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Versions: (draft-iab-privacy-terminology) 00 01 02 03 RFC 6973

Network Working Group                                          A. Cooper
Internet-Draft                                                       CDT
Intended status: Informational                             H. Tschofenig
Expires: April 25, 2012                           Nokia Siemens Networks
                                                                B. Aboba
                                                   Microsoft Corporation
                                                             J. Peterson
                                                           NeuStar, Inc.
                                                               J. Morris
                                                        October 23, 2011


             Privacy Considerations for Internet Protocols
                draft-iab-privacy-considerations-01.txt

Abstract

   This document offers guidance for developing privacy considerations
   for IETF documents and aims to make protocol designers aware of
   privacy-related design choices.

   Discussion of this document is taking place on the IETF Privacy
   Discussion mailing list (see
   https://www.ietf.org/mailman/listinfo/ietf-privacy).

Status of this Memo

   This Internet-Draft is submitted in full conformance with the
   provisions of BCP 78 and BCP 79.

   Internet-Drafts are working documents of the Internet Engineering
   Task Force (IETF).  Note that other groups may also distribute
   working documents as Internet-Drafts.  The list of current Internet-
   Drafts is at http://datatracker.ietf.org/drafts/current/.

   Internet-Drafts are draft documents valid for a maximum of six months
   and may be updated, replaced, or obsoleted by other documents at any
   time.  It is inappropriate to use Internet-Drafts as reference
   material or to cite them other than as "work in progress."

   This Internet-Draft will expire on April 25, 2012.

Copyright Notice

   Copyright (c) 2011 IETF Trust and the persons identified as the
   document authors.  All rights reserved.

   This document is subject to BCP 78 and the IETF Trust's Legal



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   Provisions Relating to IETF Documents
   (http://trustee.ietf.org/license-info) in effect on the date of
   publication of this document.  Please review these documents
   carefully, as they describe your rights and restrictions with respect
   to this document.  Code Components extracted from this document must
   include Simplified BSD License text as described in Section 4.e of
   the Trust Legal Provisions and are provided without warranty as
   described in the Simplified BSD License.


Table of Contents

   1.  Introduction . . . . . . . . . . . . . . . . . . . . . . . . .  3
   2.  Scope  . . . . . . . . . . . . . . . . . . . . . . . . . . . .  4
   3.  Threat Model . . . . . . . . . . . . . . . . . . . . . . . . .  5
   4.  Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . .  7
     4.1.  General  . . . . . . . . . . . . . . . . . . . . . . . . .  7
     4.2.  Data Minimization  . . . . . . . . . . . . . . . . . . . .  7
     4.3.  User Participation . . . . . . . . . . . . . . . . . . . .  8
     4.4.  Security . . . . . . . . . . . . . . . . . . . . . . . . .  9
     4.5.  Accountability . . . . . . . . . . . . . . . . . . . . . .  9
   5.  Example  . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
   6.  Security Considerations  . . . . . . . . . . . . . . . . . . . 11
   7.  IANA Considerations  . . . . . . . . . . . . . . . . . . . . . 12
   8.  Acknowledgements . . . . . . . . . . . . . . . . . . . . . . . 13
   9.  References . . . . . . . . . . . . . . . . . . . . . . . . . . 14
     9.1.  Normative References . . . . . . . . . . . . . . . . . . . 14
     9.2.  Informative References . . . . . . . . . . . . . . . . . . 14
   Authors' Addresses . . . . . . . . . . . . . . . . . . . . . . . . 15






















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1.  Introduction

   All IETF specifications are required by [RFC2223] to contain a
   security considerations section.  [RFC3552] provides detailed
   guidance to protocol designers about both how to consider security as
   part of protocol design and how to inform readers of IETF documents
   about security issues.  This document intends to provide a similar
   set of guidance for considering privacy in protocol design.  Whether
   any individual document will require a specific privacy
   considerations section will depend on the document's content.  The
   guidance provided here can and should be used to assess the privacy
   considerations of protocol and architectural specifications
   regardless of whether those considerations are documented in a stand-
   alone section.

   Privacy is a complicated concept with a rich history that spans many
   disciplines.  Many sets of privacy principles and privacy design
   frameworks have been developed in different forums over the years.
   These include the Fair Information Practices (FIPs) [OECD], a
   baseline set of privacy protections pertaining to the collection and
   use of data about individuals, and the Privacy by Design framework
   [PbD], which provides high-level privacy guidance for systems design.
   The guidance provided in this document is inspired by this prior
   work, but it aims to be more concrete, pointing protocol designers to
   specific engineering choices that can impact the privacy of the
   individuals that make use of Internet protocols.

   Privacy as a legal concept is understood differently in different
   jurisdictions.  The guidance provided in this document is generic and
   can be used to inform the design of any protocol to be used anywhere
   in the world, without reference to specific legal frameworks.

   The document is organized as follows: Section 2 describes the extent
   to which the guidance offered in this document is applicable within
   the IETF, Section 3 discusses a generic threat model to motivate the
   need for privacy considerations, Section 4 provides the guidelines
   for analyzing and documenting privacy considerations within IETF
   specifications, and Section 5 examines the privacy characteristics of
   an IETF protocol to demonstrate the use of the guidance framework.












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2.  Scope

   The core function of IETF activity is building protocols.  Internet
   protocols are often built flexibly, making them useful in a variety
   of architectures, contexts, and deployment scenarios without
   requiring significant interdependency between disparately designed
   components.  Although some protocols assume particular architectures
   at design time, it is not uncommon for architectural frameworks to
   develop later, after implementations exist and have been deployed in
   combination with other protocols or components to form complete
   systems.

   As a consequence, the extent to which protocol designers can foresee
   all of the privacy implications of a particular protocol at design
   time is significantly limited.  An individual protocol may be
   relatively benign on its own, but when deployed within a larger
   system or used in a way not envisioned at design time, its use may
   create new privacy risks.  The guidelines in Section 4 ask protocol
   designers to consider how their protocols are expected to interact
   with systems and information that exist outside the protocol bounds,
   but not to imagine every possible deployment scenario.

   Furthermore, in many cases the privacy properties of a system are
   dependent upon API specifics, internal application functionality,
   database structure, local policy, and other details that are specific
   to particular instantiations and generally outside the scope of the
   work conducted in the IETF.  The guidance provided here only reaches
   as far as protocol design can go.

   As an example, consider HTTP [RFC2616], which was designed to allow
   the exchange of arbitrary data.  A complete analysis of the privacy
   considerations for uses of HTTP might include what type of data is
   exchanged, how this data is stored, and how it is processed.  Hence
   the analysis for an individual's static personal web page would be
   different than the use of HTTP for exchanging health records.  A
   protocol designer working on HTTP extensions (such as WebDAV
   [RFC4918]) is not expected to describe the privacy risks derived from
   all possible usage scenarios, but rather the privacy properties
   specific to the extensions and any particular uses of the extensions
   that are expected and foreseen at design time.











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3.  Threat Model

   To consider privacy in protocol design it is helpful to consider the
   overall communication architecture and different actors' roles within
   it.  This analysis is similar to a threat analysis found in the
   security considerations sections of IETF documents.  Figure 1
   presents a communication model found in many of today's protocols
   where a sender wants to establish communication with some recipient
   and thereby uses some form of intermediary.  In some cases this
   intermediary stays in the communication path for the entire duration
   of the communication and sometimes it is only used for communication
   establishment, for either inbound or outbound communication.  In rare
   cases there may be a series of intermediaries that are traversed.


                                             +-----------+
                                             |           |
                                            >| Recipient |
                                           / |           |
                                         ,'  +-----------+
   +--------+        )--------------(  ,'    +-----------+
   |        |        |              | -      |           |
   | Sender |<------>|Intermediary  |<------>| Recipient |
   |        |        |              |`.      |           |
   +--------+        )--------------(  \     +-----------+
       ^                                `.   +-----------+
       :                                  \  |           |
       :                                   `>| Recipient |
       .....................................>|           |
                                             +-----------+

   Legend:

   <....> End-to-End Communication
   <----> Hop-by-Hop Communication

         Figure 1: Example Instantiation of Architectural Entities

   This model is vulnerable to three types of adversaries:

   Eavesdropper:  [RFC4949] describes the act of 'eavesdropping' as

         "Passive wiretapping done secretly, i.e., without the knowledge
         of the originator or the intended recipients of the
         communication."

      Eavesdropping is often considered by IETF protocols in the context
      of a security analysis.  Confidentiality protection is often



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      employed to defend against attacks based on eavesdropping, and
      [RFC3552] demands that confidentiality be incorporated as a
      security consideration.  While IETF protocols offer guidance on
      how to secure communication against eavesdroppers, deployments
      sometimes choose not to enable such security.

   Intermediary:  Many protocols developed today show a more complex
      communication pattern than simple client-server or peer-to-peer
      communication, as motivated in Figure 1.  Store-and-forward
      protocols are examples where entities participate in the message
      delivery even though they are not the final recipients.  Often,
      these intermediaries only require a small amount of information
      for message routing and/or security.  In theory, protocol
      mechanisms could ensure that end-to-end information is not made
      accessible to these entities, but in practice the difficulty of
      deploying end-to-end security procedures, additional messaging or
      computational overhead, and other business or legal requirements
      often slow or prevent the deployment of end-to-end security
      mechanisms, giving intermediaries greater exposure to
      communication patterns and payloads than is strictly necessary.

   Recipient:  It may not seem intuitive to treat the recipient as an
      adversary since the entire purpose of the communication
      interaction is to provide information to the recipient.  However,
      the recipient can act as the sender's privacy foe in two respects.
      First, the sender may be unintentionally communicating with the
      recipient, whether because of a lack of access control or because
      the sender was not properly informed about what data it would be
      communicating to the recipient.  Second, the recipient may choose
      to use the sender's data in ways that contravene the sender's
      wishes, whether by putting it to some purpose that the sender
      opposes, sharing it with other entities, or storing it after the
      communication session has ended.  Whether the recipient becomes an
      adversary depends on whether it makes use of mechanisms that
      reduce these risks, including informing the sender about how his
      or her data will be used, offering choices, and obtaining
      authorization to receive and use the sender's data.














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4.  Guidelines

   This section provides guidance for document authors in the form of a
   questionnaire about a protocol being designed.  The questionnaire may
   be useful at any point in the design process, particularly after
   document authors have developed a high-level protocol model as
   described in [RFC4101].

   Note that the guidance does not recommend specific practices.  The
   range of protocols developed in the IETF is too broad to make
   recommendations about particular uses of data or how privacy might be
   balanced against other design goals.  However, by carefully
   considering the answers to each question, document authors should be
   able to produce a comprehensive analysis that can serve as the basis
   for discussion of whether the protocol adequately protects against
   privacy threats.

   The framework is divided into four sections that address different
   aspects of privacy -- data minimization, user participation,
   security, and accountability -- plus a general section.  Security is
   not elaborated since substantial guidance already exists in
   [RFC3552].  Privacy-specific terminology used in the framework is
   [will be] defined in [I-D.hansen-privacy-terminology].

4.1.  General

      a.  Trade-offs.  Does the protocol make trade-offs between privacy
      and usability, privacy and efficiency, privacy and
      implementability, or privacy and other design goals?  Describe the
      trade-offs and the rationale for the design chosen.

4.2.  Data Minimization

      a.  Identifiers.  What identifiers does the protocol use for
      distinguishing endpoints?  Does the protocol use identifiers that
      allow different protocol interactions to be correlated?

      b.  User information.  What information does the protocol expose
      about end users and/or their devices (other than the identifiers
      discussed in (a))?  How identifiable is this information?  How
      does the protocol combine user information with the identifiers
      discussed in (a)?

      c.  Fingerprinting.  In many cases the specific ordering and/or
      occurrences of information elements in a protocol allow devices
      using the protocol to be uniquely fingerprinted.  Is this protocol
      vulnerable to fingerprinting?  If so, how?




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      d.  Persistence of identifiers.  What assumptions are made in the
      protocol design about the lifetime of the identifiers discussed in
      (a)?  Does the protocol allow implementers or users to delete or
      recycle identifiers?  How often does the specification recommend
      to delete or recycle identifiers by default?

      e.  Leakage.  Are there expected ways that information exposed by
      the protocol will be combined or correlated with information
      obtained outside the protocol?  How will such combination or
      correlation facilitate user or device fingerprinting?  Are there
      expected combinations or correlations with outside data that will
      make the information exposed by the protocol more identifiable?

      f.  Recipients.  In the protocol design, what information
      discussed in (a) and (b) is exposed to other endpoints (i.e.,
      recipients)?  Are there ways for protocol implementers to choose
      to limit the information shared with other endpoints?

      g.  Intermediaries.  In the protocol design, what information
      discussed in (a) and (b) is exposed to intermediaries?  Are there
      ways for protocol implementers to choose to limit the information
      shared with intermediaries?

      h.  Retention.  Do the protocol or its anticipated uses require
      that the information discussed in (a) or (b) be retained by
      recipients or intermediaries?  Is the retention expected to be
      persistent or temporary?

4.3.  User Participation

      a.  Control over initial sharing.  What user controls or consent
      mechanisms does the protocol define or require before user
      information or identifiers are shared or exposed via the protocol?
      If no such mechanisms are specified, is it expected that control
      and consent will be handled outside of the protocol?

      b.  Control over sharing with recipients.  Does the protocol
      provide ways for users to limit which information is shared with
      recipients?  If not, are there mechanisms that exist outside of
      the protocol to provide users with such control?

      c.  Control over sharing with intermediaries.  Does the protocol
      provide ways for users to limit which information is shared with
      intermediaries?  If not, are there mechanisms that exist outside
      of the protocol to provide users with such control?  Is it
      expected that users will have relationships (contractual or
      otherwise) with intermediaries that govern the use of the
      information?



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      d.  Preference expression.  Does the protocol provide ways for
      users to express their preferences to recipients or intermediaries
      with regard to the use or disclosure of their information?

4.4.  Security

      a.  Communication security.  Do the protocol's security
      considerations account for communication security, per RFC 3552?

4.5.  Accountability

      a.  User verification.  If the protocol provides for user
      preference expression, does it also define or require mechanisms
      that allow users to verify that their preferences are being
      honored?  If not, are there mechanisms that exist outside of the
      protocol that allow for user verification?



































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5.  Example

   [To be provided in a future version.]
















































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6.  Security Considerations

   This document describes privacy aspects that protocol designers
   should consider in addition to regular security analysis.















































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7.  IANA Considerations

   This document does not require actions by IANA.
















































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8.  Acknowledgements

   We would like to thank the participants for the feedback they
   provided during the December 2010 Internet Privacy workshop co-
   organized by MIT, ISOC, W3C and the IAB.














































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9.  References

9.1.  Normative References

   [I-D.hansen-privacy-terminology]
              Hansen, M. and H. Tschofenig, "Terminology for Talking
              about Privacy by Data Minimization: Anonymity,
              Unlinkability, Undetectability, Unobservability,
              Pseudonymity, and Identity Management",
              draft-hansen-privacy-terminology-02 (work in progress),
              March 2011.

9.2.  Informative References

   [OECD]     Organization for Economic Co-operation and Development,
              "OECD Guidelines on the Protection of Privacy and
              Transborder Flows of Personal Data", available at
              (September 2010) , http://www.oecd.org/EN/document/
              0,,EN-document-0-nodirectorate-no-24-10255-0,00.html,
              1980.

   [PbD]      Office of the Information and Privacy Commissioner,
              Ontario, Canada, "Privacy by Design", 2011.

   [RFC2223]  Postel, J. and J. Reynolds, "Instructions to RFC Authors",
              RFC 2223, October 1997.

   [RFC2616]  Fielding, R., Gettys, J., Mogul, J., Frystyk, H.,
              Masinter, L., Leach, P., and T. Berners-Lee, "Hypertext
              Transfer Protocol -- HTTP/1.1", RFC 2616, June 1999.

   [RFC3552]  Rescorla, E. and B. Korver, "Guidelines for Writing RFC
              Text on Security Considerations", BCP 72, RFC 3552,
              July 2003.

   [RFC4101]  Rescorla, E. and IAB, "Writing Protocol Models", RFC 4101,
              June 2005.

   [RFC4918]  Dusseault, L., "HTTP Extensions for Web Distributed
              Authoring and Versioning (WebDAV)", RFC 4918, June 2007.

   [RFC4949]  Shirey, R., "Internet Security Glossary, Version 2",
              RFC 4949, August 2007.

   [browser-fingerprinting]
              Eckersley, P., "How Unique Is Your Browser?", Springer
              Lecture Notes in Computer Science , Privacy Enhancing
              Technologies Symposium (PETS 2010), 2010.



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Authors' Addresses

   Alissa Cooper
   CDT
   1634 Eye St. NW, Suite 1100
   Washington, DC  20006
   US

   Phone: +1-202-637-9800
   Email: acooper@cdt.org
   URI:   http://www.cdt.org/


   Hannes Tschofenig
   Nokia Siemens Networks
   Linnoitustie 6
   Espoo  02600
   Finland

   Phone: +358 (50) 4871445
   Email: Hannes.Tschofenig@gmx.net
   URI:   http://www.tschofenig.priv.at


   Bernard Aboba
   Microsoft Corporation
   One Microsoft Way
   Redmond, WA  98052
   US

   Email: bernarda@microsoft.com


   Jon Peterson
   NeuStar, Inc.
   1800 Sutter St Suite 570
   Concord, CA  94520
   US

   Email: jon.peterson@neustar.biz


   John B. Morris, Jr.

   Email: ietf@jmorris.org






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