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Privacy Considerations for Internet Protocols
draft-iab-privacy-considerations-03

The information below is for an old version of the document.
Document Type
This is an older version of an Internet-Draft that was ultimately published as RFC 6973.
Authors Alissa Cooper , Hannes Tschofenig , Dr. Bernard D. Aboba , Jon Peterson , John Morris , Marit Hansen , Rhys Smith
Last updated 2012-07-16
Replaces draft-morris-privacy-considerations
RFC stream Internet Architecture Board (IAB)
Formats
Stream IAB state (None)
Consensus boilerplate Unknown
IAB shepherd (None)
draft-iab-privacy-considerations-03
Network Working Group                                          A. Cooper
Internet-Draft                                                       CDT
Intended status: Informational                             H. Tschofenig
Expires: January 17, 2013                         Nokia Siemens Networks
                                                                B. Aboba
                                                   Microsoft Corporation
                                                             J. Peterson
                                                           NeuStar, Inc.
                                                               J. Morris

                                                               M. Hansen
                                                                ULD Kiel
                                                                R. Smith
                                                               JANET(UK)
                                                           July 16, 2012

             Privacy Considerations for Internet Protocols
                draft-iab-privacy-considerations-03.txt

Abstract

   This document offers guidance for developing privacy considerations
   for inclusion in IETF documents and aims to make protocol designers
   aware of privacy-related design choices.

   Discussion of this document is taking place on the IETF Privacy
   Discussion mailing list (see
   https://www.ietf.org/mailman/listinfo/ietf-privacy).

Status of this Memo

   This Internet-Draft is submitted in full conformance with the
   provisions of BCP 78 and BCP 79.

   Internet-Drafts are working documents of the Internet Engineering
   Task Force (IETF).  Note that other groups may also distribute
   working documents as Internet-Drafts.  The list of current Internet-
   Drafts is at http://datatracker.ietf.org/drafts/current/.

   Internet-Drafts are draft documents valid for a maximum of six months
   and may be updated, replaced, or obsoleted by other documents at any
   time.  It is inappropriate to use Internet-Drafts as reference
   material or to cite them other than as "work in progress."

   This Internet-Draft will expire on January 17, 2013.

Copyright Notice

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   Copyright (c) 2012 IETF Trust and the persons identified as the
   document authors.  All rights reserved.

   This document is subject to BCP 78 and the IETF Trust's Legal
   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.  Code Components extracted from this document must
   include Simplified BSD License text as described in Section 4.e of
   the Trust Legal Provisions and are provided without warranty as
   described in the Simplified BSD License.

Table of Contents

   1.  Introduction . . . . . . . . . . . . . . . . . . . . . . . . .  3
   2.  Scope  . . . . . . . . . . . . . . . . . . . . . . . . . . . .  4
   3.  Terminology  . . . . . . . . . . . . . . . . . . . . . . . . .  6
     3.1.  Entities . . . . . . . . . . . . . . . . . . . . . . . . .  6
     3.2.  Data and Analysis  . . . . . . . . . . . . . . . . . . . .  6
     3.3.  Identifiability  . . . . . . . . . . . . . . . . . . . . .  7
   4.  Internet Privacy Threat Model  . . . . . . . . . . . . . . . .  9
     4.1.  Communications Model . . . . . . . . . . . . . . . . . . .  9
     4.2.  Privacy Threats  . . . . . . . . . . . . . . . . . . . . . 10
       4.2.1.  Combined Security-Privacy Threats  . . . . . . . . . . 11
       4.2.2.  Privacy-Specific Threats . . . . . . . . . . . . . . . 12
   5.  Threat Mitigations . . . . . . . . . . . . . . . . . . . . . . 16
     5.1.  Data Minimization  . . . . . . . . . . . . . . . . . . . . 16
       5.1.1.  Anonymity  . . . . . . . . . . . . . . . . . . . . . . 16
       5.1.2.  Pseudonymity . . . . . . . . . . . . . . . . . . . . . 17
       5.1.3.  Identity Confidentiality . . . . . . . . . . . . . . . 18
       5.1.4.  Data Minimization within Identity Management . . . . . 18
     5.2.  User Participation . . . . . . . . . . . . . . . . . . . . 19
     5.3.  Security . . . . . . . . . . . . . . . . . . . . . . . . . 19
   6.  Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . 21
     6.1.  General  . . . . . . . . . . . . . . . . . . . . . . . . . 21
     6.2.  Data Minimization  . . . . . . . . . . . . . . . . . . . . 21
     6.3.  User Participation . . . . . . . . . . . . . . . . . . . . 22
     6.4.  Security . . . . . . . . . . . . . . . . . . . . . . . . . 23
   7.  Example  . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
   8.  Security Considerations  . . . . . . . . . . . . . . . . . . . 29
   9.  IANA Considerations  . . . . . . . . . . . . . . . . . . . . . 30
   10. Acknowledgements . . . . . . . . . . . . . . . . . . . . . . . 31
   11. Informative References . . . . . . . . . . . . . . . . . . . . 32
   Authors' Addresses . . . . . . . . . . . . . . . . . . . . . . . . 35

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1.  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 IETF documents about security issues.  This document
   intends to provide a similar set of guidance 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," 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.

   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 will require 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, [RFC3325]).  For certain specifications,
   privacy considerations are a subset of security considerations and
   can be discussed explicitly in the security considerations section.
   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 the document.

   This document is organized as follows.  Section 2 describes the
   extent to which the guidance offered is applicable within the IETF.
   Section 3 explains the terminology used in this document.  Section 4
   discusses threats to privacy as they apply to Internet protocols.
   Section 5 outlines privacy goals.  Section 6 provides the guidelines
   for analyzing and documenting privacy considerations within IETF
   specifications.  Section 7 examines the privacy characteristics of an
   IETF protocol to demonstrate the use of the guidance framework.

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2.  Scope

   The core function of IETF activity is building 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 significantly limited.  An individual protocol may be
   relatively benign on its own, 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 in Section 6 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
   within the company doing the deployment.  These details are specific
   to 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 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

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   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 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.

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3.  Terminology

   This section defines basic terms used in this document, with
   references to pre-existing definitions as appropriate.

3.1.  Entities

   Several of these terms are further elaborated in Section 4.1.

   $ Attacker:   An entity that intentionally works against some
      protection goal.

   $ Eavesdropper:   An entity 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 natural person.

   $ 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.  For
      example, a SIP proxy is an intermediary in the SIP architecture.

   $ Observer:   An entity that is authorized to receive and handle data
      from an initiator and thereby is able to observe and collect
      information, potentially posing privacy threats depending on the
      context.  As defined in this document, recipients, intermediaries,
      and enablers can all be observers.

   $ Recipient:   A protocol entity that receives communications from an
      initiator.

3.2.  Data and Analysis

   $ Correlation:   The combination of various pieces of information
      relating to an individual.

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   $ 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, or communications interactions (such as
      the sending or receiving of a communication).

   $ Personal Data:   Any information relating to an identified
      individual or an individual who can be identified, directly or
      indirectly.

   $ (Protocol) Interaction:   A unit of communication within a
      particular protocol.  A single interaction may be compromised 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, and
      frequency).  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).

3.3.  Identifiability

   $ Anonymity:   The state of being anonymous.

   $ Anonymous:   A property 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 or initiator.

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   $ Identifiable:   A state in which a individual's identity is capable
      of being known.

   $ Identifiability:   The extent to which an individual is
      identifiable.

   $ Identified:   A state in which an individual's identity is known.

   $ Identifier:   A data object that represents a specific identity of
      a protocol entity or individual.  See [RFC4949].

   $ Identification:   The linking of information to a particular
      individual to infer the individual's identity or that allows the
      inference of the individual's identity.

   $ Identity:   Any subset of an individual's attributes 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 wherein any
      party other than the recipient cannot sufficiently identify the
      individual within a set of other individuals (the anonymity set).

   $ Identity provider:   An entity (usually an organization) that is
      responsible for establishing, maintaining, and securing the
      identity associated with individuals.

   $ Pseudonym:   An identifier of an individual other than the
      individual's real name.

   $ Pseudonymity:   The state of being pseudonymous.

   $ Pseudonymous:   A property of an individual in which the individual
      is identified by a pseudonym.

   $ Real name:   The opposite of a pseudonym.  An individual's real
      name typically comprises his or her given names and a family name.
      An individual may have multiple real names over a lifetime,
      including legal names.  From a technological perspective it cannot
      always be determined whether an identifier of an individual is a
      pseudonym or a real name.

   $ Relying party:   An entity that manages access to some resource.
      Security mechanisms allow the relying party to delegate aspects of
      identity management to an identity provider.  This delegation
      requires protocol exchanges, trust, and a common understanding of
      semantics of information exchanged between the relying party and
      the identity provider.

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4.  Internet Privacy Threat Model

   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, 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.

4.1.  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 element that initiates
   communication with some recipient (an "initiator").  Privacy analysis
   is most relevant for protocols with use cases in which the initiator
   acts on behalf of a natural person (or different people at different
   times).  It is this individual whose privacy is potentially
   threatened.

   Communications may be direct between the initiator and the recipient,
   or they may involve an application-layer intermediary (such as a
   proxy or cache) 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 and sometimes it is only
   used for communication establishment, for either inbound or outbound
   communication.  In rare cases there may be a series of intermediaries
   that are traversed.  At lower layers, additional entities are
   involved in packet forwarding that 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

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   Authentication, Authorization, and Accounting (AAA) server for
   network access and to a 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 my generate further protocol
   interactions between either the initiator or the recipient and other
   entities.  For example, an HTTP request might trigger interactions
   with an authentication server or with other resource servers.

   As a general matter, recipients, intermediaries, and enablers are
   usually 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."

   Although recipients, intermediairies, 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 and
   collect privacy-relevant data.  These entities are collectively
   described below as "observers" to distinguish them from traditional
   attackers.  From a privacy perspective, one important 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).

4.2.  Privacy Threats

   Some privacy threats are already considered in IETF 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.

   Note that an individual's awareness of and consent to the practices
   described below can greatly affect the extent to which they threaten
   privacy.  If an individual authorizes surveillance of his own
   activities, for example, the harms associated with it may be
   mitigated, or the individual may accept the risk of harm.

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4.2.1.  Combined Security-Privacy Threats

4.2.1.1.  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 to the perpetration of
   violence against the individual.  The individual need not be aware of
   the surveillance for it to impact privacy -- the possibility of
   surveillance may be enough to harm individual autonomy.

   Surveillance can be conducted by observers or eavesdroppers at any
   point along the communications path.  Confidentiality protections (as
   discussed in [RFC3552] Section 3) 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].

4.2.1.2.  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), 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.

4.2.1.3.  Intrusion

   Intrusion consists of invasive acts that disturb or interrupt one's
   life or activities.  Intrusion can thwart individuals' desires to be
   let alone, sap their time or attention, or interrupt their
   activities.

   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.

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4.2.1.4.  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.  For
   example, as [RFC6269] notes, abuse mitigation is often conducted on
   the basis of 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 case 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.

4.2.2.  Privacy-Specific Threats

4.2.2.1.  Correlation

   Correlation is the combination of various pieces of information
   related to an individual.  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 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].  In RFC 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

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   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).

   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.

4.2.2.2.  Identification

   Identification is the linking of information to a particular
   individual.  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 guarantee 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 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

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   in identification depending on the information about the initiator
   that is available via the protocol mechanism or other channels.

4.2.2.3.  Secondary Use

   Secondary use is the use of collected information 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 use can
   generate uncertainty over how one's information will be used in the
   future, potentially discouraging information exchange in the first
   place.

   One example of secondary use would be a network access server that
   uses an initiator's access requests to track the 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.

4.2.2.4.  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 in
   the next section).  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.

4.2.2.5.  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 about individuals' ability to control how information
   about them is collected and used.

   The most common way for Internet protocols to be involved in limiting

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   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.

   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.

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5.  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 in Section 4.2.  This section describes three categories of
   relevant mitigations: (1) data minimization, (2) user participation,
   and (3) security.

5.1.  Data Minimization

   Data minimization refers to collecting, using, disclosing, and
   storing the minimal data necessary to perform a task.  The less data
   about individuals that gets exchanged in the first place, the lower
   the chances of that data being 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 only to what is necessary
   (collection limitation) is the most straightforward way to ensure
   that use of the data does not incur privacy harm.  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 pseudonymous or anonymous identifiers helps to weaken
   the link between an individual and his or her communications.
   Allowing for the periodic creation of new 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.

   (Threats mitigated: surveillance, stored data compromise,
   correlation, identification, secondary use, disclosure)

5.1.1.  Anonymity

   To enable anonymity of an individual, there must exist a set of
   individuals with potentially the same attributes.  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.

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   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, consider RFC 3325 (P-Asserted-Identity, PAI)
   [RFC3325], an extension for the Session Initiation Protocol (SIP),
   that allows an individual, such as a 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 other personal data may
   be inferred from the other SIP protocol payloads.  This caveat makes
   the analysis of the specific protocol extension easier but cannot be
   assumed when conducting analysis of an entire architecture.

5.1.2.  Pseudonymity

   In the context of IETF protocols, almost all identifiers are
   pseudonyms since there is typically no requirement to use real names
   in protocols.  However, in certain scenarios it is reasonable to
   assume that real 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 it is important 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.

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5.1.3.  Identity Confidentiality

   An initiator has identity confidentiality when any party other than
   the recipient cannot sufficiently identify the initiator within the
   anonymity set.  In comparison to anonymity and pseudonymity, identity
   confidentiality is concerned with eavesdroppers and intermediaries.

   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 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.  To address this treat, as discussed in RFC 4282 [RFC4282],
   the user's identity can be hidden against these eavesdroppers and
   intermediaries with the cryptography support by EAP methods.
   Identity confidentiality has become a recommended design criteria for
   EAP (see [RFC4017]).  EAP-AKA [RFC4187], for example, protects the
   EAP peer's identity against passive adversaries by utilizing temporal
   identities.  EAP-IKEv2 [RFC5106] is an example of an EAP method that
   offers protection against active attackers with regard to the
   individual's identity.

5.1.4.  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 authentication
   and authorization information to entities (relying parties) that
   require authentication or authorization of individuals in order to
   process transactions or grant access.  To facilitate the provision of
   authentication and authorization, an identity provider will usually
   go through a process of verifying the individual's identity and
   issuing the individual a set of credentials.  When an individual
   seeks to make use of a service provided by the relying party, the
   relying party relies on the authentication and authorization
   assertions provided by its identity provider.

   Such systems have the ability to support a number of properties that
   minimize data collection in different ways:

      Relying parties can be prevented from knowing the real or
      pseudonymous identity of an individual, since the identity
      provider is the only entity involved in verifying identity.

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      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
      requires that each relying party use a different means of
      identifying individuals.

      The identity provider can be prevented from knowing which relying
      parties an individual interacted with.  This requires avoiding
      direct communication between the identity provider and the relying
      party at the time when access to a resource by the initiator is
      made.

5.2.  User Participation

   As explained in Section 4.2.2.5, data collection and use that happens
   "in secret," without the individual's knowledge, is apt to violate
   the individual's expectation of privacy and may create incentives for
   misuse of data.  As a result, privacy regimes tend to include
   provisions to support 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.
   (Threats mitigated: surveillance, secondary use, disclosure,
   exclusion)

5.3.  Security

   Keeping data secure at rest and in transit is another important
   component of privacy protection.  As they are described in [RFC3552]
   Section 2, 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

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   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).

   (Threats mitigated: surveillance, stored data compromise,
   misattribution, secondary use, disclosure, intrusion)

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6.  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 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.

   The framework is divided into four sections that address each of the
   mitigation classes from Section 5, plus a general section.  Security
   is not fully elaborated since substantial guidance already exists in
   [RFC3552].

6.1.  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.

6.2.  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?

      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

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      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?

      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
      to delete or replace identifiers by default?

      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?

      g.  Retention.  Do the protocol or its anticipated uses require
      that the information discussed in (a) or (b) be retained by
      recipients, intermediaries, or enablers?  Is the retention
      expected to be persistent or temporary?

6.3.  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 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 (contractual or
      otherwise) with intermediaries that govern the use of the
      information?

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      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?

6.4.  Security

      a.  Surveillance.  How do the protocol's security considerations
      prevent surveillance, including eavesdropping and traffic
      analysis?

      b.  Stored data compromise.  How do the protocol's security
      considerations prevent or mitigate stored data compromise?

      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?

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7.  Example

   The following section gives an example of the threat analysis and
   threat mitigation 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 to provide 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 SIP-
   based SIMPLE presence system [RFC3261] 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 in RFC 2778 and RFC 3859 is a
   mediated one.  Clients (presentities in RFC 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 explicit 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

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   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 conceivable 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 real 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.  Connections between the server and all publishers
   and consumers of presence data are moreover 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.

   Moreover, the sensitivity of presence information is not limited to
   the disposition and capability to communicate.  Capability 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

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   preserve 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 is worth it, for
   presence.  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 runs 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 provide 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.
   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

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   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, which may
   lead to unexpected results.  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 STUN and TURN, they add complexity to the overall
   system.

   Consequently, mediation is a difficult feature of the presence
   architecture to remove, and due especially to the requirement for
   composition it is hard to minimize the data shared with
   intermediaries.  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 the user participation over the activities of the presence
   server.  This work began in the GEOPRIV working group, with controls
   on location privacy, as location of users is perceived as having
   especially sensitive properties.  With the aim to meet 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 PIDF-LO that always travel with 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 [1],
   namely the usage of a limited number of conditions (such as 'Share
   Alike' [2]).  Unlike Creative Commons, the GEOPRIV working group did
   not, however, initiate work to produce legal language nor to 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 retention and retransmission elements were envisioned as the only
   first and most essential examples of preference expression in sharing
   presence.  The PIDF object was designed for extensibility, and the
   rulesets created for 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

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   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
   (defined in [RFC4745]) framework.  This language allows one to
   express ways to control the distribution of information as simple
   conditions, actions, and transformations rules expressed in an XML
   format.  Common Policy itself is an abstract format which needs to be
   instantiated: two examples can be found with the Presence
   Authorization Rules [RFC5025] and the Geolocation Policy
   [I-D.ietf-geopriv-policy].  The former provides additional
   expressiveness for presence based systems, while the latter defines
   syntax and semantic 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, nor to 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.  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.

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8.  Security Considerations

   This document describes privacy aspects that protocol designers
   should consider in addition to regular security analysis.

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9.  IANA Considerations

   This document does not require actions by IANA.

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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, Christine
   Runnegar, Lucy Lynch, Trent Adams, Mark Lizar, Martin Thomson, Josh
   Howlett, Mischa Tuffield, S. Moonesamy, Ted Hardie, Zhou Sujing,
   Claudia Diaz, Leif Johansson, and Klaas Wierenga.

   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.

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11.  Informative References

   [Chaum]    Chaum, D., "Untraceable Electronic Mail, Return Addresses,
              and Digital Pseudonyms", Communications of the ACM , 24/2,
              84-88, 1981.

   [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", available at
              (November 2010) ,
              https://wcd.coe.int/ViewDoc.jsp?Ref=CM/Rec%282010%2913,
              2010.

   [EFF]      Electronic Frontier Foundation, "Panopticlick", 2011.

   [I-D.iab-identifier-comparison]
              Thaler, D., "Issues in Identifier Comparison for Security
              Purposes", draft-iab-identifier-comparison-02 (work in
              progress), May 2012.

   [I-D.ietf-geopriv-policy]
              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", draft-ietf-geopriv-policy-26 (work
              in progress), June 2012.

   [OECD]     Organization for Economic Co-operation and Development,
              "OECD Guidelines on the Protection of Privacy and
              Transborder Flows of Personal Data", available at
              (September 2010) , http://www.oecd.org/EN/document/
              0,,EN-document-0-nodirectorate-no-24-10255-0,00.html,
              1980.

   [PbD]      Office of the Information and Privacy Commissioner,
              Ontario, Canada, "Privacy by Design", 2011.

   [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.

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   [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.

   [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.

   [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.

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   [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.

   [RFC6350]  Perreault, S., "vCard Format Specification", RFC 6350,
              August 2011.

   [Solove]   Solove, D., "Understanding Privacy", 2010.

   [Tor]      The Tor Project, Inc., "Tor", 2011.

   [1]  <http://creativecommons.org/>

   [2]  <http://wiki.creativecommons.org/Share_Alike>

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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.at

   Bernard Aboba
   Microsoft Corporation
   One Microsoft Way
   Redmond, WA  98052
   US

   Email: bernarda@microsoft.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

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   Marit Hansen
   ULD Kiel

   Email: marit.hansen@datenschutzzentrum.de

   Rhys Smith
   JANET(UK)

   Email: rhys.smith@ja.net

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