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Re: ISSUE-235 (Auditability requirement for security)

From: Walter van Holst <walter.van.holst@xs4all.nl>
Date: Wed, 05 Nov 2014 17:59:51 +0100
To: David Singer <singer@apple.com>
Cc: Justin Brookman <jbrookman@cdt.org>, Tracking Protection Working Group <public-tracking@w3.org>
Message-ID: <6befa15a1347db781dfe67e910d1f3d4@xs4all.nl>
On 2014-11-05 17:15, David Singer wrote:

> 
> There is something a little odd about adding a retention requirement
> to a specification which, on the face of it, is trying to minimize the
> amount of data retained.

Like I wrote before: this should not be construed as a retention 
requirement and frankly I find it mind-boggling that it has been read as 
such.

> Audit-ability could as easily be process rather than data based,
> couldn’t it?  An auditor could check what processes and procedures are
> defined, and that they are followed in practice.

Anyone who has ever been in the remote vicinity of EDP audits will tell 
you that audits are first and foremost about process and if they are 
data based, they focus on data on the execution of the processes and not 
so much on the data itself. Because the data is at best relevant to a 
pure financial audit, which still would be worthless if the data cannot 
be relied on because the processes for maintaining its integrity weren't 
in place. When it comes to auditing whether data has or hasn't been 
shared the data itself is beyond useless because you can never tell who 
has had access to it. That's what process logs are for.

Genuinely puzzled here,

Walter

P.S. Am again unable to attend the call.
Received on Wednesday, 5 November 2014 17:00:20 UTC

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