June Change Proposal: text on de-identification

Problem

"Data is deidentified when a party:

	• has achieved a reasonable level of justified confidence that the data cannot be used to infer information about, or otherwise be linked to, a particular consumer, computer, or other device;
	• commits to try not to reidentify the data; and
	• contractually prohibits downstream recipients from trying to re-identify the data."

1) We have had (from Ed?) text that suggests better wording than "reasonable level of justified confidence" .

2) If we have a definition of 'tracking' data, we should use it.  

3) "downstream" is undefined, and actually we don't care where in a hypothetical stream you are, we want the data not to identify.  

Proposal:

1)  I think it was something like "to a generally accepted high level of confidence".  I suggest we find text that says that basically you're doing as well as the normal state of the art.

2) Suggest "the data is not, and cannot be made into, tracking data" instead of "cannot be used to infer information about, or otherwise be linked to, a particular consumer, computer, or other device"

3) Delete "downstream" or replace it with "any".


David Singer
Multimedia and Software Standards, Apple Inc.

Received on Thursday, 20 June 2013 22:06:28 UTC