Internet Architecture Board (IAB)                              A. Cooper
Request for Comments: 6973                                           CDT
Category: Informational                                    H. Tschofenig
ISSN: 2070-1721                                   Nokia Siemens Networks
                                                                B. Aboba
                                                                   Skype
                                                             J. Peterson
                                                           NeuStar, Inc.
                                                               J. Morris

                                                               M. Hansen
                                                                     ULD
                                                                R. Smith
                                                                   Janet
                                                               July 2013


             

Privacy Considerations for Internet Protocols

Abstract This document offers guidance for developing privacy considerations for inclusion in protocol specifications. It aims to make designers, implementers, and users of Internet protocols aware of privacy- related design choices. It suggests that whether any individual RFC warrants a specific privacy considerations section will depend on the document's content. Status of This Memo This document is not an Internet Standards Track specification; it is published for informational purposes. This document is a product of the Internet Architecture Board (IAB) and represents information that the IAB has deemed valuable to provide for permanent record. It represents the consensus of the Internet Architecture Board (IAB). Documents approved for publication by the IAB are not a candidate for any level of Internet Standard; see Section 2 of RFC 5741. Information about the current status of this document, any errata, and how to provide feedback on it may be obtained at http://www.rfc-editor.org/info/rfc6973. Cooper, et al. Informational [Page 1]

RFC 6973 Privacy Considerations July 2013 Copyright Notice Copyright (c) 2013 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. Cooper, et al. Informational [Page 2]

RFC 6973 Privacy Considerations July 2013 Table of Contents 1. Introduction ....................................................4 2. Scope of Privacy Implications of Internet Protocols .............5 3. Terminology .....................................................6 3.1. Entities ...................................................7 3.2. Data and Analysis ..........................................8 3.3. Identifiability ............................................9 4. Communications Model ...........................................10 5. Privacy Threats ................................................12 5.1. Combined Security-Privacy Threats .........................13 5.1.1. Surveillance .......................................13 5.1.2. Stored Data Compromise .............................14 5.1.3. Intrusion ..........................................14 5.1.4. Misattribution .....................................14 5.2. Privacy-Specific Threats ..................................15 5.2.1. Correlation ........................................15 5.2.2. Identification .....................................16 5.2.3. Secondary Use ......................................16 5.2.4. Disclosure .........................................17 5.2.5. Exclusion ..........................................17 6. Threat Mitigations .............................................18 6.1. Data Minimization .........................................18 6.1.1. Anonymity ..........................................19 6.1.2. Pseudonymity .......................................20 6.1.3. Identity Confidentiality ...........................20 6.1.4. Data Minimization within Identity Management .......21 6.2. User Participation ........................................21 6.3. Security ..................................................22 7. Guidelines .....................................................23 7.1. Data Minimization .........................................24 7.2. User Participation ........................................25 7.3. Security ..................................................25 7.4. General ...................................................26 8. Example ........................................................26 9. Security Considerations ........................................31 10. Acknowledgements ..............................................31 11. IAB Members at the Time of Approval ...........................32 12. Informative References ........................................32 Cooper, et al. Informational [Page 3]

RFC 6973 Privacy Considerations July 2013

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 protocol specifications about security issues. This document intends to provide a similar set of guidelines for considering privacy in protocol design. Privacy is a complicated concept with a rich history that spans many disciplines. With regard to data, often it is a concept applied to "personal data", commonly defined as information relating to an identified or identifiable individual. Many sets of privacy principles and privacy design frameworks have been developed in different forums over the years. These include the Fair Information Practices [FIPs], a baseline set of privacy protections pertaining to the collection and use of personal data (often based on the principles established in [OECD], for example), and the Privacy by Design concept, which provides high-level privacy guidance for systems design (see [PbD] for one example). The guidance provided in this document is inspired by this prior work, but it aims to be more concrete, pointing protocol designers to specific engineering choices that can impact the privacy of the individuals that make use of Internet protocols. Different people have radically different conceptions of what privacy means, both in general and as it relates to them personally [Westin]. Furthermore, privacy as a legal concept is understood differently in different jurisdictions. The guidance provided in this document is generic and can be used to inform the design of any protocol to be used anywhere in the world, without reference to specific legal frameworks. Whether any individual document warrants a specific privacy considerations section will depend on the document's content. Documents whose entire focus is privacy may not merit a separate section (for example, "Private Extensions to the Session Initiation Protocol (SIP) for Asserted Identity within Trusted Networks" [RFC3325]). For certain specifications, privacy considerations are a subset of security considerations and can be discussed explicitly in the security considerations section. Some documents will not require discussion of privacy considerations (for example, "Definition of the Opus Audio Codec" [RFC6716]). The guidance provided here can and should be used to assess the privacy considerations of protocol, architectural, and operational specifications and to decide whether those considerations are to be documented in a stand-alone section, within the security considerations section, or throughout the Cooper, et al. Informational [Page 4]

RFC 6973 Privacy Considerations July 2013 document. The guidance provided here is meant to help the thought process of privacy analysis; it does not provide specific directions for how to write a privacy considerations section. This document is organized as follows. Section 2 describes the extent to which the guidance offered here is applicable within the IETF and within the larger Internet community. Section 3 explains the terminology used in this document. Section 4 reviews typical communications architectures to understand at which points there may be privacy threats. Section 5 discusses threats to privacy as they apply to Internet protocols. Section 6 outlines mitigations of those threats. Section 7 provides the guidelines for analyzing and documenting privacy considerations within IETF specifications. Section 8 examines the privacy characteristics of an IETF protocol to demonstrate the use of the guidance framework.

2. Scope of Privacy Implications of Internet Protocols

Internet protocols are often built flexibly, making them useful in a variety of architectures, contexts, and deployment scenarios without requiring significant interdependency between disparately designed components. Although protocol designers often have a particular target architecture or set of architectures in mind at design time, it is not uncommon for architectural frameworks to develop later, after implementations exist and have been deployed in combination with other protocols or components to form complete systems. As a consequence, the extent to which protocol designers can foresee all of the privacy implications of a particular protocol at design time is limited. An individual protocol may be relatively benign on its own, and it may make use of privacy and security features at lower layers of the protocol stack (Internet Protocol Security, Transport Layer Security, and so forth) to mitigate the risk of attack. But when deployed within a larger system or used in a way not envisioned at design time, its use may create new privacy risks. Protocols are often implemented and deployed long after design time by different people than those who did the protocol design. The guidelines in Section 7 ask protocol designers to consider how their protocols are expected to interact with systems and information that exist outside the protocol bounds, but not to imagine every possible deployment scenario. Furthermore, in many cases the privacy properties of a system are dependent upon the complete system design where various protocols are combined together to form a product solution; the implementation, which includes the user interface design; and operational deployment practices, including default privacy settings and security processes of the company doing the deployment. These details are specific to Cooper, et al. Informational [Page 5]

RFC 6973 Privacy Considerations July 2013 particular instantiations and generally outside the scope of the work conducted in the IETF. The guidance provided here may be useful in making choices about these details, but its primary aim is to assist with the design, implementation, and operation of protocols. Transparency of data collection and use -- often effectuated through user interface design -- is normally relied on (whether rightly or wrongly) as a key factor in determining the privacy impact of a system. Although most IETF activities do not involve standardizing user interfaces or user-facing communications, in some cases, understanding expected user interactions can be important for protocol design. Unexpected user behavior may have an adverse impact on security and/or privacy. In sum, privacy issues, even those related to protocol development, go beyond the technical guidance discussed herein. As an example, consider HTTP [RFC2616], which was designed to allow the exchange of arbitrary data. A complete analysis of the privacy considerations for uses of HTTP might include what type of data is exchanged, how this data is stored, and how it is processed. Hence the analysis for an individual's static personal web page would be different than the use of HTTP for exchanging health records. A protocol designer working on HTTP extensions (such as Web Distributed Authoring and Versioning (WebDAV) [RFC4918]) is not expected to describe the privacy risks derived from all possible usage scenarios, but rather the privacy properties specific to the extensions and any particular uses of the extensions that are expected and foreseen at design time.

3. Terminology

This section defines basic terms used in this document, with references to pre-existing definitions as appropriate. As in [RFC4949], each entry is preceded by a dollar sign ($) and a space for automated searching. Note that this document does not try to attempt to define the term 'privacy' with a brief definition. Instead, privacy is the sum of what is contained in this document. We therefore follow the approach taken by [RFC3552]. Examples of several different brief definitions are provided in [RFC4949]. Cooper, et al. Informational [Page 6]

RFC 6973 Privacy Considerations July 2013

3.1. Entities

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

RFC 6973 Privacy Considerations July 2013

3.2. Data and Analysis

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

RFC 6973 Privacy Considerations July 2013

3.3. Identifiability

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

RFC 6973 Privacy Considerations July 2013 $ Official Name: A personal name for an individual that is registered in some official context (for example, the name on an individual's birth certificate). Official names are often not unique. $ Personal Name: A natural name for an individual. Personal names are often not unique and often comprise given names in combination with a family name. An individual may have multiple personal names at any time and over a lifetime, including official names. From a technological perspective, it cannot always be determined whether a given reference to an individual is, or is based upon, the individual's personal name(s) (see Pseudonym). $ Pseudonym: A name assumed by an individual in some context, unrelated to the individual's personal names known by others in that context, with an intent of not revealing the individual's identities associated with his or her other names. Pseudonyms are often not unique. $ Pseudonymity: The state of being pseudonymous. $ Pseudonymous: A property of an individual in which the individual is identified by a pseudonym. $ Real Name: See Personal Name and Official Name. $ Relying Party: An entity that relies on assertions of individuals' identities from identity providers in order to provide services to individuals. In effect, the relying party delegates aspects of identity management to the identity provider(s). Such delegation requires protocol exchanges, trust, and a common understanding of semantics of information exchanged between the relying party and the identity provider.

4. Communications Model

To understand attacks in the privacy-harm sense, it is helpful to consider the overall communication architecture and different actors' roles within it. Consider a protocol entity, the "initiator", that initiates communication with some recipient. Privacy analysis is most relevant for protocols with use cases in which the initiator acts on behalf of an individual (or different individuals at different times). It is this individual whose privacy is potentially threatened (although in some instances an initiator communicates information about another individual, in which case both of their privacy interests will be implicated). Cooper, et al. Informational [Page 10]

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

RFC 6973 Privacy Considerations July 2013 type of attacker is an eavesdropper: an entity that passively observes the initiator's communications without the initiator's knowledge or authorization. The threat descriptions in the next section explain how observers and attackers might act to harm individuals' privacy. Different kinds of attacks may be feasible at different points in the communications path. For example, an observer could mount surveillance or identification attacks between the initiator and intermediary, or instead could surveil an enabler (e.g., by observing DNS queries from the initiator).

5. Privacy Threats

Privacy harms come in a number of forms, including harms to financial standing, reputation, solitude, autonomy, and safety. A victim of identity theft or blackmail, for example, may suffer a financial loss as a result. Reputational harm can occur when disclosure of information about an individual, whether true or false, subjects that individual to stigma, embarrassment, or loss of personal dignity. Intrusion or interruption of an individual's life or activities can harm the individual's ability to be left alone. When individuals or their activities are monitored, exposed, or at risk of exposure, those individuals may be stifled from expressing themselves, associating with others, and generally conducting their lives freely. They may also feel a general sense of unease, in that it is "creepy" to be monitored or to have data collected about them. In cases where such monitoring is for the purpose of stalking or violence (for example, monitoring communications to or from a domestic abuse shelter), it can put individuals in physical danger. This section lists common privacy threats (drawing liberally from [Solove], as well as [CoE]), showing how each of them may cause individuals to incur privacy harms and providing examples of how these threats can exist on the Internet. This threat modeling is inspired by security threat analysis. Although it is not a perfect fit for assessing privacy risks in Internet protocols and systems, no better methodology has been developed to date. Some privacy threats are already considered in Internet protocols as a matter of routine security analysis. Others are more pure privacy threats that existing security considerations do not usually address. The threats described here are divided into those that may also be considered security threats and those that are primarily privacy threats. Cooper, et al. Informational [Page 12]

RFC 6973 Privacy Considerations July 2013 Note that an individual's awareness of and consent to the practices described below may change an individual's perception of and concern for the extent to which they threaten privacy. If an individual authorizes surveillance of his own activities, for example, the individual may be able to take actions to mitigate the harms associated with it or may consider the risk of harm to be tolerable.

5.1. Combined Security-Privacy Threats

5.1.1. Surveillance

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

RFC 6973 Privacy Considerations July 2013

5.1.2. Stored Data Compromise

End systems that do not take adequate measures to secure stored data from unauthorized or inappropriate access expose individuals to potential financial, reputational, or physical harm. Protecting against stored data compromise is typically outside the scope of IETF protocols. However, a number of common protocol functions -- key management, access control, or operational logging, for example -- require the storage of data about initiators of communications. When requiring or recommending that information about initiators or their communications be stored or logged by end systems (see, e.g., RFC 6302 [RFC6302]), it is important to recognize the potential for that information to be compromised and for that potential to be weighed against the benefits of data storage. Any recipient, intermediary, or enabler that stores data may be vulnerable to compromise. (Note that stored data compromise is distinct from purposeful disclosure, which is discussed in Section 5.2.4.)

5.1.3. Intrusion

Intrusion consists of invasive acts that disturb or interrupt one's life or activities. Intrusion can thwart individuals' desires to be left alone, sap their time or attention, or interrupt their activities. This threat is focused on intrusion into one's life rather than direct intrusion into one's communications. The latter is captured in Section 5.1.1. Unsolicited messages and denial-of-service attacks are the most common types of intrusion on the Internet. Intrusion can be perpetrated by any attacker that is capable of sending unwanted traffic to the initiator.

5.1.4. Misattribution

Misattribution occurs when data or communications related to one individual are attributed to another. Misattribution can result in adverse reputational, financial, or other consequences for individuals that are misidentified. Misattribution in the protocol context comes as a result of using inadequate or insecure forms of identity or authentication, and is sometimes related to spoofing. For example, as [RFC6269] notes, abuse mitigation is often conducted on the basis of the source IP address, such that connections from individual IP addresses may be prevented or temporarily blacklisted if abusive activity is determined to be sourced from those addresses. However, in the case Cooper, et al. Informational [Page 14]

RFC 6973 Privacy Considerations July 2013 where a single IP address is shared by multiple individuals, those penalties may be suffered by all individuals sharing the address, even if they were not involved in the abuse. This threat can be mitigated by using identity management mechanisms with proper forms of authentication (ideally with cryptographic properties) so that actions can be attributed uniquely to an individual to provide the basis for accountability without generating false positives.

5.2. Privacy-Specific Threats

5.2.1. Correlation

Correlation is the combination of various pieces of information related to an individual or that obtain that characteristic when combined. Correlation can defy people's expectations of the limits of what others know about them. It can increase the power that those doing the correlating have over individuals as well as correlators' ability to pass judgment, threatening individual autonomy and reputation. Correlation is closely related to identification. Internet protocols can facilitate correlation by allowing individuals' activities to be tracked and combined over time. The use of persistent or infrequently replaced identifiers at any layer of the stack can facilitate correlation. For example, an initiator's persistent use of the same device ID, certificate, or email address across multiple interactions could allow recipients (and observers) to correlate all of the initiator's communications over time. As an example, consider Transport Layer Security (TLS) session resumption [RFC5246] or TLS session resumption without server-side state [RFC5077]. 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 session_id in its ClientHello message. The server agrees to resume the session by using the same session_id and the previously stored master_secret for the generation of the TLS Record Layer security association. RFC 5077 [RFC5077] borrows from the session resumption design idea, but the server encapsulates all state information into a ticket instead of caching it. An attacker who is able to observe the protocol exchanges between the TLS client and the TLS server is able to link the initial exchange to subsequently resumed TLS sessions when the session_id and the ticket are exchanged in the clear (which is the case with data exchanged in the initial handshake messages). Cooper, et al. Informational [Page 15]

RFC 6973 Privacy Considerations July 2013 In theory, any observer or attacker that receives an initiator's communications can engage in correlation. The extent of the potential for correlation will depend on what data the entity receives from the initiator and has access to otherwise. Often, intermediaries only require a small amount of information for message routing and/or security. In theory, protocol mechanisms could ensure that end-to-end information is not made accessible to these entities, but in practice the difficulty of deploying end-to-end security procedures, additional messaging or computational overhead, and other business or legal requirements often slow or prevent the deployment of end-to-end security mechanisms, giving intermediaries greater exposure to initiators' data than is strictly necessary from a technical point of view.