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ANEC-ICT-2006-W3C-003March 31, 2006 W3C Privacy P3P Draft version 1.1 ANEC’s comments on Last Call version of February 10, 2006 page 1 of 5 ANEC’s comments on; Title Last Call version of: “The Platform for Privacy Preferences 1.1 (P3P1.1); Specification W3C Working Draft, 10 February 2006” (available at http://www.w3.org/TR/P3P11/) Source ANEC Contacts Bruno von Niman, ANEC W3C Representative ANEC_W3CRep_Bruno@vonniman.com To P3P Specification Working Group (Privacy Activity, W3C Technology & Society Domain) Document for: Decision x Discussion x Information 1. Introduction and scope We hereby submit ANEC’s (www.anec.org) comments on the Last Call version of the working draft: “The Platform for Privacy Preferences 1.1 (P3P1.1); Specification W3C Working Draft, 10 February 2006”. As a general standpoint, ANEC considers Web Privacy to be of very high importance to consumers, due to the importance of the security issues involved. We appreciate the currently ongoing efforts to make a privacy preferences platform available and further extend and improve them through the currently ongoing update. Our comments provided below are in a positive spirit. They are intended to provide consumer-centric guidance and requirements on how to further improve and extend the coverage and usefulness of the present draft. The comments reflect issues relevant to ...

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Nombre de lectures	21
Langue	English

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ANEC-ICT-2006-W3C-003

March 31, 2006

W3C Privacy P3P Draft version 1.1

ANEC’s comments on Last Call version of February 10, 2006

page 1 of 5

Title

ANEC’s comments on;

Last Call version of: “The Platform for Privacy Preferences 1.1

(P3P1.1); Specification W3C Working Draft, 10 February 2006”

(available at http://www.w3.org/TR/P3P11/)

Source

ANEC

Contacts

Bruno von Niman, ANEC W3C Representative

ANEC_W3CRep_Bruno@vonniman.com

P3P Specification Working Group

(Privacy Activity, W3C Technology & Society Domain)

Document for:

Decision

Discussion

Information

1. Introduction and scope

We hereby submit ANEC’s (

www.anec.org

) comments on the Last Call version of the working

draft: “The Platform for Privacy Preferences 1.1 (P3P1.1); Specification W3C Working Draft,

10 February 2006”.

As a general standpoint, ANEC considers Web Privacy to be of very high importance to

consumers, due to the importance of the security issues involved. We appreciate the

currently ongoing efforts to make a privacy preferences platform available and further extend

and improve them through the currently ongoing update.

Our comments provided below are in a positive spirit. They are intended to provide

consumer-centric guidance and requirements on how to further improve and extend the

coverage and usefulness of the present draft. The comments reflect issues relevant to

consumers, discussed and agreed in ANEC.

ANEC-ICT-2006-W3C-003

March 31, 2006

W3C Privacy P3P Draft version 1.1

ANEC’s comments on Last Call version of February 10, 2006

page 2 of 5

2. Comments

Consumers must be able to understand and express their privacy preferences. They must

also be confident that their personal and private information is not used in ways or for

purposes they disapprove. Consumers also need status visibility and feedback on whether

their privacy preferences are being respected.

Most consumers will not wish to make repeated and explicit choices on whether their privacy

preferences are being respected, each time they access or use a communication or

information service. Mechanisms such as P3P that attempt to compare users' privacy

preferences against a web site's published privacy policy therefore provide a useful

approach.

The defined privacy preferences should apply across the widest possible range of clients,

services and devices and to fixed and mobile access, in a consistent way.

2.1 Definition and set-up of the privacy preferences

ANEC believes that the definition and set-up of user preferences is far too complex to most

consumers. There is evidence from various sources that a majority of consumers does not

understand the meaning of terms and the dependencies between various security and

privacy solutions used in the same device used to access the Web and can therefore not

properly configure their options. In addition, consumers will have considerable difficulties

understanding the meaning of their actions and their possible consequences. Therefore, we

wonder if there are ongoing efforts to further simplify the use of symbols, terminology and

configuration. Furthermore, we would welcome two notes, elaborating upon:

•

the accessibility of privacy preference settings in coordination with the WAI WG

currently developing WCAG 2.0; and

•

the applicability of the above to mobile access and the Mobile Web best Practices

Last Call draft.

Several difficulties can be overcome if a well defined set of default settings can be presented

to consumers. Such an extension could provide a limited number of levels (e.g. a scale

ranging from minimum to maximum privacy preferences) consumers could simply choose

from, without going through larger number parameters.

Furthermore, ANEC believes than an initiative should be taken to better explain the relations

to additional privacy preferences (e.g. the prevention of use of secondary data).

In addition, P3P should have three ordered components from the consumer perspective,

E3E:

Educate

- consumers need to understand the issues so that they can express their

requirements (not in technical detail but in general overview);

ANEC-ICT-2006-W3C-003

March 31, 2006

W3C Privacy P3P Draft version 1.1

ANEC’s comments on Last Call version of February 10, 2006

page 3 of 5

Enable

- consumers (regardless of their ability/disability, browser used and sites

visited) need to be able to easily set up or select their privacy requirements; and

Enforce

- if the consumer is in control, they need to know if/when a site is not going to

meet their requirements before they give information so that the consumer can choose

to enforce their own standards. We believe that there is a cross-area issue here of

both the language used and the method of presentation - users of the web appear to

increasingly have to click on (and accept) pages of text that they could not reasonably

read and so do not bother to read).

2.2 Access for all

The population in most Western societies is aging, while becoming more literate in accessing

and using the Web. In the mean time, more children are using the Web. Therefore, three

points need to be made:

1. It should be possible to make the settings of the privacy preferences and receive

feedback through multiple, universal user interface modalities (e.g. text and speech);

2. In order to provide access for all, it should be possible to access the set up and use of

the privacy preferences through peripheral, assistive technology devices, when these

are required; and

3. An age certificate or verification mechanisms should be developed to support

children’s privacy preferences, typically defined and set up by their parents or carers.

Some additional, useful guidance is provided in “CEN/CENELEC Guide 6: “Guidelines for

standards developers to address the needs of older persons and persons with disabilities”.

2.3 Browser support

The current, updated draft should provide more support in how to ensure consumers (and

how to provide feedback to them) about Web sites acting according to their defined privacy

preferences, regardless of the access used (fixed or mobile).

Furthermore, ANEC believes that the specifications should ensure that consumers are

informed about the applicability of their privacy preferences

before

they release personal

information to any other party.

Also, a mechanism to ensure that Web sites act according the defined consumer preferences

(or informing about deviations) should be introduced.

In addition, as consumers have the free choice of the browser they want to use, P3P should

always be compatible with all browser technologies (even those used by other devices than

the PC).

ANEC-ICT-2006-W3C-003

March 31, 2006

W3C Privacy P3P Draft version 1.1

ANEC’s comments on Last Call version of February 10, 2006

page 4 of 5

2.4 Terminology, multicultural issues and languages

Although addressed in chapter 6.2 “Plain Language Translations of P3P Vocabulary

Elements”, the current version maintains the use of technical and therefore complicated

terminology.

The set of "plain language" translations provided, designed to convey the essence of each

element in relatively simple language without conflicting with the normative definition, should

be improved further. Terms and expressions such as the ones listed below (examples only,

not an exhaustive listing) should be improved further:

•

“Find out how to opt-in or opt-out at…”

•

“We allow you to access some of our information identified with you, but not your

contact information”

•

“To aid in historical preservation as governed by a law or policy described in this

In addition, translations to all official European languages (EU and EFTA) should be

provided.

Considerations relating to multicultural issues in the use of ICT (e.g. language settings and

preferences or the privacy preference status icon) should be addressed.

2.5 Portability and security

Even if the PC is the dominant device used to access the Web, European consumers access

the Web through a variety of (own, as well as shared or even public) devices. Some

consumers may also use multiple devices. Therefore, ANEC believes that important features

not covered by the present draft such as the ones listed below should be addressed by this

or future versions:

•

Negotiation processes, compatibilities and data transfer;

•

Security of personal data in transit or storage;

•

Choice of privacy policies (may vary, depending on the device and infrastructure used

for access);

•

Transfer of user data to apply to services (to improve the consumer experience);

•

Support of device-specific settings.

Another issue of specific importance to consumers is the security of payments. Today, SSL

(Secure Sockets Layer) and Secure HTTP (S-HTTP) provide good complementary means

and are established standards used in many products. These should integrate well and be

kept compatible with the present and future P3P specifications.

ANEC-ICT-2006-W3C-003

March 31, 2006

W3C Privacy P3P Draft version 1.1

ANEC’s comments on Last Call version of February 10, 2006

page 5 of 5

Last but not least, we would like to stress the importance of coordination in this area with

other W3C activities and working groups, in order to integrate well by means of compatibility

and interoperability with recommendations from, e.g., the Web Accessibility Initiative (WAI)

WCAG 2.0 and the Mobile Web Initiative (MWI) Mobile Web Best Practices Last Call

document.

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