- From: Christopher Allen <ChristopherA@blockstream.com>
- Date: Tue, 18 Jul 2017 08:43:51 -0700
- To: Kim Hamilton Duffy <kim@learningmachine.com>
- Cc: "W3C Credentials CG (Public List)" <public-credentials@w3.org>, "W3C Digital Verification CG (Public List)" <public-digital-verification@w3.org>
- Message-ID: <CA+HTxFfnUuB=z-yi0CJDoQzaar3C3TvCs6mZcJcsDHXvUte4VA@mail.gmail.com>
On Fri, Jul 14, 2017 at 4:31 PM, Kim Hamilton Duffy <kim@learningmachine.com > wrote: > 4. Data Minimization and Selective Disclosure (20 minutes) > - Christopher and Jan to facilitate discussion > - Discuss topics, Q&A > Jan has some slides, which I’ve posted at https://drive.google.com/open?id=0B8UHtBOakwo8cDg1M3JjRDBqUmM On my side, which we don’t have time to report out, are some thoughts on data minimization. Here is some of my research so far on the the requirements for the most basic of the items “data minimization”. What are its best practices? Best tactics? No easy answers. NIST and GDPR says we have to do it, but not a lot of requirements. ===== NIST SP 800-63 Digital Identity Guidelines https://pages.nist.gov/800-63-3/ https://pages.nist.gov/800-63-3/sp800-63a/sec8_privacy.html ### 8.1 Collection and Data Minimization Section 4.2 requirement 2 permits the collection of only the PII necessary to validate the existence of the claimed identity and associate the claimed identity to the applicant, based on best available practices for appropriate identity resolution, validation, and verification. Collecting unnecessary PII can create confusion regarding why information not being used for the identity proofing service is being collected. This leads to invasiveness or overreach concerns, which can lead to loss of applicant trust. Furthermore, PII retention can become vulnerable to unauthorized access or use. Data minimization reduces the amount of PII vulnerable to unauthorized access or use, and encourages trust in the identity proofing process. http://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-63c.pdf 9.3 Data Minimization Federation enables the data exposed to an RP to be minimized — resultantly, the subscriber’s privacy is enhanced. Although an IdP may collect additional attributes beyond what the RP requires for its use case, only those attributes that were explicitly requested by the RP are to be transmitted by the IdP. In some instances, an RP does not require a full value of an attribute. For example, an RP may need to know whether the subscriber is over 13 years old, but has no need for the full date of birth. To minimize collection of potentially sensitive PII, the RP may request an attribute reference (e.g., Question: Is the subscriber over 13 years old? Response: Y/N or Pass/Fail). This minimizes the RP’s collection of potentially sensitive and unnecessary PII. Accordingly, Section 7.3 requires the RP to, where feasible, request attribute references rather than full attribute values. To support this RP requirement IdPs are, in turn, required to support attribute references. ---- http://www.lewik.org/term/13593/data-minimisation-principle-gdpr/ Data minimisation principle (GDPR) Definition Personal data shall be: (c) Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’); Source law General Data Protection Regulation Chapter II, Article 5, paragraph 1 --- https://www.privacy-regulation.eu/en/5.htm 1. Personal data shall be: (a) processed lawfully, fairly and in a transparent manner in relation to the data subject ('lawfulness, fairness and transparency'); => Article: 6, 9 (b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes ('purpose limitation'); => Article: 26 (c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed ('data minimisation'); (d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay ('accuracy'); => Article: 16 (e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject ('storage limitation'); (f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures ('integrity and confidentiality'). => Article: 24, 32 2. The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1 ('accountability'). => Article: 77, 82, 83 ========== The best source I’ve found so far (sent by Jan) are some what is desirable or undesireable in data minimization: ========= Pfitzmann, A & Hansen M — "A terminology for talking about privacy by data minimization: Anonymity, Unlinkability, Undetectability, Unobservability, Pseudonymity, and Identity Management" http://dud.inf.tu-dresden.de/literatur/Anon_Terminology_v0.34.pdf **Anonymity** of a subject from an attacker’s perspective means that the attacker cannot sufficiently identify the subject within a set of subjects, the anonymity set. VS. **Identifiability** of a subject from an attacker’s perspective means that the attacker can sufficiently identify the subject within a set of subjects, the identifiability set. --- **Unlinkability** of two or more items of interest (IOIs, e.g., subjects, messages, actions, ...) from an attacker’s perspective means that within the system (comprising these and possibly other items), the attacker cannot sufficiently distinguish whether these IOIs are related or not. VS. **Linkability** of two or more items of interest (IOIs, e.g., subjects, messages, actions, ...) from an attacker’s perspective means that within the system (comprising these and possibly other items), the attacker can sufficiently distinguish whether these IOIs are related or not. --- **Undetectability** of an item of interest (IOI) from an attacker’s perspective means that the attacker cannot sufficiently distinguish whether it exists or not. VS. **Detectability** of an item of interest (IOI) from an attacker’s perspective means that the attacker can sufficiently distinguish whether it exists or not. --- **Unobservability** of an item of interest (IOI) means * undetectability of the IOI against all subjects uninvolved in it and * anonymity of the subject(s) involved in the IOI even against the other subject(s) involved in that IOI. VS. **Observability** of an item of interest (IOI) means: <many possibilities to define the semantics>. ======== — Christopher Allen
Received on Tuesday, 18 July 2017 15:44:50 UTC