NOTE-IPWG-Practices-971017

Internet Privacy Working Group Privacy
Practices for the Web

Submitted to W3C on 17 October 1997 ·

Latest version:

http://www.w3.org/TR/NOTE-IPWG-Practices

This version:

http://www.w3.org/TR/NOTE-IPWG-Practices-971017

Authors:

Internet Privacy Working Group

Editor:

Deirdre Mulligan, CDT

Status of this Document

This document is a NOTE made available by the World Wide Web Consortium for discussion only. This indicates no endorsement of its content, nor that the Consortium has, is, or will be allocating any resources to the issues addressed by the NOTE. A list of current NOTEs can be found at: http://www.w3.org/TR/.

This document is part of a complete submission to the W3C. The full submission has been acknowledged by W3C and is available at http://www.w3.org/Submission/1997/17/. 

Note: since working drafts are subject to frequent change, you are advised to reference the above URL, rather than the URLs for working drafts themselves.

Document Version 1.0
October 17, 1997

Introduction

This document is intended for consideration by the Platform for Privacy Preferences Project. The vocabularies specified (Data Categories, Data Practices, Release, and Access, Contact) are offered for considerations as vocabularies that would fit within the P3P grammar. We also make some ancillary recommendations regarding identification of the "entity" with whom the individual is dealing and the "space" within which a P3P agreement applies.

For a further explanation of what P3P architecture, grammar, and vocabularies please see:

• P3P Grammatical Model and Data Design Model Working Draft
• General Overview of the P3P Architectur Working Draft
• W3C P3P Overview.

Data Categories

A data category is a quality of a data element or class that may be used by a trust engine to determine what type of element is under discussion (for example anonymous demographics or personal contact information). The first seven data categories are actually data elements within the data category Contact Information but are considered to be important enough to be their own category. The inclusion of a category or data element (as a bullet or example) in no way requires a user to enter that information. For instance, while we state SSN is an example of a Government or Unique Identifier the exchange of this type off data is extremely sensitive and may even be unlawful. We are not recommending that these data elements should be collected or transferred, they are merely examples for a category or type of information one may make privacy practice statements about.

First name

this would include nick-names

Last name

Middle name

Maiden name

Address

Phone number

Other physical contact information

other information that is commonly used to identify, locate and/or contact a person.

Cyberspace Contact Information

information that allows an individual to be contacted or located on the Internet.

• email address
• site specific email address
• URL

Government ids and unique identifiers

identifiers issued by a government or other entity for purposes of consistently identifying the individual -- for example SSN, pseudonyms, account numbers.

Financial account identifiers

identifiers that tie an individual to a financial instrument, account, or payment system -- for example Visa or American Express account number, or bank account number.

Computer Information

• non-identifying information about the individual's computer system.
• visitor's computer type
• operating system

• browser

Navigational and Click-stream Data

data generated by the individuals activities at a Web site or other experience space, such as the pages of a web site viewed, the links made, the time spent in particular areas.

Transactional data

data that reflects transactions such as logs of phone calls, emails or purchases.

Preference and Demographic Data

non-identifiable data collected from the individual or other source -- not click-stream data -- for example gender, age, and clothes size. There are elements that fall in this category -- such as race, nationality, ethnicity, religion, income -- that raise additional issues.

Content

the words and expressions contained in the body of a communication including the text of email, bulletin board postings, chat room communications.

Practices Defined

A practice is a P3P clause that describes what a service plans to do with data. We specify four types of practices: use, transfer, release, and access.

USE means the handling of information by the entity who received it directly from the subject of the information. The use of information by agents who represent or act for the entity under the relation of agency also is considered use.

• System administration the use of information solely to support the operation of the computer system
• Research and/or product development the use of information to enhance, evaluate, or otherwise review the site, a product, or a market. The use of information to improve the content of a site would fall under this definition, but the use of personal information to tailor or modify the content to the specific individual would not. This definition does not include the use of information to evaluate, target, profile or contact the individual.
• Completion and support of current transaction the use of information to complete the activity for which it was provided -- for example place an order, ship an order, recall a faulty product.
• customization of content and/or design of site the use of information to tailor or modify the site to the particular individual.
• contacting visitors for marketing of services or products the use of information to contact the individual to promote a product or service. This includes notifying visitors about updates to the web site.
• in identifiable form for contacting visitors for marketing of services and/or products, and opt-out is provided (definition. of opt-out -- the individual is given conspicuous notice of the intent to disclose and the ability to limit the disclosure of personal information through an online feature at or before the time at which such information is requested.)
• linking with identifiable information combining non-identifiable information with personally identifiable information.
• other uses uses of information not captured by the above definitions and not involving disclosure.

TRANSFER means to transfer, provide access to, or otherwise divulge information to another entity that is legally related to the entity with whom the individual is interacting and is bound by the same information practices. the sharing of information between "affiliates" or "subsidiaries" is considered a transfer.

• in identifiable form for research and/or product development
• in identifiable form for customization and/or improvement of content and/or design of site
• in identifiable form for contacting visitors for marketing of services and/or products
• in identifiable form for contacting visitors for marketing of services and/or products, and opt-out is provided (definition. of opt-out -- the individual is given conspicuous notice of the intent to disclose and the ability to limit the disclosure of personal information through an online feature at or before the time at which such information is requested.)

RELEASE means to release, provide access to, or otherwise divulge information to one or more unrelated third-parties. exchanges of information between two separate corporations is a disclosure.

• in identifiable form for customization and/or improvement of content and/or design of site
• in identifiable form for contacting visitors for marketing of services and/or products
• in identifiable form for contacting visitors for marketing of services and/or products, and opt-out is provided (Definition. of Opt-out -- the individual is given conspicuous notice of the intent to disclose and the ability to limit the disclosure of personal information through an online feature at or before the time at which such information is requested.)
• in identifiable form to others for other purposes
• in non-identifiable form

ACCESS the ability of the individual who is the subject of the information to view, and/or correct it.

• view the ability of the individual who is the subject of the information to inspect and copy it.
• correct the ability of the individual who is the subject of the information to amend, delete, and/or retract it.

(this field would also have a space for a pointer to a Web page or some text giving more information)

Ancillary Recommendations

We believe that within P3P statements a field for each of the following should exist:

CONTACT site should provide relevant contact information including company or individual name, contact person, phone number, address, email.

AGREEMENT WITH site should indicate the entity with whom the individual is interacting (representation should be consistent with consumers perception).