Consultation on revised IETF Privacy Statement

IETF Executive Director <exec-director@ietf.org> Wed, 04 December 2019 00:24 UTC

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Subject: Consultation on revised IETF Privacy Statement
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Date: Tue, 03 Dec 2019 16:24:48 -0800
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The IETF Administration LLC has reviewed the IETF Privacy Statement [1] and proposes to introduce a new version [2].  The main reasons for this are to support the introduction of web analytics, to support the collection of demographic data in surveys and to make the whole statement more legally compliant, easier to read and clearer to understand.  This new version contains the following changes, which have been reviewed by our privacy counsel:

1. Significant reordering, moving of text and changing of headings, with minimal change in meaning, in order to make the statement clearer and easier to understand.

2. The scope statement has changed from covering the IETF/IRTF/IAB to identifying the specific groups that can legally be considered data controllers in various data protection regimes, namely the LLC, IESG, IAB, IRSG and RFC Editor, and being clear that their activities form a single privacy context.  The scope uses “IETF” as a collective term for all these groups, even though that is not structurally accurate, as attempting to convey accurate structure in this statement is too complex. “This statement sets out the privacy and data protection policy of the following related organizations and groups: the IETF Administration LLC ("LLC"); the Internet Engineering Steering Group (“IESG”); the Internet Architecture Board ("IAB"); the Internet Research Steering Group ("IRSG"); and the RFC Editor (each a "Party"), which are collectively referred to in this policy as  the Internet Engineering Task Force ("IETF") and whose activities constitute a single privacy context.“

3. The existing version contains a number of references to the Internet Society (ISOC) given the legal structure that existed before the creation of the IETF Administration LLC.  Those references have all been removed as data will no longer be shared with ISOC and a statement added for the avoidance of doubt: “For the avoidance of doubt, this policy does not apply to the Internet Society (“ISOC”) and its activities and practices constitute a separate privacy context. ISOC should be regarded as a third-party for the purposes of this policy.”

4. Two new elements have been added to the list of data that may be made public, which reflects existing practice.  These are “metadata related to the time and frequency of your interactions with any IETF system” and “message headers”.

5. Added an additional example of personal data to be clear that email message headers contain a lot of data “the IP address of a message sender and details of the device or service used to send the message, as found in email headers”.

6. Added a clear statement that we do not sell data "We do not sell your Personal Data".

7. Added a new bullet on what data we collect to cover web analytics and a new paragraph that covers what we intend to do with that data.  The bullet is “information provided when you interact with any IETF website” and the paragraph is “We track your usage of our websites in order to understand how our websites are used and how we can improve them.  We do this using Javascript based tracking code, which collects a limited set of technical data.  If Javascript is disabled or not available in your browser then this tracking will not take place and your usage of our websites should not be affected.”

8. Section on Do Not Track (DNT) made clearer as previous version required you to read the specification to understand it “We do not enable or participate in any third-party tracking of your website activity.  As no third-party tracking is enabled on our website, our websites do not alter their behavior according to the value of a browser Do Not Track (DNT) setting.”

9. The section on the use of cookies for online transactions has been made clearer “When you log into one of our websites or initiate an online transaction through one of our websites then we may use cookies to uniquely identify you during that session, to record your preferences and to simplify the establishment of new sessions.  If you disable your web browser's ability to accept cookies you will still be able to browse the site but authenticated and transactional services may not function.”

10. A new section has been added to explain that if we collect demographic information in a survey then that will only be published in an aggregated form that does not allow individual identification.  This addition is not needed to enable collection of demographics, we can do that anyway, it is solely to explain what we do if we do collect it.  “We may ask you to provide demographic information (e.g. age, sex, country of residence) in surveys or other information gathering activities.  You are not required to provide that information and your disclosure of that information to us is voluntary.  We do not disclose the demographic information of individuals.  We may publish aggregated information using demographic data as one dimension, in which case we will aggregate at a sufficient level to prevent disaggregation or deanonymization.“

This email now begins a two week consultation on this revised statement, closing on Wednesday 18 December.

If you have any comments or questions then you can submit those by any of the following methods:

* Raising an issue on the Github repository https://github.com/ietf-llc/ietf-privacy-statement-consultation 
* Direct to me at exec-director@ietf.org
* To the ietf@ietf.org list

[1]  https://ietf.org/privacy-statement/
[2]  https://github.com/ietf-llc/ietf-privacy-statement-consultation/blob/master/DRAFT%20IETF%20Privacy%20Statement%202019.md 

-- 
Jay Daley
IETF Executive Director
exec-director@ietf.org