RE: ISSUE-198: Define new word for yellow state due to the fact that the process of de-identification spans all three states (red,yellow and green).

John,

Great question.  Raw data in this context is data collected that is unaltered from its originally collected form (minimization could of course occur).  Data in this state can be anywhere in the personal data spectrum: personally identifiable, pseudonymous, or anonymous.  

One of the leading Pseudonymous definitions in the EU Draft Regulation debate is:  'pseudonymous data' means any personal 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.  For example, if a unique ID is placed in a cookie but that ID is not able to be attributed to a specific data subject (meaning the "real person") without additional data then it meets the definition of Pseudonymous.  This is important state to the privacy discussion as up until this point the argument has always centered around two positions: is data personally identifiable (personal data in EU context) or is it anonymous?  Pseudonymous provides a meaningful middle point to better balance the debate and offer differentiated treatment to this class of identifier/data.

- Shane 

-----Original Message-----
From: John Simpson [mailto:john@consumerwatchdog.org] 
Sent: Wednesday, May 15, 2013 12:51 PM
To: Shane Wiley
Cc: rob@blaeu.com; Tracking Protection Working Group
Subject: Re: ISSUE-198: Define new word for yellow state due to the fact that the process of de-identification spans all three states (red,yellow and green).

Shane,
I'm not sure I follow how raw data equates with pseudonymous data.  Could you please point me to definitions you're using so I can better understand what you mean here.
Thanks,
John

On May 15, 2013, at 12:40 PM, Shane Wiley <wileys@yahoo-inc.com> wrote:

> Rob,
> 
> I strongly disagree and believe based on the current definitions of pseudonymous being considered in the EU context, data in the Red area can meet this definition.  Similarly, yellow data meets the definition of de-identified in both the FTC and DAA contexts - whereas "Unlinked" is a bit more debatable.
> 
> So I believe it's still appropriate to define these as:
> 
> Stage 1:  Raw/Pseudonymous
> Stage 2:  De-Identified
> Stage 3:  Unlinkable (or simply - Out of Scope)
> 
> As these terms has highly loaded in the regulatory context there will continue to be significant sensitivity to naming conventions here.  This is similarly true of the color scheme proposed due to the immediate traffic light connotations it invokes (green = good, yellow = caution, red = bad).  I was okay (not happy) with using colors in this manner but don't believe it's fair to over bias the definitions of each phase based on an overly conservative read of existing definitions. 
> 
> - Shane
> 
> -----Original Message-----
> From: Rob van Eijk [mailto:rob@blaeu.com]
> Sent: Wednesday, May 15, 2013 12:03 PM
> To: Tracking Protection Working Group
> Subject: ISSUE-198: Define new word for yellow state due to the fact that the process of de-identification spans all three states (red,yellow and green).
> 
> 
> Dear group,
> 
> As discussed at the Face to Face and a previous thread [1], there is confusion on the word de-identified data. We discussed the three state model, that I introduced in Cambridge. The FTC text defines unlinkability in terms of de-identification, which makes the term de-identified applicable for the green state. The DAA text Due to the fact that the process of de-identification spans up to the green state when data is considered unlinkable, I would like to propose a new term for the yellow domain.
> 
> <text proposal>
> 
> red data: raw data, event level data
> yellow data: pseudonumous data
> green data: de-identified data
> 
> </text proposal>
> 
> 
> [1]
> http://lists.w3.org/Archives/Public/public-tracking/2013Mar/0147.html
> 
> Tracking Protection Working Group Issue Tracker schreef op 2013-05-15
> 20:47:
>> ISSUE-198: Define new word for yellow state due to the fact that the 
>> process of de-identification spans all three states (red,yellow and 
>> green).
>> 
>> http://www.w3.org/2011/tracking-protection/track/issues/198
>> 
>> Raised by:
>> On product:
>

Received on Wednesday, 15 May 2013 20:05:38 UTC