Data Deletion Request Handing spec #6

alextcone · 2020-05-11T16:24:02Z

For CCPA/US Privacy Technical Working Group approval before merge

CCPA/Data Deletion Request Handling.md

lon-pilot-mpf · 2020-05-13T15:37:01Z

CCPA/Data Deletion Request Handling.md

+       if(typeof (json) === 'object' && json !== null && '__uspapiCall' in json)
+       {
+        var i = json.__uspapiCall;
+        window.__uspapi(i.command, i.version, function (retValue, success) 


Does this need the extra optional parameter ('identifiers') used in non-web contexts as a placeholder?

yes, probably

can you show exactly where that would go?

It's already there I think. I may have missed it in my original comment or it may have been added (not honestly sure which). It's on line 229 below.

CCPA/Data Deletion Request Handling.md

Co-authored-by: lon-pilot-mpf <36295845+lon-pilot-mpf@users.noreply.github.com> Co-authored-by: Andrea Giannangelo <facens@gmail.com>

alextcone · 2020-05-20T23:39:36Z

@Facens and @lon-pilot-mpf there are two more questions on the code example that I myself cannot resolve. Ideally we could publish this this week (as I'm already a week behind my artificial deadline). How do you suggest we resolve? If we did resolve those questions would you both give an official approval? Would like to have two from the group here!

Facens · 2020-05-21T13:32:28Z

@alextcone I don't have the competence to respond. I think you should loop in Jan or someone else who's savvy on the JS side.

janwinkler

the part from
// find the __uspapi frame
untill the end of the script needs to be wrapped into a
if(!('__uspapi' in window))
{
....
}

alextcone · 2020-05-21T19:21:26Z

CCPA/Data Deletion Request Handling.md

+
+```
+// find the __uspapi frame
+if(!('__uspapi' in window)){


@janwinkler did I do this correctly?

It looks correct to me, though I think best practice would wrap the whole thing in an anonymous script block.
So at the top you put:
(function(window, document) {
And at the end of the file add this:
}(window, document));

chrispaterson · 2020-05-22T00:16:12Z

CCPA/Data Deletion Request Handling.md

+Publishers working with any services provided by these vendors consume the exposed JavaScript and embed it on their properties where consumers can request deletion of their personal data. If data deletion is requested, all vendor javascript on the publisher property is notified. Vendors then respond by deleting the relevant personal data and signaling any affected vendors downstream.
+
+
+### Multiple Services


From the blurb above in the CCPA Regulation:

direct any service providers to delete the consumer's personal information from their records

The relationship is consumer to service provider not consumer to service. So, therefore, no matter how many services a Vendor provides, there is only one request to be made to that Vendor and therefore no need to support multiple services. There is nothing prohibiting a Vendor from doing this either, but it shouldn't be specified in this document.

chrispaterson · 2020-05-22T00:21:26Z

CCPA/Data Deletion Request Handling.md

+The technical solution detailed in this specification provides the means to signal consumer requests for data deletion. Companies supporting the US Privacy Framework (i.e., service providers) will respond to the signals by deleting the consumer's relevant personal data to the extent required by CCPA. The process for deletion depends on the company's technology and operational practices in place. _How_ a vendor deletes a consumer's personal data is out of scope for this specification.
+
+
+### Non-web Environments


"In-App" is correct term here. "In-App" was created specifically for this use case. I understand it has a Mobile-only feel but that's only because Mobile is the biggest use case. If a clarifying statement is needed then add that.

My problem with Non-web is that it then proceeds to tell us to use a web page in the non-web environment. It sounds like there is no Internet connection or something.

chrispaterson · 2020-05-22T00:33:56Z

CCPA/Data Deletion Request Handling.md

+
+When operating in a non-web environment, data deletion requests are handled by sending the user to a web page where they can complete the request to have their data deleted. Vendors need certain information to correctly identify the data to delete:  the platform name, the unique app identifier used in the app store, and the device identifier for that platform / store. 
+
+The `performDeletion` command includes a parameter for identifiers. Using the `identifiers` parameter, publishers can pass multiple items, each with the required fields: `platform`, `app_identifier`, and `user_identifier`. These details should be passed from the app context to the delete webpage and then along with the request from the page. Below are a few examples of that information:


I don't think it is ever possible to have more than one platform, app_identifier, or user_identifier in a single app.

You may need to pass the deletion for multiple apps at the same time?

@Facens this software only runs in one App at a time

chrispaterson · 2020-05-22T00:37:28Z

CCPA/Data Deletion Request Handling.md

+```
+
+```
+Note: For purposes of this explanation, a "bundle id" is used for (iOS) and a "package" for (Android).


for which property?

app_identifier I believe @chrispaterson

chrispaterson · 2020-05-22T00:39:48Z

CCPA/Data Deletion Request Handling.md

+
+### Common Platform / Stores identifiers
+
+These identifiers can be used for the "platform" field where applicable. Otherwise, the platform field can include an arbitrary value.


How can platform contain an arbitrary value? If a Vendor is meant to interpret this information to be able to identify a user, this can not be arbitrary.

We've decided to keep it open in order to support additional platforms that aren't listed (knowing that we can't possibly list them all)

@Facens if it's arbitrary it's not usable because this information enables a Vendor script to interpret the other two values. For example: If I'm a Vendor and I receive a "platform" value of "foo-bar-23" and it's not a platform I recognize, what do I do? It won't match any user identifier information I have on record and I can not delete the relevant data.

chrispaterson · 2020-05-22T00:43:17Z

CCPA/Data Deletion Request Handling.md

+Publisher site setup:
+
+```
+<html>


This whole section is WAY too much. There is already a specification that defines how to set up the __usapiLocator frame and stub. There is too much repeated information and it's too easy to get lost in all of this.

lon-pilot-mpf

Looks closer!

lon-pilot-mpf · 2020-05-22T10:26:36Z

CCPA/Data Deletion Request Handling.md

+```
+
+```
+Note: For purposes of this explanation, a "bundle id" is used for (iOS) and a "package" for (Android).


app_identifier I believe @chrispaterson

lon-pilot-mpf · 2020-05-22T10:28:39Z

CCPA/Data Deletion Request Handling.md

+       if(typeof (json) === 'object' && json !== null && '__uspapiCall' in json)
+       {
+        var i = json.__uspapiCall;
+        window.__uspapi(i.command, i.version, function (retValue, success) 


It's already there I think. I may have missed it in my original comment or it may have been added (not honestly sure which). It's on line 229 below.

* Readability / simplification changes * fix typo Co-authored-by: lon-pilot-mpf <36295845+lon-pilot-mpf@users.noreply.github.com> * linting sample code * Adding italics to CCPA Section quote * removing sampleCode.js * fixing italics Co-authored-by: Alex <alextcone@gmail.com> Co-authored-by: lon-pilot-mpf <36295845+lon-pilot-mpf@users.noreply.github.com>

Data Deletion Request Handing spec

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alextcone commented May 12, 2020

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alextcone commented May 12, 2020

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Incorporate counsel's language clarifications

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lon-pilot-mpf reviewed May 13, 2020

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Facens suggested changes May 14, 2020

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alextcone and others added 5 commits May 20, 2020 19:27

Addressing Lon's ask to remove "via a webpage"

a5b7579

Addressing Andrea's request for a minor text update

3af0f7a

address Andrea's wording comment

eaa94a7

apply in-code suggestions from code review

2e510d5

Co-authored-by: lon-pilot-mpf <36295845+lon-pilot-mpf@users.noreply.github.com> Co-authored-by: Andrea Giannangelo <facens@gmail.com>

add Andrea's comments on Lon's updates

ce34562

add reference to new data deletion spec on top level readme

74fdb98

janwinkler suggested changes May 21, 2020

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wrap example script in check for _usapi

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alextcone commented May 21, 2020

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fix closure misplacement in example script

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chrispaterson suggested changes May 22, 2020

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lon-pilot-mpf suggested changes May 22, 2020

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alextcone merged commit 1c85b6d into master May 26, 2020

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Data Deletion Request Handing spec #6

Data Deletion Request Handing spec #6

alextcone commented May 11, 2020

lon-pilot-mpf May 13, 2020

janwinkler May 21, 2020

alextcone May 21, 2020

lon-pilot-mpf May 22, 2020

alextcone commented May 20, 2020

Facens commented May 21, 2020

janwinkler left a comment

alextcone May 21, 2020

lon-pilot-mpf May 22, 2020 •

edited

chrispaterson May 22, 2020 •

edited

chrispaterson May 22, 2020

chrispaterson May 22, 2020

Facens May 22, 2020

chrispaterson May 26, 2020

chrispaterson May 22, 2020

lon-pilot-mpf May 22, 2020

chrispaterson May 22, 2020

Facens May 22, 2020

chrispaterson May 26, 2020 •

edited

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lon-pilot-mpf May 22, 2020

lon-pilot-mpf May 22, 2020

		Publishers working with any services provided by these vendors consume the exposed JavaScript and embed it on their properties where consumers can request deletion of their personal data. If data deletion is requested, all vendor javascript on the publisher property is notified. Vendors then respond by deleting the relevant personal data and signaling any affected vendors downstream.


		### Multiple Services

		The technical solution detailed in this specification provides the means to signal consumer requests for data deletion. Companies supporting the US Privacy Framework (i.e., service providers) will respond to the signals by deleting the consumer's relevant personal data to the extent required by CCPA. The process for deletion depends on the company's technology and operational practices in place. _How_ a vendor deletes a consumer's personal data is out of scope for this specification.


		### Non-web Environments


		When operating in a non-web environment, data deletion requests are handled by sending the user to a web page where they can complete the request to have their data deleted. Vendors need certain information to correctly identify the data to delete: the platform name, the unique app identifier used in the app store, and the device identifier for that platform / store.

		The `performDeletion` command includes a parameter for identifiers. Using the `identifiers` parameter, publishers can pass multiple items, each with the required fields: `platform`, `app_identifier`, and `user_identifier`. These details should be passed from the app context to the delete webpage and then along with the request from the page. Below are a few examples of that information:


		### Common Platform / Stores identifiers

		These identifiers can be used for the "platform" field where applicable. Otherwise, the platform field can include an arbitrary value.

Data Deletion Request Handing spec #6

Data Deletion Request Handing spec #6

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alextcone commented May 11, 2020

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