P3P Implementation Tips : Observations for approaching Design, Build and Deploy PricewaterhouseCoopers Brendon Lynch

2 Assemble your team Your P3P Build and Deploy team needs a combination of skill sets –IT –Privacy –Legal –Marketing –Content Management –and perhaps….. Consultants

3 Understand Your Website Architecture Perform a detailed review of your website to determine: –How reliant is your website on cookies? –What “states” do users have on your site – (e.g. visitor (anon), registrant, transactor?) –Which cookies are associated with these states? How will a users experience be affected if cookies are blocked or denied? Does your website recognize when cookies are blocked? –Are suitable work-around instructions provided

4 Detect and instruct - example

5 Other 3 rd Party Cookies Some companies are missing the true impact, example: (now changed but) served a metric count cookie from –This is a 3P cookie in the IE6 logic and is blocked at medium (default) –Solutions – a suitable Compact Policy or an architecture change to ‘minimal level domain’

6 Determine 3 rd Party Compliance Your third party cookie providers should be P3P compliant by now If not, what effect will this have on your site? –Consider unique metric counts relied upon by analysts Engage in dialog with your 3 rd Party cookie vendors and work with them to implement P3P compact policies

7 Our Tools for Understanding Your Web Architecture WebCPO TM, a complete privacy technology developed by Watchfire and PwC that scans and provides an automated detailed analysis of your website architecture, cookies and IE6 impact. WebCPO TM will scan every link on the website, identifying 3 rd Parties, Cookies, Forms, Security, domains, and other important privacy criteria. –More details can be explained post-workshop

8 IE 6 Cookie Handling Report

9 Know the Spec! The specification is long and cumbersome, it takes a while to digest Simple, one Full P3P (verbose) instance is best, but only IF your architecture permits Use the P3P Generators but beware they are not perfect, you still need to micro-audit, test and pilot the outputs P.S. Do you have the correct version of the spec?

10 Understand Your Existing Narrative Privacy Policy Does your narrative privacy policy adequately disclose all of the elements in the Spec? Are you comfortable that your site conforms to the statement? Does your policy map to the binary disclosures required in Full P3P policy? Check some elements, (e.g. Data Retention) –“Indefinitely” may sound bad, your company does have retention standards, should this be articulated in your narrative policy?

11 Understand Your Existing Narrative Privacy Policy Be Aware - Your current policy may need to be revised after a P3P Policy is created. –Simple items – e.g. entity contact information, phone number –Complex items - Access, Retention, “Multiple”-choice

12 Edit the Full Policy The Policy Building utilities are a good starting point, but are not perfect (e.g. may not output multiple statements) If changes need to be made to the Full Policy, a simple XML editor should be used to make the changes –Avoid using a text editor or word processor to make changes, they will not always work properly

13 Full P3P Matrix Recommended: –Map each Data element by user state, double/triple check, get a second pair of eyes, (then code) –Discuss the mapping with the whole team, check your binary i/o decisions with legal You’d be surprised….

14 Full Policy – Some key areas Disputes: sometimes legislation can also be disclosed, see ATT example Statement: groups together a purpose element, a recipient element, a data group element, and optionally a consequence elements and one or more extensions –NOTE: create a statement per user “state” and also the cookies associated with that state for future proofing, also name your statements using the extension syntax so they view in the Privacy Report

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16 User states – confusing example

17 Validate the Full Policy Use the W3C developed Validator to ensure Full Policy does not have errors – WARNING! – the validator DOES NOT check all logic, (e.g. prior version did not check for opturi [3.2.2] – mandatory if purpose elements have opt-in or opt-out)

18 Test View Privacy Report REMINDER: IE6 uses the Full P3P policy to create the View Privacy Report Check if the Privacy Report displays accurately, (e.g. the seal gifs, did you correctly code name extensions on statements, did you have good descriptions in the Other Purpose and Other Categories?) –If Policy Reference File contains EXCLUDE statements, the Full Policy should not work on those areas of the site - double check the coding and the accuracy of the “*” elements –Recommend testing on a local webserver environment - NOT in live environment

19 Build a Compact Policy The Compact policy must associate the elements of your Full P3P policy that relate to the actual practices of the cookie, it would be normal to have multiple CP’s REMINDER: IE6 only evaluates the Compact Policy

20 Validate the Compact Policy Manual Validation Required Reference P3P Specification for details around tokens Ensure that you have not created unsatisfactory conditions by not specifying opt-in or opt-out criteria –See IE6 guidance on msdn –Be cognizant of Low, Medium and High (e.g. o = unsatisfactory at High setting) –Build site logic to recognize blocked cookies and prompt users to accept

21 Implement & Test IE6 offers two good methods for testing P3P –View Privacy Report Option –Prompt for Cookies Tools / Internet Options / Privacy Advanced, check override Prompt 1P and 3P Once prompted, allow, block, more info displays the full cookie properties including CP served

22 Check All Cookies Make sure you have deployed the right CP on the matching cookie and every cookie! –You’d be surprised…………. IT department should validate the purpose of each cookie, get sign-off prior to launch Again, if possible - deploy on test first

23 Ongoing Monitoring Periodically review your website –Preferably use an automated tool, such a WebCPO TM, to ensure ongoing P3P compliance Ensure that current and future 3P Cookies are P3P compliant New or changes in use of 1P cookies deployed must be revisited Implement automatic manual triggers – human change = machine change