- From: Nicholas Doty <npdoty@w3.org>
- Date: Thu, 27 Jun 2013 00:51:00 -0700
- To: Thomas Schauf <schauf@bvdw.org>, "Roy T. Fielding" <fielding@gbiv.com>
- Cc: "public-tracking@w3.org Mailing List" <public-tracking@w3.org>
Hi Thomas and Roy, I have added these two proposals to the wiki page collecting change proposals on deidentification: http://www.w3.org/wiki/Privacy/TPWG/Change_Proposal_Deidentification Thomas, I modified your language slightly in a way that I believe is easier to read in a grammatical way, but isn't intended to change its apparent meaning. Thanks, Nick On Jun 26, 2013, at 9:03 AM, Thomas Schauf <schauf@bvdw.org> wrote: > On issue 188 the existing text in sec. 2.8 is pretty unclear: "has achieved a reasonable level of justified confidence" > I would like to make a proposal which is more European/German legal language: > > Data is deidentified when a party: > 1. data that has been collected, altered or otherwise processed so that it of itself cannot be attributed to a data subject without the use of additional data which is subject to separate and distinct technical and organisational controls to ensure such non attribution, or that such attribution would require a disproportionate amount of time, expense and effort. > > KR, Thomas > > Thomas Schauf > Head of European & International Affairs > Von: Roy T. Fielding [mailto:fielding@gbiv.com] > Betreff: June Change Proposal, de-identified > > This is ISSUE-188 > > The definition of de-identified does not capture the discussion we had on list regarding anonymous data and the unnecessary burden of contracts. It also uses old terms like "consumer" > and "computer" that we don't need, and is phrased in terms of the process of de-identification (what a party must do) rather than the state of the data after de-identification has completed. > > Existing text in Sec 2.8: > ============================ > Data is deidentified when a party: > > 1. 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; 2. commits to try not to reidentify the data; and 3. contractually prohibits downstream recipients from trying to re-identify the data. > ============================ > > Replacement: > ============================ > A data set is considered de-identified when there exists a reasonable level of justified confidence that the data within it cannot be used to infer information about, or otherwise be linked to, a particular user. > ============================ > > ....Roy
Received on Thursday, 27 June 2013 07:51:09 UTC