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IntArea Working Group                                    A. Andersdotter
Internet-Draft                                                ARTICLE 19
Intended status: Informational                            April 22, 2018
Expires: October 24, 2018


  An update to RFC6302 on Logging Recommendations for Internet-Facing
                                Servers
            draft-andersdotter-intarea-update-to-rfc6302-00

Abstract

   This draft seeks to update RFC6302 on Logging Recommendations for
   Internet-Facing Servers.  The new recommendations aim to be a best
   practice for service providers and server maintainers, by following
   recommendations outlined in RFC6973 and taking into account new
   regulatory requirements in the privacy area.

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
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   This Internet-Draft will expire on October 24, 2018.

Copyright Notice

   Copyright (c) 2018 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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   include Simplified BSD License text as described in Section 4.e of




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   the Trust Legal Provisions and are provided without warranty as
   described in the Simplified BSD License.

Table of Contents

   1.  Introduction  . . . . . . . . . . . . . . . . . . . . . . . .   2
   2.  Terminology . . . . . . . . . . . . . . . . . . . . . . . . .   3
   3.  Recommendations for Internet-facing servers . . . . . . . . .   3
     3.1.  Data minimization . . . . . . . . . . . . . . . . . . . .   4
     3.2.  User involvement  . . . . . . . . . . . . . . . . . . . .   4
     3.3.  Security  . . . . . . . . . . . . . . . . . . . . . . . .   5
   4.  Considerations for electronic communications providers  . . .   5
   5.  Security considerations . . . . . . . . . . . . . . . . . . .   5
   6.  Acknowledgments . . . . . . . . . . . . . . . . . . . . . . .   5
   7.  References  . . . . . . . . . . . . . . . . . . . . . . . . .   6
     7.1.  Normative References  . . . . . . . . . . . . . . . . . .   6
     7.2.  Informative References  . . . . . . . . . . . . . . . . .   6
   Author's Address  . . . . . . . . . . . . . . . . . . . . . . . .   7

1.  Introduction

   In 2013, the IETF adopted [RFC6973] Privacy Guidelines for Internet
   protocols to ensure robust procedures for evaluating existing
   protocols and standards with respect to privacy, and insert
   protective mechanisms for privacy in future protocol and standards
   work.  In the past couple of years, new data privacy regulations with
   wide geographical scope are entering into effect with big effects for
   technology companies and technology consumers around the world.  The
   combination of these changes, in IETF procedure and regulatory
   requirements, have caused some previously established best practices
   to become poor practices.

   This draft proposes updates to specifically [RFC6302] on Logging
   Recommendations for Internet-Facing Servers with a view for it to
   serve as a useful reference for operators seeking to be compliant
   with modern regulatory requirements for the protection of end-users,
   e.g.  [GDPR].

   Earlier recommendations contained in [RFC6302] relied heavily on
   observations made in Section 12 of [RFC6269] that regulatory
   requirements could imply a broad obligation to log identifiers.  At
   the time of the adoption of [RFC6302], it was known that European
   Union law mandated data retention and trace-ability of each and every
   telecommunications subscriber in the European Union.  The regulatory
   landscape in Europe has since changed, for instance in the European
   Union through [C20315], and in the broader Council of Europe area
   through [Zakharov] and [SzaboVissy].  It is possible that [RFC6269]




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   should be revisited in light of these developments, but such work is
   outside the scope of this text.

   The below text is intended to replace Section 1 in [RFC6302].

   Service providers, in so far as they are a collection of individual
   persons, and subscribers, and the transactional relationships of
   these individuals with the service provision, all give rise to
   personal data.  In [RFC6973] it is specified that data minimization
   and security are important mitigation strategies against privacy
   threats.  Further, regulatory requirements place an obligation on
   protocol designers and operators of servers to implement privacy-by-
   design and data minimization techniques.

   [RFC6973] as well as new regulatory requirements have been put in
   place to protect the privacy of internet users.  They are in the vein
   of previous IETF work on pervasive monitoring as a security risk in
   and of itself [RFC7258], and have parallels in new developments in
   international human rights law, see e.g.  [UNGA2013].

2.  Terminology

   This section is intended to be introduced in [RFC6302] as a separate
   terminology section, replacing the first paragraph of Section 2 of
   [RFC6302].

   The key words *MUST*, *MUST NOT*, *REQUIRED*, *SHALL*, *SHALL NOT*,
   *SHOULD*, *SHOULD NOT*, *RECOMMENDED*, *MAY* and *OPTIONAL* in this
   document as to be interpreted as described in [RFC2119].

   This document adheres to the privacy terminology established in
   [RFC6973].

3.  Recommendations for Internet-facing servers

   This section is intended to replace Section 2 of [RFC6302].

   Providers of internet-facing servers

      SHOULD only store entire incoming IP addresses for as long as is
      necessary to provide the specific service requested by the user.

      SHOULD keep only the first two octets (of an IPv4 address) or the
      first three octets (of an IPv6 address) with remaining octets set
      to zero, when logging.

      SHOULD NOT store logs of incoming IP addresses from inbound
      traffic for longer than three days.



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      SHOULD NOT log unnecessary identifiers, such as source port
      number, time stamps, transport protocol numbers or destination
      port numbers.

      SHOULD ensure adequate log access control, with suitable
      mechanisms for keeping track of which entity accesses logged
      identifiers, for what reason and at what time.

   It is RECOMMENDED that deviations from the above practices are
   carefully documented and communicated to subscribers.

3.1.  Data minimization

   Data minimization is proposed by Section 6.1 in [RFC6973] as an
   effective way of ensuring privacy protections.  A data minimization
   principle is further a regulatory requirement in some parts of the
   world (e.g.  [GDPR]).

   Data minimization can be effectuated in a number of different ways,
   including by limiting collection, retention and identifiability to
   personal data.  The recommendation to anonymize IP addresses intended
   for logging, the recommendation not to store logs for longer than a
   limited amount of time, and the recommendation not to log unnecessary
   identifiers are intended to advance such effectuations of data
   minimization.

   A three-day logging period covers a week-end, which is convenient for
   professional server providers.  It also accounts for the ability of
   content providers to geolocate subscribers for the duration of their
   content consumption, in those cases where this is necessary due to
   legal restrictions.

3.2.  User involvement

   In Section 6.2 of [RFC6973] it is established involving individuals
   in decisions about data collection and treatment of data is a way of
   mitigating privacy threats.  The section proposes that individuals be
   informed, and that they are provided ways to signal their
   preferences, and make choices, about collection and sharing of data.

   Identifiers about subscribers can be logged at an internet-facing
   server to enable provision of content that is geoblocked, but are
   only required for as long as the service is requested by the user.
   In these circumstances, data which is logged for longer than the time
   it takes to deliver the service should be subject to careful
   considerations and the subscriber should be informed thereof.





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   Similarly, there exists no duty of subscribers to assist internet-
   facing servers in their efforts to improve services or the Internet.
   Where IP addresses or identifiers about individuals are logged with a
   view to improving services or the Internet, and having no other
   technical justification, individuals should be given a way to signal
   preferences and make choices about such logging.

3.3.  Security

   Security is advanced by Section 6.3 of [RFC6973] as an effective way
   to mitigate privacy threats.  Among the important security goals
   mentioned are confidentiality, unauthorized usage and inappropriate
   usage.  The recommendation to have adequate access control is
   intended to ensure security in the handling of such logs that are
   kept even after the data minimization strategies are deployed.

4.  Considerations for electronic communications providers

   This section is intended to replace Section 3 of [RFC6302].

   The new regulatory requirements referenced earlier in this document
   imply that electronic communications providers may also have to
   review their logging practices.  It is advisable that they should do
   so, bearing in mind [RFC6973].  However, the details are outside the
   scope of this document.

5.  Security considerations

   This draft gives recommendations for logging at internet-facing
   servers.  It is intended to protect internet users from the threats
   of pervasive monitoring [RFC7258] and to assist operators of
   internet-facing servers in adhering to regulatory requirements.

   Operators seeking to deviate from the base-level of privacy and
   security assumed for internet users, should make time-limited,
   specific exceptions which have clearly stated and lawful aims.
   Deviations could for instance be included in employment contracts or
   consumer contracts that are tied to non-public services which are
   nevertheless provided through Internet-facing servers and which
   require authentication for access.

6.  Acknowledgments

   The author would like to thank Mallory Knodel, Linus Nordberg and
   Anders Jensen-Urstad for their comments during the drafting of this
   document.





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7.  References

7.1.  Normative References

   [RFC2119]  Bradner, S., "Key words for use in RFCs to Indicate
              Requirement Levels", RFC 2119, DOI 10.17487/RFC2119, March
              1997, <https://www.rfc-editor.org/info/rfc2119>.

7.2.  Informative References

   [C20315]   Court of Justice of the European Union,
              "ECLI:EU:C:2016:970, Judgment of the Court (Grand Chamber)
              of 21 December 2016, Tele2 Sverige AB v Post- och
              telestyrelsen and Secretary of State for the Home
              Department v Tom Watson and Others", December 2016,
              <http://curia.europa.eu/juris/liste.jsf?num=C-203/15>.

   [GDPR]     European Union, "Regulation (EU) 2016/679 (General Data
              Protection Regulation)", May 2016,
              <http://data.europa.eu/eli/reg/2016/679/oj>.

   [RFC6269]  Ford, M., Boucadair, M., Durand, A., Levis, P., and P.
              Roberts, "Issues with IP Address Sharing", RFC 6269,
              DOI 10.17487/RFC6269, June 2011,
              <https://www.rfc-editor.org/info/rfc6269>.

   [RFC6302]  Durand, A., Gashinsky, I., Lee, D., and S. Sheppard,
              "Logging Recommendations for Internet-Facing Servers",
              RFC 6302, DOI 10.17487/RFC6302, June 2011,
              <https://www.rfc-editor.org/info/rfc6302>.

   [RFC6973]  Cooper, A., Tschofenig, H., Aboba, B., Petersen, J.,
              Morris, J., Hansen, M., and R. Smith, "Privacy
              Considerations for Internet Protocols", RFC 6973,
              DOI 10.17487/RFC6973, July 2013,
              <https://www.rfc-editor.org/info/rfc6973>.

   [RFC7258]  Farrell, S. and H. Tschofenig, "Pervasive Monitoring Is an
              Attack", RFC 7258, DOI 10.17487/RFC7258, May 2017,
              <https://www.rfc-editor.org/info/rfc7258>.

   [SzaboVissy]
              European Court of Human Rights, "Case of Szabo and Vissy
              v. Hungary, Application no. 37138/14, ECHR 2016", January
              2016, <http://hudoc.echr.coe.int/eng?i=001-160020>.






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   [UNGA2013]
              United Nations General Assembly, ""The right to privacy in
              the digital age" (A/C.3/68/L.45)", 2013,
              <http://daccess-ods.un.org/TMP/1133732.05065727.html>.

   [Zakharov]
              European Court of Human Rights, "Case of Zakharov v.
              Russia, Application no. 47143/06, ECHR 2015.", December
              2015, <http://hudoc.echr.coe.int/eng?i=001-159324>.

Author's Address

   Amelia Andersdotter
   ARTICLE 19
   Free Word Centre, 60 Farringdon Road
   London EC1R 3GA
   United Kingdom

   Email: amelia@article19.org
































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