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INFORMATIONAL
Internet Architecture Board (IAB)                              A. CooperRequest for Comments: 6973                                           CDTCategory: Informational                                    H. TschofenigISSN: 2070-1721                                   Nokia Siemens Networks                                                                B. Aboba                                                                   Skype                                                             J. Peterson                                                           NeuStar, Inc.                                                               J. Morris                                                               M. Hansen                                                                     ULD                                                                R. Smith                                                                   Janet                                                               July 2013Privacy Considerations for Internet ProtocolsAbstract   This document offers guidance for developing privacy considerations   for inclusion in protocol specifications.  It aims to make designers,   implementers, and users of Internet protocols aware of privacy-   related design choices.  It suggests that whether any individual RFC   warrants a specific privacy considerations section will depend on the   document's content.Status of This Memo   This document is not an Internet Standards Track specification; it is   published for informational purposes.   This document is a product of the Internet Architecture Board (IAB)   and represents information that the IAB has deemed valuable to   provide for permanent record.  It represents the consensus of the   Internet Architecture Board (IAB).  Documents approved for   publication by the IAB are not a candidate for any level of Internet   Standard; seeSection 2 of RFC 5741.   Information about the current status of this document, any errata,   and how to provide feedback on it may be obtained athttp://www.rfc-editor.org/info/rfc6973.Cooper, et al.                Informational                     [Page 1]

RFC 6973                 Privacy Considerations                July 2013Copyright Notice   Copyright (c) 2013 IETF Trust and the persons identified as the   document authors.  All rights reserved.  This document is subject toBCP 78 and the IETF Trust's Legal 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.Cooper, et al.                Informational                     [Page 2]

RFC 6973                 Privacy Considerations                July 2013Table of Contents1. Introduction ....................................................42. Scope of Privacy Implications of Internet Protocols .............53. Terminology .....................................................63.1. Entities ...................................................73.2. Data and Analysis ..........................................83.3. Identifiability ............................................94. Communications Model ...........................................105. Privacy Threats ................................................125.1. Combined Security-Privacy Threats .........................135.1.1. Surveillance .......................................135.1.2. Stored Data Compromise .............................145.1.3. Intrusion ..........................................145.1.4. Misattribution .....................................145.2. Privacy-Specific Threats ..................................155.2.1. Correlation ........................................155.2.2. Identification .....................................165.2.3. Secondary Use ......................................165.2.4. Disclosure .........................................175.2.5. Exclusion ..........................................176. Threat Mitigations .............................................186.1. Data Minimization .........................................186.1.1. Anonymity ..........................................196.1.2. Pseudonymity .......................................206.1.3. Identity Confidentiality ...........................206.1.4. Data Minimization within Identity Management .......216.2. User Participation ........................................216.3. Security ..................................................227. Guidelines .....................................................237.1. Data Minimization .........................................247.2. User Participation ........................................257.3. Security ..................................................257.4. General ...................................................268. Example ........................................................269. Security Considerations ........................................3110. Acknowledgements ..............................................3111. IAB Members at the Time of Approval ...........................3212. Informative References ........................................32Cooper, et al.                Informational                     [Page 3]

RFC 6973                 Privacy Considerations                July 20131.  Introduction   [RFC3552] provides detailed guidance to protocol designers about both   how to consider security as part of protocol design and how to inform   readers of protocol specifications about security issues.  This   document intends to provide a similar set of guidelines for   considering privacy in protocol design.   Privacy is a complicated concept with a rich history that spans many   disciplines.  With regard to data, often it is a concept applied to   "personal data", commonly defined as information relating to an   identified or identifiable individual.  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], a baseline set of privacy protections pertaining to   the collection and use of personal data (often based on the   principles established in [OECD], for example), and the Privacy by   Design concept, which provides high-level privacy guidance for   systems design (see [PbD] for one example).  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.   Different people have radically different conceptions of what privacy   means, both in general and as it relates to them personally [Westin].   Furthermore, 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.   Whether any individual document warrants a specific privacy   considerations section will depend on the document's content.   Documents whose entire focus is privacy may not merit a separate   section (for example, "Private Extensions to the Session Initiation   Protocol (SIP) for Asserted Identity within Trusted Networks"   [RFC3325]).  For certain specifications, privacy considerations are a   subset of security considerations and can be discussed explicitly in   the security considerations section.  Some documents will not require   discussion of privacy considerations (for example, "Definition of the   Opus Audio Codec" [RFC6716]).  The guidance provided here can and   should be used to assess the privacy considerations of protocol,   architectural, and operational specifications and to decide whether   those considerations are to be documented in a stand-alone section,   within the security considerations section, or throughout theCooper, et al.                Informational                     [Page 4]

RFC 6973                 Privacy Considerations                July 2013   document.  The guidance provided here is meant to help the thought   process of privacy analysis; it does not provide specific directions   for how to write a privacy considerations section.   This document is organized as follows.Section 2 describes the   extent to which the guidance offered here is applicable within the   IETF and within the larger Internet community.Section 3 explains   the terminology used in this document.Section 4 reviews typical   communications architectures to understand at which points there may   be privacy threats.Section 5 discusses threats to privacy as they   apply to Internet protocols.Section 6 outlines mitigations of those   threats.Section 7 provides the guidelines for analyzing and   documenting privacy considerations within IETF specifications.Section 8 examines the privacy characteristics of an IETF protocol to   demonstrate the use of the guidance framework.2.  Scope of Privacy Implications of Internet 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 protocol designers often have a particular   target architecture or set of architectures in mind 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 limited.  An individual protocol may be relatively benign on   its own, and it may make use of privacy and security features at   lower layers of the protocol stack (Internet Protocol Security,   Transport Layer Security, and so forth) to mitigate the risk of   attack.  But when deployed within a larger system or used in a way   not envisioned at design time, its use may create new privacy risks.   Protocols are often implemented and deployed long after design time   by different people than those who did the protocol design.  The   guidelines inSection 7 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 the complete system design where various protocols are   combined together to form a product solution; the implementation,   which includes the user interface design; and operational deployment   practices, including default privacy settings and security processes   of the company doing the deployment.  These details are specific toCooper, et al.                Informational                     [Page 5]

RFC 6973                 Privacy Considerations                July 2013   particular instantiations and generally outside the scope of the work   conducted in the IETF.  The guidance provided here may be useful in   making choices about these details, but its primary aim is to assist   with the design, implementation, and operation of protocols.   Transparency of data collection and use -- often effectuated through   user interface design -- is normally relied on (whether rightly or   wrongly) as a key factor in determining the privacy impact of a   system.  Although most IETF activities do not involve standardizing   user interfaces or user-facing communications, in some cases,   understanding expected user interactions can be important for   protocol design.  Unexpected user behavior may have an adverse impact   on security and/or privacy.   In sum, privacy issues, even those related to protocol development,   go beyond the technical guidance discussed herein.  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 Web Distributed Authoring and   Versioning (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.3.  Terminology   This section defines basic terms used in this document, with   references to pre-existing definitions as appropriate.  As in   [RFC4949], each entry is preceded by a dollar sign ($) and a space   for automated searching.  Note that this document does not try to   attempt to define the term 'privacy' with a brief definition.   Instead, privacy is the sum of what is contained in this document.   We therefore follow the approach taken by [RFC3552].  Examples of   several different brief definitions are provided in [RFC4949].Cooper, et al.                Informational                     [Page 6]

RFC 6973                 Privacy Considerations                July 20133.1.  Entities   Several of these terms are further elaborated inSection 4.   $ Attacker:  An entity that works against one or more privacy      protection goals.  Unlike observers, attackers' behavior is      unauthorized.   $ Eavesdropper:  A type of attacker that passively observes an      initiator's communications without the initiator's knowledge or      authorization.  See [RFC4949].   $ Enabler:  A protocol entity that facilitates communication between      an initiator and a recipient without being directly in the      communications path.   $ Individual:  A human being.   $ Initiator:  A protocol entity that initiates communications with a      recipient.   $ Intermediary:  A protocol entity that sits between the initiator      and the recipient and is necessary for the initiator and recipient      to communicate.  Unlike an eavesdropper, an intermediary is an      entity that is part of the communication architecture and      therefore at least tacitly authorized.  For example, a SIP      [RFC3261] proxy is an intermediary in the SIP architecture.   $ Observer:  An entity that is able to observe and collect      information from communications, potentially posing privacy      threats, depending on the context.  As defined in this document,      initiators, recipients, intermediaries, and enablers can all be      observers.  Observers are distinguished from eavesdroppers by      being at least tacitly authorized.   $ Recipient:  A protocol entity that receives communications from an      initiator.Cooper, et al.                Informational                     [Page 7]

RFC 6973                 Privacy Considerations                July 20133.2.  Data and Analysis   $ Attack:  An intentional act by which an entity attempts to violate      an individual's privacy.  See [RFC4949].   $ Correlation:  The combination of various pieces of information that      relate to an individual or that obtain that characteristic when      combined.   $ Fingerprint:  A set of information elements that identifies a      device or application instance.   $ Fingerprinting:  The process of an observer or attacker uniquely      identifying (with a sufficiently high probability) a device or      application instance based on multiple information elements      communicated to the observer or attacker.  See [EFF].   $ Item of Interest (IOI):  Any data item that an observer or attacker      might be interested in.  This includes attributes, identifiers,      identities, communications content, and the fact that a      communication interaction has taken place.   $ Personal Data:  Any information relating to an individual who can      be identified, directly or indirectly.   $ (Protocol) Interaction:  A unit of communication within a      particular protocol.  A single interaction may be comprised of a      single message between an initiator and recipient or multiple      messages, depending on the protocol.   $ Traffic Analysis:  The inference of information from observation of      traffic flows (presence, absence, amount, direction, timing,      packet size, packet composition, and/or frequency), even if flows      are encrypted.  See [RFC4949].   $ Undetectability:  The inability of an observer or attacker to      sufficiently distinguish whether an item of interest exists      or not.   $ Unlinkability:  Within a particular set of information, the      inability of an observer or attacker to distinguish whether two      items of interest are related or not (with a high enough degree of      probability to be useful to the observer or attacker).Cooper, et al.                Informational                     [Page 8]

RFC 6973                 Privacy Considerations                July 20133.3.  Identifiability   $ Anonymity:  The state of being anonymous.   $ Anonymity Set:  A set of individuals that have the same attributes,      making them indistinguishable from each other from the perspective      of a particular attacker or observer.   $ Anonymous:  A state of an individual in which an observer or      attacker cannot identify the individual within a set of other      individuals (the anonymity set).   $ Attribute:  A property of an individual.   $ Identifiability:  The extent to which an individual is      identifiable.   $ Identifiable:  A property in which an individual's identity is      capable of being known to an observer or attacker.   $ Identification:  The linking of information to a particular      individual to infer an individual's identity or to allow the      inference of an individual's identity in some context.   $ Identified:  A state in which an individual's identity is known.   $ Identifier:  A data object uniquely referring to a specific      identity of a protocol entity or individual in some context.  See      [RFC4949].  Identifiers can be based upon natural names --      official names, personal names, and/or nicknames -- or can be      artificial (for example, x9z32vb).  However, identifiers are by      definition unique within their context of use, while natural names      are often not unique.   $ Identity:  Any subset of an individual's attributes, including      names, that identifies the individual within a given context.      Individuals usually have multiple identities for use in different      contexts.   $ Identity Confidentiality:  A property of an individual where only      the recipient can sufficiently identify the individual within a      set of other individuals.  This can be a desirable property of      authentication protocols.   $ Identity Provider:  An entity (usually an organization) that is      responsible for establishing, maintaining, securing, and vouching      for the identities associated with individuals.Cooper, et al.                Informational                     [Page 9]

RFC 6973                 Privacy Considerations                July 2013   $ Official Name:  A personal name for an individual that is      registered in some official context (for example, the name on an      individual's birth certificate).  Official names are often not      unique.   $ Personal Name:  A natural name for an individual.  Personal names      are often not unique and often comprise given names in combination      with a family name.  An individual may have multiple personal      names at any time and over a lifetime, including official names.      From a technological perspective, it cannot always be determined      whether a given reference to an individual is, or is based upon,      the individual's personal name(s) (see Pseudonym).   $ Pseudonym:  A name assumed by an individual in some context,      unrelated to the individual's personal names known by others in      that context, with an intent of not revealing the individual's      identities associated with his or her other names.  Pseudonyms are      often not unique.   $ Pseudonymity:  The state of being pseudonymous.   $ Pseudonymous:  A property of an individual in which the individual      is identified by a pseudonym.   $ Real Name:  See Personal Name and Official Name.   $ Relying Party:  An entity that relies on assertions of individuals'      identities from identity providers in order to provide services to      individuals.  In effect, the relying party delegates aspects of      identity management to the identity provider(s).  Such delegation      requires protocol exchanges, trust, and a common understanding of      semantics of information exchanged between the relying party and      the identity provider.4.  Communications Model   To understand attacks in the privacy-harm sense, it is helpful to   consider the overall communication architecture and different actors'   roles within it.  Consider a protocol entity, the "initiator", that   initiates communication with some recipient.  Privacy analysis is   most relevant for protocols with use cases in which the initiator   acts on behalf of an individual (or different individuals at   different times).  It is this individual whose privacy is potentially   threatened (although in some instances an initiator communicates   information about another individual, in which case both of their   privacy interests will be implicated).Cooper, et al.                Informational                    [Page 10]

RFC 6973                 Privacy Considerations                July 2013   Communications may be direct between the initiator and the recipient,   or they may involve an application-layer intermediary (such as a   proxy, cache, or relay) that is necessary for the two parties to   communicate.  In some cases, this intermediary stays in the   communication path for the entire duration of the communication;   sometimes it is only used for communication establishment, for either   inbound or outbound communication.  In some cases, there may be a   series of intermediaries that are traversed.  At lower layers,   additional entities involved in packet forwarding may interfere with   privacy protection goals as well.   Some communications tasks require multiple protocol interactions with   different entities.  For example, a request to an HTTP server may be   preceded by an interaction between the initiator and an   Authentication, Authorization, and Accounting (AAA) server for   network access and to a Domain Name System (DNS) server for name   resolution.  In this case, the HTTP server is the recipient and the   other entities are enablers of the initiator-to-recipient   communication.  Similarly, a single communication with the recipient   might generate further protocol interactions between either the   initiator or the recipient and other entities, and the roles of the   entities might change with each interaction.  For example, an HTTP   request might trigger interactions with an authentication server or   with other resource servers wherein the recipient becomes an   initiator in those later interactions.   Thus, when conducting privacy analysis of an architecture that   involves multiple communications phases, the entities involved may   take on different -- or opposing -- roles from a privacy   considerations perspective in each phase.  Understanding the privacy   implications of the architecture as a whole may require a separate   analysis of each phase.   Protocol design is often predicated on the notion that recipients,   intermediaries, and enablers are assumed to be authorized to receive   and handle data from initiators.  As [RFC3552] explains, "we assume   that the end systems engaging in a protocol exchange have not   themselves been compromised".  However, privacy analysis requires   questioning this assumption, since systems are often compromised for   the purpose of obtaining personal data.   Although recipients, intermediaries, and enablers may not generally   be considered as attackers, they may all pose privacy threats   (depending on the context) because they are able to observe, collect,   process, and transfer privacy-relevant data.  These entities are   collectively described below as "observers" to distinguish them from   traditional attackers.  From a privacy perspective, one importantCooper, et al.                Informational                    [Page 11]

RFC 6973                 Privacy Considerations                July 2013   type of attacker is an eavesdropper: an entity that passively   observes the initiator's communications without the initiator's   knowledge or authorization.   The threat descriptions in the next section explain how observers and   attackers might act to harm individuals' privacy.  Different kinds of   attacks may be feasible at different points in the communications   path.  For example, an observer could mount surveillance or   identification attacks between the initiator and intermediary, or   instead could surveil an enabler (e.g., by observing DNS queries from   the initiator).5.  Privacy Threats   Privacy harms come in a number of forms, including harms to financial   standing, reputation, solitude, autonomy, and safety.  A victim of   identity theft or blackmail, for example, may suffer a financial loss   as a result.  Reputational harm can occur when disclosure of   information about an individual, whether true or false, subjects that   individual to stigma, embarrassment, or loss of personal dignity.   Intrusion or interruption of an individual's life or activities can   harm the individual's ability to be left alone.  When individuals or   their activities are monitored, exposed, or at risk of exposure,   those individuals may be stifled from expressing themselves,   associating with others, and generally conducting their lives freely.   They may also feel a general sense of unease, in that it is "creepy"   to be monitored or to have data collected about them.  In cases where   such monitoring is for the purpose of stalking or violence (for   example, monitoring communications to or from a domestic abuse   shelter), it can put individuals in physical danger.   This section lists common privacy threats (drawing liberally from   [Solove], as well as [CoE]), showing how each of them may cause   individuals to incur privacy harms and providing examples of how   these threats can exist on the Internet.  This threat modeling is   inspired by security threat analysis.  Although it is not a perfect   fit for assessing privacy risks in Internet protocols and systems, no   better methodology has been developed to date.   Some privacy threats are already considered in Internet protocols as   a matter of routine security analysis.  Others are more pure privacy   threats that existing security considerations do not usually address.   The threats described here are divided into those that may also be   considered security threats and those that are primarily privacy   threats.Cooper, et al.                Informational                    [Page 12]

RFC 6973                 Privacy Considerations                July 2013   Note that an individual's awareness of and consent to the practices   described below may change an individual's perception of and concern   for the extent to which they threaten privacy.  If an individual   authorizes surveillance of his own activities, for example, the   individual may be able to take actions to mitigate the harms   associated with it or may consider the risk of harm to be tolerable.5.1.  Combined Security-Privacy Threats5.1.1.  Surveillance   Surveillance is the observation or monitoring of an individual's   communications or activities.  The effects of surveillance on the   individual can range from anxiety and discomfort to behavioral   changes such as inhibition and self-censorship, and even to the   perpetration of violence against the individual.  The individual need   not be aware of the surveillance for it to impact his or her privacy   -- the possibility of surveillance may be enough to harm individual   autonomy.   Surveillance can impact privacy, even if the individuals being   surveilled are not identifiable or if their communications are   encrypted.  For example, an observer or eavesdropper that conducts   traffic analysis may be able to determine what type of traffic is   present (real-time communications or bulk file transfers, for   example) or which protocols are in use, even if the observed   communications are encrypted or the communicants are unidentifiable.   This kind of surveillance can adversely impact the individuals   involved by causing them to become targets for further investigation   or enforcement activities.  It may also enable attacks that are   specific to the protocol, such as redirection to a specialized   interception point or protocol-specific denials of service.   Protocols that use predictable packet sizes or timing or include   fixed tokens at predictable offsets within a packet can facilitate   this kind of surveillance.   Surveillance can be conducted by observers or eavesdroppers at any   point along the communications path.  Confidentiality protections (as   discussed inSection 3 of [RFC3552]) are necessary to prevent   surveillance of the content of communications.  To prevent traffic   analysis or other surveillance of communications patterns, other   measures may be necessary, such as [Tor].Cooper, et al.                Informational                    [Page 13]

RFC 6973                 Privacy Considerations                July 20135.1.2.  Stored Data Compromise   End systems that do not take adequate measures to secure stored data   from unauthorized or inappropriate access expose individuals to   potential financial, reputational, or physical harm.   Protecting against stored data compromise is typically outside the   scope of IETF protocols.  However, a number of common protocol   functions -- key management, access control, or operational logging,   for example -- require the storage of data about initiators of   communications.  When requiring or recommending that information   about initiators or their communications be stored or logged by end   systems (see, e.g.,RFC 6302 [RFC6302]), it is important to recognize   the potential for that information to be compromised and for that   potential to be weighed against the benefits of data storage.  Any   recipient, intermediary, or enabler that stores data may be   vulnerable to compromise.  (Note that stored data compromise is   distinct from purposeful disclosure, which is discussed inSection 5.2.4.)5.1.3.  Intrusion   Intrusion consists of invasive acts that disturb or interrupt one's   life or activities.  Intrusion can thwart individuals' desires to be   left alone, sap their time or attention, or interrupt their   activities.  This threat is focused on intrusion into one's life   rather than direct intrusion into one's communications.  The latter   is captured inSection 5.1.1.   Unsolicited messages and denial-of-service attacks are the most   common types of intrusion on the Internet.  Intrusion can be   perpetrated by any attacker that is capable of sending unwanted   traffic to the initiator.5.1.4.  Misattribution   Misattribution occurs when data or communications related to one   individual are attributed to another.  Misattribution can result in   adverse reputational, financial, or other consequences for   individuals that are misidentified.   Misattribution in the protocol context comes as a result of using   inadequate or insecure forms of identity or authentication, and is   sometimes related to spoofing.  For example, as [RFC6269] notes,   abuse mitigation is often conducted on the basis of the source IP   address, such that connections from individual IP addresses may be   prevented or temporarily blacklisted if abusive activity is   determined to be sourced from those addresses.  However, in the caseCooper, et al.                Informational                    [Page 14]

RFC 6973                 Privacy Considerations                July 2013   where a single IP address is shared by multiple individuals, those   penalties may be suffered by all individuals sharing the address,   even if they were not involved in the abuse.  This threat can be   mitigated by using identity management mechanisms with proper forms   of authentication (ideally with cryptographic properties) so that   actions can be attributed uniquely to an individual to provide the   basis for accountability without generating false positives.5.2.  Privacy-Specific Threats5.2.1.  Correlation   Correlation is the combination of various pieces of information   related to an individual or that obtain that characteristic when   combined.  Correlation can defy people's expectations of the limits   of what others know about them.  It can increase the power that those   doing the correlating have over individuals as well as correlators'   ability to pass judgment, threatening individual autonomy and   reputation.   Correlation is closely related to identification.  Internet protocols   can facilitate correlation by allowing individuals' activities to be   tracked and combined over time.  The use of persistent or   infrequently replaced identifiers at any layer of the stack can   facilitate correlation.  For example, an initiator's persistent use   of the same device ID, certificate, or email address across multiple   interactions could allow recipients (and observers) to correlate all   of the initiator's communications over time.   As an example, consider Transport Layer Security (TLS) session   resumption [RFC5246] or TLS session resumption without server-side   state [RFC5077].  InRFC 5246 [RFC5246], a server provides the client   with a session_id in the ServerHello message and caches the   master_secret for later exchanges.  When the client initiates a new   connection with the server, it re-uses the previously obtained   session_id in its ClientHello message.  The server agrees to resume   the session by using the same session_id and the previously stored   master_secret for the generation of the TLS Record Layer security   association.RFC 5077 [RFC5077] borrows from the session resumption   design idea, but the server encapsulates all state information into a   ticket instead of caching it.  An attacker who is able to observe the   protocol exchanges between the TLS client and the TLS server is able   to link the initial exchange to subsequently resumed TLS sessions   when the session_id and the ticket are exchanged in the clear (which   is the case with data exchanged in the initial handshake messages).Cooper, et al.                Informational                    [Page 15]

RFC 6973                 Privacy Considerations                July 2013   In theory, any observer or attacker that receives an initiator's   communications can engage in correlation.  The extent of the   potential for correlation will depend on what data the entity   receives from the initiator and has access to otherwise.  Often,   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 initiators' data than is strictly necessary from a   technical point of view.5.2.2.  Identification   Identification is the linking of information to a particular   individual to infer an individual's identity or to allow the   inference of an individual's identity.  In some contexts, it is   perfectly legitimate to identify individuals, whereas in others,   identification may potentially stifle individuals' activities or   expression by inhibiting their ability to be anonymous or   pseudonymous.  Identification also makes it easier for individuals to   be explicitly controlled by others (e.g., governments) and to be   treated differentially compared to other individuals.   Many protocols provide functionality to convey the idea that some   means has been provided to validate that entities are who they claim   to be.  Often, this is accomplished with cryptographic   authentication.  Furthermore, many protocol identifiers, such as   those used in SIP or the Extensible Messaging and Presence Protocol   (XMPP), may allow for the direct identification of individuals.   Protocol identifiers may also contribute indirectly to identification   via correlation.  For example, a web site that does not directly   authenticate users may be able to match its HTTP header logs with   logs from another site that does authenticate users, rendering users   on the first site identifiable.   As with correlation, any observer or attacker may be able to engage   in identification, depending on the information about the initiator   that is available via the protocol mechanism or other channels.5.2.3.  Secondary Use   Secondary use is the use of collected information about an individual   without the individual's consent for a purpose different from that   for which the information was collected.  Secondary use may violate   people's expectations or desires.  The potential for secondary useCooper, et al.                Informational                    [Page 16]

RFC 6973                 Privacy Considerations                July 2013   can generate uncertainty as to how one's information will be used in   the future, potentially discouraging information exchange in the   first place.  Secondary use encompasses any use of data, including   disclosure.   One example of secondary use would be an authentication server that   uses a network access server's Access-Requests to track an   initiator's location.  Any observer or attacker could potentially   make unwanted secondary uses of initiators' data.  Protecting against   secondary use is typically outside the scope of IETF protocols.5.2.4.  Disclosure   Disclosure is the revelation of information about an individual that   affects the way others judge the individual.  Disclosure can violate   individuals' expectations of the confidentiality of the data they   share.  The threat of disclosure may deter people from engaging in   certain activities for fear of reputational harm, or simply because   they do not wish to be observed.   Any observer or attacker that receives data about an initiator may   engage in disclosure.  Sometimes disclosure is unintentional because   system designers do not realize that information being exchanged   relates to individuals.  The most common way for protocols to limit   disclosure is by providing access control mechanisms (discussed inSection 5.2.5).  A further example is provided by the IETF   geolocation privacy architecture [RFC6280], which supports a way for   users to express a preference that their location information not be   disclosed beyond the intended recipient.5.2.5.  Exclusion   Exclusion is the failure to allow individuals to know about the data   that others have about them and to participate in its handling and   use.  Exclusion reduces accountability on the part of entities that   maintain information about people and creates a sense of   vulnerability in relation to individuals' ability to control how   information about them is collected and used.   The most common way for Internet protocols to be involved in   enforcing exclusion is through access control mechanisms.  The   presence architecture developed in the IETF is a good example where   individuals are included in the control of information about them.   Using a rules expression language (e.g., presence authorization rules   [RFC5025]), presence clients can authorize the specific conditions   under which their presence information may be shared.Cooper, et al.                Informational                    [Page 17]

RFC 6973                 Privacy Considerations                July 2013   Exclusion is primarily considered problematic when the recipient   fails to involve the initiator in decisions about data collection,   handling, and use.  Eavesdroppers engage in exclusion by their very   nature, since their data collection and handling practices are   covert.6.  Threat Mitigations   Privacy is notoriously difficult to measure and quantify.  The extent   to which a particular protocol, system, or architecture "protects" or   "enhances" privacy is dependent on a large number of factors relating   to its design, use, and potential misuse.  However, there are certain   widely recognized classes of mitigations against the threats   discussed inSection 5.  This section describes three categories of   relevant mitigations: (1) data minimization, (2) user participation,   and (3) security.  The privacy mitigations described in this section   can loosely be mapped to existing privacy principles, such as the   Fair Information Practices, but they have been adapted to fit the   target audience of this document.6.1.  Data Minimization   Data minimization refers to collecting, using, disclosing, and   storing the minimal data necessary to perform a task.  Reducing the   amount of data exchanged reduces the amount of data that can be   misused or leaked.   Data minimization can be effectuated in a number of different ways,   including by limiting collection, use, disclosure, retention,   identifiability, sensitivity, and access to personal data.  Limiting   the data collected by protocol elements to only what is necessary   (collection limitation) is the most straightforward way to help   reduce privacy risks associated with the use of the protocol.  In   some cases, protocol designers may also be able to recommend limits   to the use or retention of data, although protocols themselves are   not often capable of controlling these properties.   However, the most direct application of data minimization to protocol   design is limiting identifiability.  Reducing the identifiability of   data by using pseudonyms or no identifiers at all helps to weaken the   link between an individual and his or her communications.  Allowing   for the periodic creation of new or randomized identifiers reduces   the possibility that multiple protocol interactions or communications   can be correlated back to the same individual.  The following   sections explore a number of different properties related to   identifiability that protocol designers may seek to achieve.Cooper, et al.                Informational                    [Page 18]

RFC 6973                 Privacy Considerations                July 2013   Data minimization mitigates the following threats: surveillance,   stored data compromise, correlation, identification, secondary use,   and disclosure.6.1.1.  Anonymity   To enable anonymity of an individual, there must exist a set of   individuals that appear to have the same attribute(s) as the   individual.  To the attacker or the observer, these individuals must   appear indistinguishable from each other.  The set of all such   individuals is known as the anonymity set, and membership of this set   may vary over time.   The composition of the anonymity set depends on the knowledge of the   observer or attacker.  Thus, anonymity is relative with respect to   the observer or attacker.  An initiator may be anonymous only within   a set of potential initiators -- its initiator anonymity set -- which   itself may be a subset of all individuals that may initiate   communications.  Conversely, a recipient may be anonymous only within   a set of potential recipients -- its recipient anonymity set.  Both   anonymity sets may be disjoint, may overlap, or may be the same.   As an example, considerRFC 3325 (P-Asserted-Identity (PAI))   [RFC3325], an extension for the Session Initiation Protocol (SIP)   that allows an individual, such as a Voice over IP (VoIP) caller, to   instruct an intermediary that he or she trusts not to populate the   SIP From header field with the individual's authenticated and   verified identity.  The recipient of the call, as well as any other   entity outside of the individual's trust domain, would therefore only   learn that the SIP message (typically a SIP INVITE) was sent with a   header field 'From: "Anonymous" <sip:anonymous@anonymous.invalid>'   rather than the individual's address-of-record, which is typically   thought of as the "public address" of the user.  When PAI is used,   the individual becomes anonymous within the initiator anonymity set   that is populated by every individual making use of that specific   intermediary.   Note that this example ignores the fact that the recipient may infer   or obtain personal data from the other SIP payloads (e.g., SIP Via   and Contact headers, the Session Description Protocol (SDP)).  The   implication is that PAI only attempts to address a particular threat,   namely the disclosure of identity (in the From header) with respect   to the recipient.  This caveat makes the analysis of the specific   protocol extension easier but cannot be assumed when conducting   analysis of an entire architecture.Cooper, et al.                Informational                    [Page 19]

RFC 6973                 Privacy Considerations                July 20136.1.2.  Pseudonymity   In the context of Internet protocols, almost all identifiers can be   nicknames or pseudonyms, since there is typically no requirement to   use personal names in protocols.  However, in certain scenarios it is   reasonable to assume that personal names will be used (with vCard   [RFC6350], for example).   Pseudonymity is strengthened when less personal data can be linked to   the pseudonym; when the same pseudonym is used less often and across   fewer contexts; and when independently chosen pseudonyms are more   frequently used for new actions (making them, from an observer's or   attacker's perspective, unlinkable).   For Internet protocols, the following are important considerations:   whether protocols allow pseudonyms to be changed without human   interaction, the default length of pseudonym lifetimes, to whom   pseudonyms are exposed, how individuals are able to control   disclosure, how often pseudonyms can be changed, and the consequences   of changing them.6.1.3.  Identity Confidentiality   An initiator has identity confidentiality when any party other than   the recipient cannot sufficiently identify the initiator within the   anonymity set.  The size of the anonymity set has a direct impact on   identity confidentiality, since the smaller the set is, the easier it   is to identify the initiator.  Identity confidentiality aims to   provide a protection against eavesdroppers and intermediaries rather   than against the intended communication endpoints.   As an example, consider the network access authentication procedures   utilizing the Extensible Authentication Protocol (EAP) [RFC3748].   EAP includes an identity exchange where the Identity Response is   primarily used for routing purposes and selecting which EAP method to   use.  Since EAP Identity Requests and Identity Responses are sent in   cleartext, eavesdroppers and intermediaries along the communication   path between the EAP peer and the EAP server can snoop on the   identity, which is encoded in the form of the Network Access   Identifier (NAI) as defined inRFC 4282 [RFC4282].  To address this   threat, as discussed inRFC 4282 [RFC4282], the username part of the   NAI (but not the realm part) can be hidden from these eavesdroppers   and intermediaries with the cryptographic support offered by EAP   methods.  Identity confidentiality has become a recommended design   criteria for EAP (see [RFC4017]).  The EAP method for 3rd Generation   Authentication and Key Agreement (EAP-AKA) [RFC4187], for example,   protects the EAP peer's identity against passive adversaries by   utilizing temporal identities.  The EAP-Internet Key ExchangeCooper, et al.                Informational                    [Page 20]

RFC 6973                 Privacy Considerations                July 2013   Protocol version 2 (EAP-IKEv2) method [RFC5106] is an example of an   EAP method that offers protection against active attackers with   regard to the individual's identity.6.1.4.  Data Minimization within Identity Management   Modern systems are increasingly relying on multi-party transactions   to authenticate individuals.  Many of these systems make use of an   identity provider that is responsible for providing AAA functionality   to relying parties that offer some protected resources.  To   facilitate these functions, an identity provider will usually go   through a process of verifying the individual's identity and issuing   credentials to the individual.  When an individual seeks to make use   of a service provided by the relying party, the relying party relies   on the authentication assertions provided by its identity provider.   Note that in more sophisticated scenarios the authentication   assertions are traits that demonstrate the individual's capabilities   and roles.  The authorization responsibility may also be shared   between the identity provider and the relying party and does not   necessarily need to reside only with the identity provider.   Such systems have the ability to support a number of properties that   minimize data collection in different ways:      In certain use cases, relying parties do not need to know the real      name or date of birth of an individual (for example, when the      individual's age is the only attribute that needs to be      authenticated).      Relying parties that collude can be prevented from using an      individual's credentials to track the individual.  That is, two      different relying parties can be prevented from determining that      the same individual has authenticated to both of them.  This      typically requires identity management protocol support as well as      support by both the relying party and the identity provider.      The identity provider can be prevented from knowing which relying      parties an individual interacted with.  This requires, at a      minimum, avoiding direct communication between the identity      provider and the relying party at the time when access to a      resource by the initiator is made.6.2.  User Participation   As explained inSection 5.2.5, data collection and use that happen   "in secret", without the individual's knowledge, are apt to violate   the individual's expectation of privacy and may create incentives for   misuse of data.  As a result, privacy regimes tend to includeCooper, et al.                Informational                    [Page 21]

RFC 6973                 Privacy Considerations                July 2013   provisions to require informing individuals about data collection and   use and involving them in decisions about the treatment of their   data.  In an engineering context, supporting the goal of user   participation usually means providing ways for users to control the   data that is shared about them.  It may also mean providing ways for   users to signal how they expect their data to be used and shared.   Different protocol and architectural designs can make supporting user   participation (for example, the ability to support a dialog box for   user interaction) easier or harder; for example, OAuth-based services   may have more natural hooks for user input than AAA services.   User participation mitigates the following threats: surveillance,   secondary use, disclosure, and exclusion.6.3.  Security   Keeping data secure at rest and in transit is another important   component of privacy protection.  As they are described inSection 2   of [RFC3552], a number of security goals also serve to enhance   privacy:   o  Confidentiality: Keeping data secret from unintended listeners.   o  Peer entity authentication: Ensuring that the endpoint of a      communication is the one that is intended (in support of      maintaining confidentiality).   o  Unauthorized usage: Limiting data access to only those users who      are authorized.  (Note that this goal also falls within data      minimization.)   o  Inappropriate usage: Limiting how authorized users can use data.      (Note that this goal also falls within data minimization.)   Note that even when these goals are achieved, the existence of items   of interest -- attributes, identifiers, identities, communications,   actions (such as the sending or receiving of a communication), or   anything else an attacker or observer might be interested in -- may   still be detectable, even if they are not readable.  Thus,   undetectability, in which an observer or attacker cannot sufficiently   distinguish whether an item of interest exists or not, may be   considered as a further security goal (albeit one that can be   extremely difficult to accomplish).   Detection of the protocols or applications in use via traffic   analysis may be particularly difficult to defend against.  As with   the anonymity of individuals, achieving "protocol anonymity" requires   that multiple protocols or applications exist that appear to have theCooper, et al.                Informational                    [Page 22]

RFC 6973                 Privacy Considerations                July 2013   same attributes -- packet sizes, content, token locations, or   inter-packet timing, for example.  An attacker or observer will not   be able to use traffic analysis to identify which protocol or   application is in use if multiple protocols or applications are   indistinguishable.   Defending against the threat of traffic analysis will be possible to   different extents for different protocols, may depend on   implementation- or use-specific details, and may depend on which   other protocols already exist and whether they share similar traffic   characteristics.  The defenses will also vary relative to what the   protocol is designed to do; for example, in some situations   randomizing packet sizes, timing, or token locations will reduce the   threat of traffic analysis, whereas in other situations (real-time   communications, for example) holding some or all of those factors   constant is a more appropriate defense.  See "Guidelines for the Use   of Variable Bit Rate Audio with Secure RTP" [RFC6562] for an example   of how these kinds of trade-offs should be evaluated.   By providing proper security protection, the following threats can be   mitigated: surveillance, stored data compromise, misattribution,   secondary use, disclosure, and intrusion.7.  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 provided in this section 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.  This guidance is meant to help the   thought process of privacy analysis; it does not provide specific   directions for how to write a privacy considerations section.   The framework is divided into four sections: three sections that   address each of the mitigation classes fromSection 6, plus a general   section.  Security is not fully elaborated, since substantial   guidance already exists in [RFC3552].Cooper, et al.                Informational                    [Page 23]

RFC 6973                 Privacy Considerations                July 20137.1.  Data Minimization   a.  Identifiers.  What identifiers does the protocol use for       distinguishing initiators of communications?  Does the protocol       use identifiers that allow different protocol interactions to be       correlated?  What identifiers could be omitted or be made less       identifying while still fulfilling the protocol's goals?   b.  Data.  What information does the protocol expose about       individuals, their devices, and/or their device usage (other than       the identifiers discussed in (a))?  To what extent is this       information linked to the identities of the individuals?  How       does the protocol combine personal data with the identifiers       discussed in (a)?   c.  Observers.  Which information discussed in (a) and (b) is exposed       to each other protocol entity (i.e., recipients, intermediaries,       and enablers)?  Are there ways for protocol implementers to       choose to limit the information shared with each entity?  Are       there operational controls available to limit the information       shared with each entity?   d.  Fingerprinting.  In many cases, the specific ordering and/or       occurrences of information elements in a protocol allow users,       devices, or software using the protocol to be fingerprinted.  Is       this protocol vulnerable to fingerprinting?  If so, how?  Can it       be designed to reduce or eliminate the vulnerability?  If not,       why not?   e.  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 replace identifiers?  How often does the specification       recommend deleting or replacing identifiers by default?  Can the       identifiers, along with other state information, be set to       automatically expire?   f.  Correlation.  Does the protocol allow for correlation of       identifiers?  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 fingerprinting of a user, device, or       application?  Are there expected combinations or correlations       with outside data that will make users of the protocol more       identifiable?Cooper, et al.                Informational                    [Page 24]

RFC 6973                 Privacy Considerations                July 2013   g.  Retention.  Does the protocol or its anticipated uses require       that the information discussed in (a) or (b) be retained by       recipients, intermediaries, or enablers?  If so, why?  Is the       retention expected to be persistent or temporary?7.2.  User Participation   a.  User control.  What controls or consent mechanisms does the       protocol define or require before personal data or identifiers       are shared or exposed via the protocol?  If no such mechanisms or       controls are specified, is it expected that control and consent       will be handled outside of the protocol?   b.  Control over sharing with individual recipients.  Does the       protocol provide ways for initiators to share different       information with different recipients?  If not, are there       mechanisms that exist outside of the protocol to provide       initiators with such control?   c.  Control over sharing with intermediaries.  Does the protocol       provide ways for initiators 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 that govern the       use of the information (contractual or otherwise) with those who       operate these intermediaries?   d.  Preference expression.  Does the protocol provide ways for       initiators to express individuals' preferences to recipients or       intermediaries with regard to the collection, use, or disclosure       of their personal data?7.3.  Security   a.  Surveillance.  How do the protocol's security considerations       prevent surveillance, including eavesdropping and traffic       analysis?  Does the protocol leak information that can be       observed through traffic analysis, such as by using a fixed token       at fixed offsets, or packet sizes or timing that allow observers       to determine characteristics of the traffic (e.g., which protocol       is in use or whether the traffic is part of a real-time flow)?   b.  Stored data compromise.  How do the protocol's security       considerations prevent or mitigate stored data compromise?Cooper, et al.                Informational                    [Page 25]

RFC 6973                 Privacy Considerations                July 2013   c.  Intrusion.  How do the protocol's security considerations prevent       or mitigate intrusion, including denial-of-service attacks and       unsolicited communications more generally?   d.  Misattribution.  How do the protocol's mechanisms for identifying       and/or authenticating individuals prevent misattribution?7.4.  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.   b.  Defaults.  If the protocol can be operated in multiple modes or       with multiple configurable options, does the default mode or       option minimize the amount, identifiability, and persistence of       the data and identifiers exposed by the protocol?  Does the       default mode or option maximize the opportunity for user       participation?  Does it provide the strictest security features       of all the modes/options?  If the answer to any of these       questions is no, explain why less protective defaults were       chosen.8.  Example   The following section gives an example of the threat analysis and   threat mitigations recommended by this document.  It covers a   particularly difficult application protocol, presence, to try to   demonstrate these principles on an architecture that is vulnerable to   many of the threats described above.  This text is not intended as an   example of a privacy considerations section that might appear in an   IETF specification, but rather as an example of the thinking that   should go into the design of a protocol when considering privacy as a   first principle.   A presence service, as defined in the abstract in [RFC2778], allows   users of a communications service to monitor one another's   availability and disposition in order to make decisions about   communicating.  Presence information is highly dynamic and generally   characterizes whether a user is online or offline, busy or idle, away   from communications devices or nearby, and the like.  Necessarily,   this information has certain privacy implications, and from the start   the IETF approached this work with the aim of providing users with   the controls to determine how their presence information would be   shared.  The Common Profile for Presence (CPP) [RFC3859] defines a   set of logical operations for delivery of presence information.  This   abstract model is applicable to multiple presence systems.  The SIPCooper, et al.                Informational                    [Page 26]

RFC 6973                 Privacy Considerations                July 2013   for Instant Messaging and Presence Leveraging Extensions (SIMPLE)   presence system [RFC3856] uses CPP as its baseline architecture, and   the presence operations in the Extensible Messaging and Presence   Protocol (XMPP) have also been mapped to CPP [RFC3922].   The fundamental architecture defined inRFC 2778 andRFC 3859 is a   mediated one.  Clients (presentities inRFC 2778 terms) publish their   presence information to presence servers, which in turn distribute   information to authorized watchers.  Presence servers thus retain   presence information for an interval of time, until it either changes   or expires, so that it can be revealed to authorized watchers upon   request.  This architecture mirrors existing pre-standard deployment   models.  The integration of an explicit authorization mechanism into   the presence architecture has been widely successful in involving the   end users in the decision-making process before sharing information.   Nearly all presence systems deployed today provide such a mechanism,   typically through a reciprocal authorization system by which a pair   of users, when they agree to be "buddies", consent to divulge their   presence information to one another.  Buddylists are managed by   servers but controlled by end users.  Users can also explicitly block   one another through a similar interface, and in some deployments it   is desirable to provide "polite blocking" of various kinds.   From a perspective of privacy design, however, the classical presence   architecture represents nearly a worst-case scenario.  In terms of   data minimization, presentities share their sensitive information   with presence services, and while services only share this presence   information with watchers authorized by the user, no technical   mechanism constrains those watchers from relaying presence to further   third parties.  Any of these entities could conceivably log or retain   presence information indefinitely.  The sensitivity cannot be   mitigated by rendering the user anonymous, as it is indeed the   purpose of the system to facilitate communications between users who   know one another.  The identifiers employed by users are long-lived   and often contain personal information, including personal names and   the domains of service providers.  While users do participate in the   construction of buddylists and blacklists, they do so with little   prospect for accountability: the user effectively throws their   presence information over the wall to a presence server that in turn   distributes the information to watchers.  Users typically have no way   to verify that presence is being distributed only to authorized   watchers, especially as it is the server that authenticates watchers,   not the end user.  Moreover, connections between the server and all   publishers and consumers of presence data are an attractive target   for eavesdroppers and require strong confidentiality mechanisms,   though again the end user has no way to verify what mechanisms are in   place between the presence server and a watcher.Cooper, et al.                Informational                    [Page 27]

RFC 6973                 Privacy Considerations                July 2013   Additionally, the sensitivity of presence information is not limited   to the disposition and capability to communicate.  Capabilities can   reveal the type of device that a user employs, for example, and since   multiple devices can publish the same user's presence, there are   significant risks of allowing attackers to correlate user devices.   An important extension to presence was developed to enable the   support for location sharing.  The effort to standardize protocols   for systems sharing geolocation was started in the GEOPRIV working   group.  During the initial requirements and privacy threat analysis   in the process of chartering the working group, it became clear that   the system would require an underlying communication mechanism   supporting user consent to share location information.  The   resemblance of these requirements to the presence framework was   quickly recognized, and this design decision was documented in   [RFC4079].  Location information thus mingles with other presence   information available through the system to intermediaries and to   authorized watchers.   Privacy concerns about presence information largely arise due to the   built-in mediation of the presence architecture.  The need for a   presence server is motivated by two primary design requirements of   presence: in the first place, the server can respond with an   "offline" indication when the user is not online; in the second   place, the server can compose presence information published by   different devices under the user's control.  Additionally, to   facilitate the use of URIs as identifiers for entities, some service   must operate a host with the domain name appearing in a presence URI,   and in practical terms no commercial presence architecture would   force end users to own and operate their own domain names.  Many end   users of applications like presence are behind NATs or firewalls and   effectively cannot receive direct connections from the Internet --   the persistent bidirectional channel these clients open and maintain   with a presence server is essential to the operation of the protocol.   One must first ask if the trade-off of mediation for presence is   worthwhile.  Does a server need to be in the middle of all   publications of presence information?  It might seem that end-to-end   encryption of the presence information could solve many of these   problems.  A presentity could encrypt the presence information with   the public key of a watcher and only then send the presence   information through the server.  The IETF defined an object format   for presence information called the Presence Information Data Format   (PIDF), which for the purposes of conveying location information was   extended to the PIDF Location Object (PIDF-LO) -- these XML objects   were designed to accommodate an encrypted wrapper.  Encrypting this   data would have the added benefit of preventing stored cleartext   presence information from being seized by an attacker who manages to   compromise a presence server.  This proposal, however, quickly runsCooper, et al.                Informational                    [Page 28]

RFC 6973                 Privacy Considerations                July 2013   into usability problems.  Discovering the public keys of watchers is   the first difficulty, one that few Internet protocols have addressed   successfully.  This solution would then require the presentity to   publish one encrypted copy of its presence information per authorized   watcher to the presence service, regardless of whether or not a   watcher is actively seeking presence information -- for a presentity   with many watchers, this may place an unacceptable burden on the   presence server, especially given the dynamism of presence   information.  Finally, it prevents the server from composing presence   information reported by multiple devices under the same user's   control.  On the whole, these difficulties render object encryption   of presence information a doubtful prospect.   Some protocols that support presence information, such as SIP, can   operate intermediaries in a redirecting mode rather than a publishing   or proxying mode.  Instead of sending presence information through   the server, in other words, these protocols can merely redirect   watchers to the presentity, and then presence information could pass   directly and securely from the presentity to the watcher.  It is   worth noting that this would disclose the IP address of the   presentity to the watcher, which has its own set of risks.  In that   case, the presentity can decide exactly what information it would   like to share with the watcher in question, it can authenticate the   watcher itself with whatever strength of credential it chooses, and   with end-to-end encryption it can reduce the likelihood of any   eavesdropping.  In a redirection architecture, a presence server   could still provide the necessary "offline" indication without   requiring the presence server to observe and forward all information   itself.  This mechanism is more promising than encryption but also   suffers from significant difficulties.  It too does not provide for   composition of presence information from multiple devices -- it in   fact forces the watcher to perform this composition itself.  The   largest single impediment to this approach is, however, the   difficulty of creating end-to-end connections between the   presentity's device(s) and a watcher, as some or all of these   endpoints may be behind NATs or firewalls that prevent peer-to-peer   connections.  While there are potential solutions for this problem,   like Session Traversal Utilities for NAT (STUN) and Traversal Using   Relays around NAT (TURN), they add complexity to the overall system.   Consequently, mediation is a difficult feature of the presence   architecture to remove.  It is hard to minimize the data shared with   intermediaries, especially due to the requirement for composition.   Control over sharing with intermediaries must therefore come from   some other explicit component of the architecture.  As such, the   presence work in the IETF focused on improving user participation in   the activities of the presence server.  This work began in the   GEOPRIV working group, with controls on location privacy, as locationCooper, et al.                Informational                    [Page 29]

RFC 6973                 Privacy Considerations                July 2013   of users is perceived as having especially sensitive properties.   With the aim of meeting the privacy requirements defined in   [RFC2779], a set of usage indications, such as whether retransmission   is allowed or when the retention period expires, have been added to   the PIDF-LO such that they always travel with the location   information itself.  These privacy preferences apply not only to the   intermediaries that store and forward presence information but also   to the watchers who consume it.   This approach very much follows the spirit of Creative Commons [CC],   namely the usage of a limited number of conditions (such as 'Share   Alike' [CC-SA]).  Unlike Creative Commons, the GEOPRIV working group   did not, however, initiate work to produce legal language or design   graphical icons, since this would fall outside the scope of the IETF.   In particular, the GEOPRIV rules state a preference on the retention   and retransmission of location information; while GEOPRIV cannot   force any entity receiving a PIDF-LO object to abide by those   preferences, if users lack the ability to express them at all, we can   guarantee their preferences will not be honored.  The GEOPRIV rules   can provide a means to establish accountability.   The retention and retransmission elements were envisioned as the most   essential examples of preference expression in sharing presence.  The   PIDF object was designed for extensibility, and the rulesets created   for the PIDF-LO can also be extended to provide new expressions of   user preference.  Not all user preference information should be bound   into a particular PIDF object, however; many forms of access control   policy assumed by the presence architecture need to be provisioned in   the presence server by some interface with the user.  This   requirement eventually triggered the standardization of a general   access control policy language called the common policy framework   (defined in [RFC4745]).  This language allows one to express ways to   control the distribution of information as simple conditions,   actions, and transformation rules expressed in an XML format.  Common   Policy itself is an abstract format that needs to be instantiated:   two examples can be found with the presence authorization rules   [RFC5025] and the Geolocation Policy [RFC6772].  The former provides   additional expressiveness for presence-based systems, while the   latter defines syntax and semantics for location-based conditions and   transformations.   Ultimately, the privacy work on presence represents a compromise   between privacy principles and the needs of the architecture and   marketplace.  While it was not feasible to remove intermediaries from   the architecture entirely or prevent their access to presence   information, the IETF did provide a way for users to express their   preferences and provision their controls at the presence service.  We   have not had great successes in the implementation space with privacyCooper, et al.                Informational                    [Page 30]

RFC 6973                 Privacy Considerations                July 2013   mechanisms thus far, but by documenting and acknowledging the   limitations of these mechanisms, the designers were able to provide   implementers, and end users, with an informed perspective on the   privacy properties of the IETF's presence protocols.9.  Security Considerations   This document describes privacy aspects that protocol designers   should consider in addition to regular security analysis.10.  Acknowledgements   We would like to thank Christine Runnegar for her extensive helpful   review comments.   We would like to thank Scott Brim, Kasey Chappelle, Marc Linsner,   Bryan McLaughlin, Nick Mathewson, Eric Rescorla, Scott Bradner, Nat   Sakimura, Bjoern Hoehrmann, David Singer, Dean Willis, Lucy Lynch,   Trent Adams, Mark Lizar, Martin Thomson, Josh Howlett, Mischa   Tuffield, S. Moonesamy, Zhou Sujing, Claudia Diaz, Leif Johansson,   Jeff Hodges, Stephen Farrell, Steven Johnston, Cullen Jennings, Ted   Hardie, Dave Thaler, Klaas Wierenga, Adrian Farrel, Stephane   Bortzmeyer, Dave Crocker, and Hector Santos for their useful feedback   on this document.   Finally, 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.   Although John Morris is currently employed by the U.S. Government, he   participated in the development of this document in his personal   capacity, and the views expressed in the document may not reflect   those of his employer.Cooper, et al.                Informational                    [Page 31]

RFC 6973                 Privacy Considerations                July 201311.  IAB Members at the Time of Approval   Bernard Aboba   Jari Arkko   Marc Blanchet   Ross Callon   Alissa Cooper   Spencer Dawkins   Joel Halpern   Russ Housley   Eliot Lear   Xing Li   Andrew Sullivan   Dave Thaler   Hannes Tschofenig12.  Informative References   [CC-SA]    Creative Commons, "Share Alike", 2012,              <http://wiki.creativecommons.org/Share_Alike>.   [CC]       Creative Commons, "Creative Commons", 2012,              <http://creativecommons.org/>.   [CoE]      Council of Europe, "Recommendation CM/Rec(2010)13 of the              Committee of Ministers to member states on the protection              of individuals with regard to automatic processing of              personal data in the context of profiling", November 2010,              <https://wcd.coe.int/ViewDoc.jsp?Ref=CM/Rec%282010%2913>.   [EFF]      Electronic Frontier Foundation, "Panopticlick", 2013,              <http://panopticlick.eff.org>.   [FIPs]     Gellman, B., "Fair Information Practices: A Basic              History", 2012,              <http://bobgellman.com/rg-docs/rg-FIPShistory.pdf>.   [OECD]     Organisation for Economic Co-operation and Development,              "OECD Guidelines on the Protection of Privacy and              Transborder Flows of Personal Data", (adopted 1980),              September 2010, <http://www.oecd.org/>.   [PbD]      Office of the Information and Privacy Commissioner,              Ontario, Canada, "Privacy by Design", 2013,              <http://privacybydesign.ca/>.Cooper, et al.                Informational                    [Page 32]

RFC 6973                 Privacy Considerations                July 2013   [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.   [RFC2778]  Day, M., Rosenberg, J., and H. Sugano, "A Model for              Presence and Instant Messaging",RFC 2778, February 2000.   [RFC2779]  Day, M., Aggarwal, S., Mohr, G., and J. Vincent, "Instant              Messaging / Presence Protocol Requirements",RFC 2779,              February 2000.   [RFC3261]  Rosenberg, J., Schulzrinne, H., Camarillo, G., Johnston,              A., Peterson, J., Sparks, R., Handley, M., and E.              Schooler, "SIP: Session Initiation Protocol",RFC 3261,              June 2002.   [RFC3325]  Jennings, C., Peterson, J., and M. Watson, "Private              Extensions to the Session Initiation Protocol (SIP) for              Asserted Identity within Trusted Networks",RFC 3325,              November 2002.   [RFC3552]  Rescorla, E. and B. Korver, "Guidelines for Writing RFC              Text on Security Considerations",BCP 72,RFC 3552,              July 2003.   [RFC3748]  Aboba, B., Blunk, L., Vollbrecht, J., Carlson, J., and H.              Levkowetz, "Extensible Authentication Protocol (EAP)",RFC 3748, June 2004.   [RFC3856]  Rosenberg, J., "A Presence Event Package for the Session              Initiation Protocol (SIP)",RFC 3856, August 2004.   [RFC3859]  Peterson, J., "Common Profile for Presence (CPP)",RFC 3859, August 2004.   [RFC3922]  Saint-Andre, P., "Mapping the Extensible Messaging and              Presence Protocol (XMPP) to Common Presence and Instant              Messaging (CPIM)",RFC 3922, October 2004.   [RFC4017]  Stanley, D., Walker, J., and B. Aboba, "Extensible              Authentication Protocol (EAP) Method Requirements for              Wireless LANs",RFC 4017, March 2005.   [RFC4079]  Peterson, J., "A Presence Architecture for the              Distribution of GEOPRIV Location Objects",RFC 4079,              July 2005.Cooper, et al.                Informational                    [Page 33]

RFC 6973                 Privacy Considerations                July 2013   [RFC4101]  Rescorla, E. and IAB, "Writing Protocol Models",RFC 4101,              June 2005.   [RFC4187]  Arkko, J. and H. Haverinen, "Extensible Authentication              Protocol Method for 3rd Generation Authentication and Key              Agreement (EAP-AKA)",RFC 4187, January 2006.   [RFC4282]  Aboba, B., Beadles, M., Arkko, J., and P. Eronen, "The              Network Access Identifier",RFC 4282, December 2005.   [RFC4745]  Schulzrinne, H., Tschofenig, H., Morris, J., Cuellar, J.,              Polk, J., and J. Rosenberg, "Common Policy: A Document              Format for Expressing Privacy Preferences",RFC 4745,              February 2007.   [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.   [RFC5025]  Rosenberg, J., "Presence Authorization Rules",RFC 5025,              December 2007.   [RFC5077]  Salowey, J., Zhou, H., Eronen, P., and H. Tschofenig,              "Transport Layer Security (TLS) Session Resumption without              Server-Side State",RFC 5077, January 2008.   [RFC5106]  Tschofenig, H., Kroeselberg, D., Pashalidis, A., Ohba, Y.,              and F. Bersani, "The Extensible Authentication Protocol-              Internet Key Exchange Protocol version 2 (EAP-IKEv2)              Method",RFC 5106, February 2008.   [RFC5246]  Dierks, T. and E. Rescorla, "The Transport Layer Security              (TLS) Protocol Version 1.2",RFC 5246, August 2008.   [RFC6269]  Ford, M., Boucadair, M., Durand, A., Levis, P., and P.              Roberts, "Issues with IP Address Sharing",RFC 6269,              June 2011.   [RFC6280]  Barnes, R., Lepinski, M., Cooper, A., Morris, J.,              Tschofenig, H., and H. Schulzrinne, "An Architecture for              Location and Location Privacy in Internet Applications",BCP 160,RFC 6280, July 2011.   [RFC6302]  Durand, A., Gashinsky, I., Lee, D., and S. Sheppard,              "Logging Recommendations for Internet-Facing Servers",BCP 162,RFC 6302, June 2011.Cooper, et al.                Informational                    [Page 34]

RFC 6973                 Privacy Considerations                July 2013   [RFC6350]  Perreault, S., "vCard Format Specification",RFC 6350,              August 2011.   [RFC6562]  Perkins, C. and JM. Valin, "Guidelines for the Use of              Variable Bit Rate Audio with Secure RTP",RFC 6562,              March 2012.   [RFC6716]  Valin, JM., Vos, K., and T. Terriberry, "Definition of the              Opus Audio Codec",RFC 6716, September 2012.   [RFC6772]  Schulzrinne, H., Tschofenig, H., Cuellar, J., Polk, J.,              Morris, J., and M. Thomson, "Geolocation Policy: A              Document Format for Expressing Privacy Preferences for              Location Information",RFC 6772, January 2013.   [Solove]   Solove, D., "Understanding Privacy", March 2010.   [Tor]      The Tor Project, Inc., "Tor", 2013,              <https://www.torproject.org/>.   [Westin]   Kumaraguru, P. and L. Cranor, "Privacy Indexes: A Survey              of Westin's Studies", December 2005,              <http://reports-archive.adm.cs.cmu.edu/anon/isri2005/CMU-ISRI-05-138.pdf>.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.atCooper, et al.                Informational                    [Page 35]

RFC 6973                 Privacy Considerations                July 2013   Bernard Aboba   Skype   EMail: bernard_aboba@hotmail.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   Marit Hansen   ULD   EMail: marit.hansen@datenschutzzentrum.de   Rhys Smith   Janet   EMail: rhys.smith@ja.netCooper, et al.                Informational                    [Page 36]

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