- From: Marcos Caceres <marcosc@opera.com>
- Date: Wed, 21 Jul 2010 17:52:20 +0200
- To: public-privacy@w3.org
Hi, During the workshop we discussed the possibility of gathering best practices for API design that focus on privacy. We also discussed setting up a place where we could document how implementations had dealt with privacy aspects of certain APIs (e.g., <input file> and geolocation). In my paper [1], I used a simple critical framework (based on Daniel J. Solove's 2007 book The Future of Reputation [3]) for doing such evaluations based on accessibility, control, and confidentiality. The framework served its purpose for the short paper I wrote - but we obviously need something better. Other sources, such as Nick Doty, Deirde K. Mulligan and Erik Wilde's paper "Privacy Issues of the W3C Geolocation API" [2], provides a more comprehensive critical framework based around appropriateness, minimization, user control, notice, consent, secondary use, distribution, retention, transparency and aggregation. Daniel J. Solove book, Understanding Privacy [5], also provides an extensive taxonomy which could potentially be applied as a critical framework to evaluate and discuss privacy aspects of implementations. I don't know if anyone has actually done that or not in the literature. Another interesting framework we could look at is the one that is the e seven principles of the OECD’s recommendations for protection of personal data, which are summarized on Wikipedia [4]: [[ Notice — data subjects should be given notice when their data is being collected; Purpose — data should only be used for the purpose stated and not for any other purposes; Consent — data should not be disclosed without the data subject’s consent; Security — collected data should be kept secure from any potential abuses; Disclosure — data subjects should be informed as to who is collecting their data; Access — data subjects should be allowed to access their data and make corrections to any inaccurate data; and Accountability — data subjects should have a method available to them to hold data collectors accountable for following the above principles. ]] To get the ball rolling, in my paper, I made the following recommendations. I don't suggest we use we use this exact wording, as the following is just a slightly modified copy paste from my paper. 1. Browsers must avoid confirmation dialogs that don’t allow users to make informed decisions. 2. Digital signatures must be only used to verify data integrity and verify continuity of authorship, and should not exclusively be used as a means of enabling APIs. 3. Where device capabilities are required by applications, those capabilities must be declared by the author up-front. Where capabilities are declared and potentially affect a user’s privacy, the system must provide a user interface to view which capabilities will be used by an application. 4. As exemplified by the Geolocation Spec, and where necessary, standards bodies must mandate that conforming user agents provide user interfaces that give end-users access and control over privacy preferences. 5. Where it makes sense, it must be possible to change providers – particularly third-party providers. And where the provider is a third party, the provider’s privacy policy must be accessible and intrinsically linked in the user interface. 6. Communication between the provider and the client must be encrypted, particularly in the case of third-party providers. 7. Browser vendors must work together to reach de facto or de jure standardization of iconic activity indicators (as has effectively been achieved with the padlock indicator for secure communication). 8. Policy and law makers should work with the public to come up with more accessible privacy policies (i.e., like the creative commons icons, but for privacy policies). 9. When it comes to storing privacy choices that an end-user has made, such as which provider to use, those choices should be treated as sensitive data and appropriately secured via, for example, cryptographic means. End user’s should be informed of any attempt by a third party to temper with their choices. I would like to add this one too: 10. Where possible, a "reverse cookie" or "rule set" should be used to give users control over how their data is used/stored by a third party (as third parties do when they sent data to clients). Kind regards, Marcos [1] http://datadriven.com.au/2010/06/privacy-of-geolocation-implementations/ [2] http://escholarship.org/uc/item/0rp834wf [3] http://docs.law.gwu.edu/facweb/dsolove/Future-of-Reputation/text.htm [4] http://en.wikipedia.org/wiki/Data_Protection_Directive [5] http://docs.law.gwu.edu/facweb/dsolove/Understanding-Privacy/ -- Marcos Caceres Opera Software
Received on Wednesday, 21 July 2010 15:52:54 UTC