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Privacy issues on pan-European White Pages

service

4rd TF-LSD Meeting Amsterdam, 29.10.2001

Peter Gietz

Peter.gietz@DAASI.de

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Agenda Some more texts P3P NEEDS solution Privacy issues of the CIP WPS Organizational and technical

solutions

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New valuable texts Commission of the European

Communities: Proposal for a Directive of the European Parliament and the Council concerning the processing of personal data and the protection of prvacy in the electronic communications sector, Brussels, 12.7.2000, COM(2000) 385 final, 2000/0189 (COD)• Changes to Directive 97/66/EC to enlargen the scope

from telephone to general data traffic

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Other texts Data protection in the European

Union• Introductory text that discusses the matter for

the user Directory Workshop: Data Privacy

Protection, 4.4.2001, ISSS/WS-DIR, www.cenorm.be/isss/Workshop/dir/Details/dataprot.htm• Short and introductory

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P3P a new standard The Platform for Privacy

Preferences 1.0. (P3P1.0) Specification, W3C Working Draft 28. September 2001• Concerns privacy of information supplied to

Web sites• RDF/XML descriptions of privacy policies that

can be automatically processed in HTTP client server communication

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P3P vocabulary excerpt

Data categories, e.g.:• Physical contact information• Online contact information• Computer information

Consequences• Human readable description of the results of agreeing to

a proposal Purpose• Purposes for collecting data

Recipients• Who else than the service provider

gets access to the data

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P3P and Directories When using Webgateways with

possibilities to add or modify data P3P usage is obvious

Data structures could be used:• To store privacy statements of directory services• to store user privacy preferences

More research is needed

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Who else is working on this?

Walter M. Tveter, University of Oslo: Privacy aspects of the NEEDS project• Educational institutions (EIs) are owner and

controller and thus responsible• NRNs are processors and service provider on

their behalf• EIs grant rights to NRNs via contract• NRNs grant rights to other NRNs via contract• EIs have all contacts to subjects

and national data protectionagencies

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Privacy Issues Controller and processor are the

maintainers of the actual data server

Do the maintainer of the index service have the same legal bindings to the data subject?

If not all data subjects have consented to transmission to unadequate legislation countries, transmission to those countries has to be prevented

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Organizational Solutions

• Define and stick to purpose of service• Call for a data protection officer• Define who is the controller and who is processor• Define and restrict population of data subjects• Define procedures how the data are gathered

and processed• Inform data subjects about e.g. via email:• Who collected data • What data • For what purpose• About the rights of the data subject

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Organizational Solut. contd.

• Define procedure of informing the data subjects about rights and data updates

• Define how data subjects can make use of their rights (e.g. via signed e-mail, Web-Formular)

• Better have user consent when he applies for a user account

• Only collect minimum set of data attributes

• Publish and disseminate all organizational definitions in a policy text

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Technical Solutions• Establish adequate security against loss, damage

and unlawful access or manipulation of the data• Restrict maximum number of retrievable entries• Disallow wildcards• Restrict number of searchable attributes• Do robots detection and refuse services to them

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Issue of export to third countries:

Either:• Restrict access to user from countries with

adequate privacy legislation• Disallow access from proxies

Or:• Let the subject decide to be visable• Only in it‘s own institution

• Only within the own country (???)

• Only within the EU

• World wide

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Technical Solut. contd.

• Encrypt Indexobjects while on the net• Define Crawler policies• Only let registered crawlers access the data• Enforce digital signatures for e-Mail-consent of

the data subjects

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How to proceed? We should restrict ourselfes to

EC-Direcives But not quote a lot of it

A template privacy policy text should be included

A template privacy policy P3P definition should be included?

Contact Working Party?