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 [email protected]
* To the [email protected] 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
[email protected]
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