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Review privacy implications #4

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michael-n-cooper opened this issue Jul 13, 2017 · 10 comments
Closed

Review privacy implications #4

michael-n-cooper opened this issue Jul 13, 2017 · 10 comments
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@michael-n-cooper
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IndieUI: User Context was known to introduce privacy risks, which the specification called out. Personalization semantics takes a different approach but should be reviewed for any privacy implications, and address them in the spec.

@clapierre
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clapierre commented Mar 26, 2018

Thaddeus, please use this Checklist to check for Privacy Concerns.
https://www.w3.org/wiki/DocumentReview#TL.3BDR:

We may also want to after we did our own CheckList audit
ask for a privacy review from "Privacy Interest Group"

@clapierre clapierre assigned ghost Mar 26, 2018
@ghost
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ghost commented Apr 16, 2018

Thank you. I will make my response to this issue today.

@ghost
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ghost commented Apr 22, 2018

Two overall concerns here would be data ownership and confidentiality of user data. Because some semantics require user input, who would own that data? In the case of an HTML form the site owner typically owns the data as they are collecting information for a valid business use case and the user is made aware of this ownership through the site owners privacy and other policies. In the personalization use case, data is being used for the benefit of the user vs. a business use case of the site owner. The second concern is confidentiality. Based on the semantics, which as stored openly in the DOM, an untrusted third-party could potentially infer quite a lot of information about a user .

@johnfoliot
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johnfoliot commented Apr 23, 2018 via email

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ghost commented Apr 23, 2018

In the current work yes, all semantics are author-generated, however, my understanding is that future modules would allow for broader customization by users. This would include user defined values, some of which may need to persist across pages or sessions. Is this not correct? Two of the links to the additional modules, "Adaptable Help and Support" and "Adaptable Tools", in the explainer document are broken. I will open an issue for these.

@johnfoliot
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johnfoliot commented Apr 23, 2018 via email

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ghost commented Apr 23, 2018

In some respects we are on the same page here. If a user 'defined' their own value, how would that work - I am not sure how that would work in practice either. I am under the impression that we would be allowing user input or customization in some of the modules, however I could be wrong. If this was the case there could be privacy concerns based on data classification of the user input and these would need to be reviewed, in terms of privacy, on a case-by-case basis.

@ghost
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ghost commented Jun 22, 2018

Privacy review is dependent on multiple factors including intended functionality, user data provided input (where applicable) and implementation. Messages and reminders would most likely require post authentication implementation. Although this may satisfy the need to protect data in transit there may be additional controls for data at rest. There may also be the need for non-technical controls in some cases. For example, opt-in language may be needed if a user shares or submits data, particularly if this data involves PII. I recommend maintaining a working privacy document which looks at the vocabulary on a case by case basis.

@ghost
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ghost commented Aug 26, 2018

Within the context of an incomplete taxonomy where the implementation method has not been determined, risk analysis should be as broad as potentially possible. In terms of user defined values, some of the suggestions in the current draft ask for user input, for example, one suggestion is depended on the contact information of an individual with whom the users is associated with as a property. The task here is not necessarily to demonstrate how the collection of user input would technically work, however, the task is to understand the potential risk and mitigation of collecting such information in the event the task force decides to explore these option further.

https://www.dol.gov/general/ppii

@lseeman lseeman self-assigned this Mar 16, 2020
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lseeman commented Mar 16, 2020

Thank you for your comment. We have done the PING self-review. See #131
Please let us know if there are additional concerns.

@lseeman lseeman closed this as completed Mar 16, 2020
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