- From: Joseph Lorenzo Hall <joehall@gmail.com>
- Date: Wed, 20 Jun 2012 14:45:09 -0400
- To: Shane Wiley <wileys@yahoo-inc.com>
- Cc: "public-tracking@w3.org" <public-tracking@w3.org>
Some comments on the Evolving Online Privacy proposal: * Definitions: I think there's still some work needed in the definitions section for this to be more clear. For example, in (C) a first party is defined as "the party that owns the Web site or has control over the Web site the consumer visits"; "owns" and, moreso, "controls" here aren't defined. I doubt a user posting something to a forum, for example, is what you intended by "controls" but to some extent that user is changing the content of the web site that other users will see. * Also, the NOTE in that definition seems to enumerate a few actions that don't result in a first-party relationship... but is it only those three? Is there a more neutral way to word that or maybe list the actions that do explicitly result in a "first party widget interaction"? * Later in the document, you use the word profiling as in "No profiling" (which is bolded... which raises what the meaning of bolded text is in this document). What "profiling" means doesn't seem defined. * p. 2 uses "browser agent" when I think you mean "user agent". * typo, p.2: "DNT significantly impacted the availability" -> "DNT significantly impacting the availability" * I'm a little skeptical that aggregate reporting requires retaining raw data... but I'm not familiar with how that works. (for sums, at least, you can do a running sum... doesn't work so well with other kinds of statistics (like median). * I don't think I understand III (4)(b)... servers should be able to defend a decision? That could use a bit more precision. * Finally, the last bullet in unlinkability says you can hash a unique ID to anonymize and that servers should rotate keys. First, this has probably been mentioned before, but hashing a unique ID is pseudonymization, not anonymization. Second, cryptographic hashing doesn't involve a key... it typically takes "salt" which can make dictionary attacks harder. However, unless the input is particularly rich, the space of possible values this would "hash" to is small, so it's not so much about rotating keys (which sounds more like HMAC) but password-like protections for "key stretching" (e.g., running a hash algorithm many, many times so that you effectively increase the time (effort) an attacker would need to expend. This is all a long winded way of saying that if you want to begin to anonymize for unlinkability, you'll have to simply remove unique IDs, not turn them into another kind of unique ID. best, Joe -- Joseph Lorenzo Hall Postdoctoral Research Fellow Media, Culture and Communication New York University https://josephhall.org/
Received on Wednesday, 20 June 2012 18:46:19 UTC