would meet the definition of "unlinkable" I'm aiming for.
> 
> - Shane
> 
> -----Original Message-----
> From: Grimmelmann, James [mailto:James.Grimmelmann@nyls.edu<mailto:James.Grimmelmann@nyls.edu>]
> Sent: Friday, September 21, 2012 8:14 AM
> To: Lauren Gelman
> Cc: Ed Felten; <public-tracking@w3.org<mailto:public-tracking@w3.org>>
> Subject: Re: definition of "unlinkable data" in the Compliance spec
> 
> I really like Lauren's suggestion.  My only concern is that "reasonably" and "reasonable" have so many different meanings in legal settings that it could be ambiguous.  Sometimes an action is "reasonable" if a person who is ethical and cautious would do it: it's not reasonable to leave sharp tools lying around in a children's play area, or to invest a trust fund in marshmallows.  Sometimes it refers to what a rational non-expert would believe about the subject, so a court will uphold a jury verdict unless "no reasonable jury" could have reached the conclusion it did.  Sometimes it's about the norms and expectations of an industry.  An auction might need to be conducted in a "commercially reasonable" way, which means for example giving enough notice that there will be real competitive bidding, but not spending more than the property is worth.
> 
> I think this last sense is the most appropriate one in context.  So perhaps something like "data that cannot be associated with an identifiable person or user agent through commercially reasonable means."  That is, the question would be whether a normal business with normal resources and motivations would consider reidentifying the data to be feasible.
> 
> James
> 
> --------------------------------------------------
> James Grimmelmann              Professor of Law
> New York Law School                 (212) 431-2864<tel:%28212%29%20431-2864>
> 185 West Broadway       james.grimmelmann@nyls.edu<mailto:james.grimmelmann@nyls.edu><mailto:james.grimmelmann@nyls.edu<mailto:james.grimmelmann@nyls.edu>>
> New York, NY 10013    http://james.grimmelmann.net
> 
> On Sep 20, 2012, at 7:22 PM, Lauren Gelman <gelman@blurryedge.com<mailto:gelman@blurryedge.com><mailto:gelman@blurryedge.com<mailto:gelman@blurryedge.com>>> wrote:
> 
> 
> Unlinkable data is data that cannot reasonably be associated with an identifiable person or user agent.
> 
> Lauren Gelman
> BlurryEdge Strategies
> 415-627-8512<tel:415-627-8512>
> 
> On Sep 18, 2012, at 8:05 AM, Ed Felten wrote:
> 
> Sorry to repost this, but nobody has answered any of my questions about Option 1 for the unlinkability definition.
> 
> Note to proponents of Option 1 (if any): If nobody can explain or clarify Option 1, that will presumably be used as an argument against Option 1 when decision time comes.
> 
> ---------- Forwarded message ----------
> From: Ed Felten <ed@felten.com<mailto:ed@felten.com><mailto:ed@felten.com<mailto:ed@felten.com>>>
> Date: Thu, Sep 13, 2012 at 5:03 PM
> Subject: definition of "unlinkable data" in the Compliance spec
> To: "<public-tracking@w3.org<mailto:public-tracking@w3.org><mailto:public-tracking@w3.org<mailto:public-tracking@w3.org>>>" <public-tracking@w3.org<mailto:public-tracking@w3.org><mailto:public-tracking@w3.org<mailto:public-tracking@w3.org>>>
> 
> 
> I have some questions about the Option 1 definition of "Unlinkable Data", section 3.6.1 in the Compliance spec editor's draft.   The definition is as follows [fixing typos]:
> 
> A party renders a dataset unlinkable when it:
> 1. takes commercially reasonable steps to de-identify data such that there is confidence that it contains information which could not be linked to a specific user, user agent, or device in a production environment [2. and 3. aren't relevant to my questions]
> 
> I have several questions about what this means.
> (A) Why does the definition talk about a process of making data unlinkable, instead of directly defining what it means for data to be unlinkable?  Some data needs to be processed to make it unlinkable, but some data is unlinkable from the start.  The definition should speak to both, even though unlinkable-from-the-start data hasn't gone through any kind of process.  Suppose FirstCorp collects data X; SecondCorp collects X+Y but then runs a process that discards Y to leave it with only X; and ThirdCorp collects X+Y+Z but then minimizes away Y+Z to end up with X.  Shouldn't these three datasets be treated the same--because they are the same X--despite having been through different processes, or no process at all?
> (B) Why "commercially reasonable" rather than just "reasonable"?  The term "reasonable" already takes into account all relevant factors.  Can somebody give an example of something that would qualify as "commercially reasonable" but not "reasonable", or vice versa?  If not, "commercially" only makes the definition harder to understand.
> (C) "there is confidence" seems to raise two questions.  First, who is it that needs to be confident?  Second, can the confidence be just an unsupported gut feeling of optimism, or does there need to be some valid reason for confidence?  Presumably the intent is that the party holding the data has justified confidence that the data cannot be linked, but if so it might be better to spell that out.
> (D) Why "it contains information which could not be linked" rather than the simpler "it could not be linked"?  Do the extra words add any meaning?
> (E) What does "in a production environment" add?  If the goal is to rule out results demonstrated in a research environment, I doubt this language would accomplish that goal, because all of the re-identification research I know of required less than a production environment.  If the goal is to rule out linking approaches that aren't at all practical, some other language would probably be better.
> 
> (I don't have questions about the meaning of Option 2; which shouldn't be interpreted as a preference for or against Option 2.)
> 
> 
> 
> 
> 
> 
> 
> 
Received on Sunday, 23 September 2012 23:02:09 UTC

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