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 know you disagree, that is why we need this discussion on record. I 
am open for a new word an invite you to propose a better word for the 
yellow. De-identified aka not about a person anymore is a concern to me 
that I expressed previously, because in the EU it is still considered 
personal data. The best word in my vocabulary is pseudonumous, since new 
data can still be linked to already collected data. Having taken out 
identiying elements through data scrubbing is not enough to make it 
anonymous. unlinkability is key here, hence the 3 state approach.

On the scope of the process of de-identification, in the 3 state 
approach, the process includes the second step to make data unlinkable 
through various anonymization techniques.

Looking forward to a new word and would like to learn if you disagree 
if the process of de-identification includes all 3 states.

Rob

John Simpson schreef op 2013-05-15 21:50:
> 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 20:08:17 UTC