1. 1 Privacy issues on pan-European White Pages service 4rd TF-LSD Meeting Amsterdam, 29.10.2001 Peter Gietz Peter.gietz@DAASI.de

2. 2 Agenda  Some more texts  P3P  NEEDS solution  Privacy issues of the CIP WPS  Organizational and technical solutions

3. 3 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

4. 4 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 www.cenorm.be/isss/Workshop/dir/Details /dataprot.htm Short and introductory

5. 5 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

6. 6 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

7. 7 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

8. 8 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 protection agencies

9. 9 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

10. 10 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

11. 11 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

12. 12 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

13. 13 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

14. 14 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

15. 15 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?