29/04/2021 Device API Privacy Requirements

Device API Privacy Requirements

W3C Working Group Note 29 June 2010
This version:
http://www.w3.org/TR/2010/NOTE-dap-privacy-reqs-20100629/
Latest version:
http://www.w3.org/TR/dap-privacy-reqs/
Latest editor's draft:
http://dev.w3.org/2009/dap/privacy-reqs/
Editors:
Alissa Cooper, Center for Democracy and Technology
Frederick Hirsch, Nokia
John Morris, Center for Democracy and Technology

Copyright © 2010 W3C® (MIT, ERCIM, Keio), All Rights Reserved. W3C liability, trademark and document
use rules apply.

Abstract
This document provides definitions, use cases, and requirements for making device APIs
more privacy-friendly.

Status of This Document

This section describes the status of this document at the time of its publication. Other
documents may supersede this document. A list of current W3C publications and the
latest revision of this technical report can be found in the W3C technical reports index at
http://www.w3.org/TR/.

This is the first public Working Group Note of the Device API Privacy Requirements. This
document is expected to be further updated based on both Working Group input and
public comments. The Working Group anticipates to eventually publish a stabilized
version of this document as a W3C Working Group Note.

This document was published by the Device APIs and Policy Working Group. If you wish
to make comments regarding this document, please send them to public-device-
apis@w3.org (subscribe, archives). All feedback is welcome.

Publication as a Working Group Note does not imply endorsement by the W3C
Membership. This is a draft document and may be updated, replaced or obsoleted by
other documents at any time. It is inappropriate to cite this document as other than work
in progress.

This document was produced by a group operating under the 5 February 2004 W3C
Patent Policy. W3C maintains a public list of any patent disclosures made in connection
with the deliverables of the group; that page also includes instructions for disclosing a
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patent. An individual who has actual knowledge of a patent which the individual believes
contains Essential Claim(s) must disclose the information in accordance with section 6 of
the W3C Patent Policy.

Table of Contents
1. Introduction
1.1 Architectural Approach
1.2 Privacy Principles relevant to APIs
2. Requirements for API Definitions
2.1 Notice
2.2 Consent
2.3 Minimization
2.4 Control
2.5 Access
3. Requirements related to User Expectations of Data Use
3.1 Retention
3.2 Secondary Use
3.3 Sharing
A. Acknowledgements
B. References
B.1 Normative references
B.2 Informative references

1. Introduction
Privacy considerations are important to Device APIs, since misuse of information
exposed by the APIs can have potentially harmful financial, physical safety, reputational
and other impacts. Privacy needs a systemic solution that includes functional
requirements on user agents, web sites and other components of the system, since any
opportunity for misuse of private information is a risk. Addressing privacy may include
functional requirements in technical standards, laws and regulations, and best practices.

While privacy is an important consideration for all APIs, privacy risks may vary according
to the information exposed by an individual API. For example, inappropriate disclosure of
contacts or location information could create serious personal safety issues in a broad
range of cases, while disclosure of certain system information might create privacy risks
in fewer contexts.

1.1 Architectural Approach

Privacy is a broad topic with various aspects that involve different parties in a system. In
order to be clear which aspects are addressed and how, we take an architectural
approach of breaking down the problem into smaller pieces. This should provide clarity
and enable privacy-respecting solutions that can be adopted. We have identified the
following pieces:

Defining APIs in such a way that they are as “naturally” privacy-respecting as

possible
This is similar to writing APIs in such a way that they are security-friendly; you can't
keep people from making mistakes, but you can make it easier and more natural to
be privacy-respecting through the API design. An example is supporting the
concept of Minimization by designing APIs that return the minimum data needed for
a task, such as only obtaining address fields when an address is needed.

Requiring from user agents what they can realistically enforce

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User agents are crucial to ensuring that user privacy is protected, but this capability
must take implementation and adoption considerations into account. User agent
design decisions can be separated to a large degree from API design decisions.

Empowering users to express privacy preferences

This can be hard to manage technically but might be possible through a simpler
approach of defining and agreeing upon a small set of privacy preferences, similar
to Creative Commons copyright licenses, that users can attach to their data.
Defining a simple vocabulary for privacy could enable privacy rulesets that can be
referenced by URI. Other people have had this idea as well.

Conducting education and outreach, similar to the accessibility efforts

WAI and the Web community at large have done a great job raising awareness
about accessibility issues, and while implementations are not perfect, their effort
has had a very measurable impact. There is therefore experience to be tapped in
such an approach for the parts of the problem that depend on convincing people to
do the right thing (which in some cases can be wide-ranging, including making
script libraries support the solution directly, or having various organizations enforce
it internally).

1.2 Privacy Principles relevant to APIs

Privacy protections are frequently understood as a set of principles or elements (one
such set is described in [PRIVACY-ISSUES-GEO]). The core elements of privacy that are
relevant to Device APIs, user agents that support the APIs, and applications that use the
APIs are as follows:

Notice: Informing users about the data collected through Device APIs

Consent: Obtaining user agreement to sharing data through Device APIs

Minimization: Limiting the amount and level of detail of data collected through
Device APIs

Control: Allowing users to control access to their data once they have consented to
having it collected through Device APIs

Access: Providing users with access to information about the data that has been
collected about them through Device APIs

Retention: Limiting how long applications retain data that was collected through
Device APIs

Secondary Use: Limiting applications from using data collected through Device
APIs for purposes other than the purpose for which it was collected

Sharing: Limiting applications from sharing data collected through Device APIs with
third parties

These elements will each need to be approached in different ways. Approaches include
specific requirements on individual APIs, conveying user expectations together with the
data itself, and/or documenting best practices for application and content developers.
Certain approaches are better suited to safeguarding certain privacy elements than
others.

This document provides specific requirements for individual APIs, addressing the
elements that are most relevant to API definitions: notice, consent, minimization, control,
and access. Requirements involving user expectations, which primarily address
retention, secondary use, and sharing, will be documented separately. Best practices for
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developers will also be documented separately, covering notice, minimization, control,

access, retention, secondary use, and sharing in the application developer context.

The following table summarizes the breakdown of how each element is covered:

Privacy Requirements for Requirements related to User Best practices

Element API Definitions Expectations of Data Use for developers
Notice X X
Consent X X
Minimization X X
Control X X
Access X X
Retention X X
Secondary
X X
Use
Sharing X X

The privacy requirements for individual APIs are provided in the next section. The
requirements described in this document are intended to be applicable to device APIs
both in the context of widgets and web applications.
Issue

The breakdown described above foreshadows the idea of providing API hooks that
allow users to attach their expectations/preferences/policies about privacy to the
data they share through the APIs. Attaching policy rules to the data that get shared
can provide a legal basis for enhancing the control users have over their data once
they are shared; but doing so create the following challenges:

getting the user to understand and set rules on sharing their information, and
to understand that limits of those rules, is hard;
if users set their preferences in the user agent, they may expect the user
agent to enforce these preferences while it cannot actually control the data
flow once the data has been transmitted;
developers may ignore policy rules sent along with the data they're actually
interested in (at the risk of encountering legal or market consequences)

2. Requirements for API Definitions

Many of the requirements listed here are recommendations (SHOULDs) rather than
absolute requirements (MUSTs). In many cases this is because making a requirement
absolute is appropriate for only a subset of the APIs, but not every API. As appropriate,
individual APIs may place stronger normative requirements on user agents than the
requirements in this document place on APIs.

2.1 Notice

Making sure that users understand the implications of using an application that relies on
a Device API is fundamental to ensuring the protection of their data. The following
requirements can help to make sure that users are properly notified:

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APIs make it possible for user agents to notify users that their data is being
collected via the API. This notification identify the application (for example, by
displaying its document origin [HTML5]) and the precise data being collected.

APIs provide support for visual indicator(s) that data is being collected via
the APIs.
Issue
Should the APIs have a hook for applications to convey the intended usage of the
data? If they do, should it be a required parameter? And how can this information be
conveyed without misleading the user about the trustworthiness of that information?

2.2 Consent
The semantics of some APIs are defined such that user interaction is essential to make
use of the API. An example is a camera API that enables the user to take a photograph,
but is defined to require the user to press a shutter key to take the photograph. Another
example is an API that produces a message template, but requires the user to press
"send" to actually send the message.

Such user actions constitute implicit consent to collection of data via the API, since the
user has a choice to perform these actions and doing so implies consent for the
application to access the associated Device Capabilities. In such situations where it is
obvious that performing the action involves sharing data with the application and the
application’s intended use of the data is also obvious, additional dialogs that prompt
users for consent may not be necessary.

Device APIs may also be defined such that consent must be explicit, not implicit.
Examples are a camera API that takes a photograph without user involvement, or a
messaging API that sends a message without the user pressing "send." In these cases
dialogs may be required.

To ensure that data is not collected without users knowing or realizing, APIs should be
designed with the presumption that the explicit consent model will be used, and should
explain the specific circumstances under which implicit consent may be acceptable. This
gives rise to the following requirements:

APIs make it possible for user agents to obtain user consent before sharing
any data via the APIs.

APIs be defined in such a way that explicit consent is assumed, and they
articulate the circumstances under which implicit consent is acceptable.

An important caveat to the consent model supported by Device APIs relates to data
about other people that the user may have on his or her device and be able to share via
the APIs (other people’s contact or calendar information, for example). A user should not
be able to consent through the Device APIs to use of other people’s information beyond
the original interaction with the API. Thus, for example, a user should be able to consent
to have an application contact another person mentioned in a calendar entry (perhaps to
say “I am running late”), but the user should not also be able to consent to have the
application make later use of the person’s contact information (perhaps to send
marketing messages to that person). This caveat should be conveyed where appropriate
in the APIs, best practices, and other Device APIs documents.

2.3 Minimization

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To reduce the risks of over-exposing users data, it is important to design APIs so that
Web developers can request as little information as they need to accomplish their goals.

An example use case is a social networking case where the contacts API is used to
contacts who are also members of a social network. Email addresses serve as the social
network handles. In this case limiting results to the addresses and not other personal
information is an example of minimization.

This gives rise to the following requirements:

APIs make it easy to request as little information as required for the intended
usage.

For instance, an API call should require specific parameters to be set to obtain
more information, and should default to little or no information.

APIs make it possible for user agents to convey the breadth of information
that the requester is asking for.

For instance, if a developer only needs to access a specific field of a user address
book, it should be possible to explicitly mark that field in the API call so that the
user agent can inform the user that this single field of data will be shared.

APIs make it possible for user agents to let the user select, filter, and
transform information before it is shared with the requester.

The user agent can then act as a broker for trusted data, and will only transmit data
to the requester that the user has explicitly allowed.

2.4 Control
Given the sensitivity of the data made available through Device APIs, it is important for
users to be able to control which applications have access to that data. The following
requirements ensure that (1) users have control over their data even after they have
shared it with an application, and (2) users have robust controls over which applications
can obtain their data to begin with:

APIs make it possible for user agents to support the revocation of user
consent to sharing of data via the APIs.

APIs support the ability for user agents to allow users to whitelist trusted
applications and blacklist untrusted applications.

2.5 Access
Notice and control cannot be fully implemented unless users can review how they have
shared data in the past. The following requirements suggest how APIs can support
users’ access to this information:

APIs make it possible for user agents to allow users to view the
applications with whom they have shared data.

APIs make it possible for user agents to allow users to view, edit, and
delete the history of the user's data sharing with each.

3. Requirements related to User Expectations of Data Use

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Users may have expectations of how their data is used, in particular related to data
retention, use for other purposes, and sharing. How applications specify how they plan to
meet these expectations (application policy), how users express their desires (user
policy) and constraints on data use may all be related to managing these expectations. A
license approach similar to Creative Commons may offer a simple manner to address
these requirements.
Issue

This section does not currently contain any requirements. Because retention,
secondary use, and sharing are largely out of the control of the APIs, it's not entirely
clear that it makes sense to have any API requirements about these aspects. On the
other hand, one can envision a requirement that supports the ruleset model, such
as:

APIs support a mechanism for users to convey their preferences about

retention, secondary use, and sharing to applications in the context of an API
interaction.

Likewise, if we wanted the APIs to support applications' ability to convey their

intended policies about these aspects, we could have a requirement like:

APIs support a mechanism for applications to convey their policies about

retention, secondary use, and sharing to users prior to or during API
interactions.

3.1 Retention
Retention is about to user expectations about how long data they provide will be
retained, and whether applications must dispose of collected data after fulfilling the
purpose for which it was collected.

3.2 Secondary Use

Secondary Use is about to user expectations regarding whether applications can use
data for purposes other than that for which the data was collected.

3.3 Sharing
Sharing is about user expectations on how data will be shared. Once data have been
made available to a requester, the requester is in a position to store and redistribute
these data, with or without the user consent. Granularity of data shared is an important
aspect of sharing.

A. Acknowledgements
B. References
B.1 Normative references

No normative references.

B.2 Informative references

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[HTML5]
Ian Hickson; David Hyatt. HTML 5. 4 March 2010. W3C Working Draft. (Work in
progress.) URL: http://www.w3.org/TR/2010/WD-html5-20100304/

[PRIVACY-ISSUES-GEO]
Doty, N. Mulligan, D. Wilde, E. Privacy Issues of the W3C Geolocation API. UC
Berkeley School of Information. 24 February 2010. URI:
http://escholarship.org/uc/item/0rp834wf

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