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Change proposal: Counterproposal for a 3-state approach (R-Y-G)

From: Rob van Eijk <rob@blaeu.com>
Date: Wed, 03 Jul 2013 16:28:30 +0200
To: <public-tracking@w3.org>
Message-ID: <4b3ab23ed611c2e343eb17906a9cdec0@xs4all.nl>

Peter,

I added the following change proposal to the wiki: 
www.w3.org/wiki/Privacy/TPWG/Change_Proposal_Deidentification

Counterproposal for a 3-state approach (R-Y-G)

Proposal from Rob van Eijk email to the list.

non normative text: When applying a 3 state approach to data collection 
and subsequent processing, data is considered:

  * Red, meaning in a RAW state and linkable;
  * Yellow, meaning in an intermediary state towards de-identification 
and still linkable;
  * Green: meaning in a de-identified state and no longer linkable. Data 
may be shared under the obligation to manage the risk of 
re-identification.

Data is de-identified (Green) when a party, including the party that 
collected the data:

  * has taken reasonable steps to ensure that the data as been deleted, 
modified, aggregated, anonymized, made unlinkable or otherwise 
manipulated in order to achieve a reasonable level of justified 
confidence that the data cannot reasonably be used to infer information 
about, or otherwise be linked to, a particular user, user agent, or 
device.

Data is not de-identified (Red, Yellow) when it is still possible to 
link new data to already collected data.
Received on Wednesday, 3 July 2013 14:29:02 UTC

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