An Analysis of P3P Deployment Hyun Jin Kim Sensitive Information in a Wired World November 11, 2003

Introduction Privacy Policies US self-regulatory approach to online privacy protection Description of a company’s data practices What information they collect from individuals and what they do with it

P3P Specifications Developed by World Wide Web Consortium (W3C) over 5 years of work Became an official W3C “Recommendation” just over a year ago on April 16, 2002

P3P Specifications

P3P Evaluation System Design Automated process to measure P3P adoption and gather data from P3P-enabled web sites By Lorrie Faith Cranor, Simon Byers, and David Kormann (AT&T Labs-Research) Five major components URL Collection Mechanism P3P Policy Retriever Scripted Interface to the W3C P3P Validator P3P Policy Evaluator Generic Data Analysis Tools

URL Collector To identify sets of sites of interest Existing lists of URLs Newly constructed lists that focus on particular web sites Web spidering technique  Gather information from web directories and other sources

P3P Policy Retriever Pearl Script to retrieve P3P information All policies, policy reference files, compact header policies

P3P Validator W3C P3P Validator Fetches P3P policy reference files, policy files and compact policies Checks them for compliance with the P3P 1.0 Specification Stops validation upon encountering an error Scripted interface to the W3C P3P Validator Retrieve P3P policies from sites with errors in their policy reference files

P3P Policy Evaluator Compares a web site’s policy with a user’s privacy preferences Finds a mismatch between the P3P policy and the privacy preferences

Data Analysis Outputs of policy evaluations gathered in a rectangular matrix Row – policy from a web site Column – APPEL rule set file Run a Pearl script over the matrix Produce various tabulations i.e., number of sites that returned mismatch between privacy preferences and P3P policies

Web Site Selection Focus on the sites frequently visited by users PFF Most Popular 85 of the 100 busiest sites determined by the October 2001 Nielsen/NetRatings ranking of sites with the most unique visitors per month Excludes adult sites, children’s sites, business-to-business sites, and sites not in the.com top level domain PFF Random Random sample of 302 of the 7821 domains with at least 39,000 unique monthly visitors in October 2001 by Nielsen/NetRatings PFF Refined Random 209 domains from the PFF Random list that were in the top 5,625 domains in October 2001 by Nielsen/NetRatings Excludes adult sites, children’s sites, business-to-business sites, and non-dot-coms Netscore Top domains with the most unique visitors during July 2002 by comScore Media Matrix netScore Standard Traffic Measurement report Key Measures Top 500 domains with the most unique visitors during July 2002 by comScore Media Matrix Key Measures report Includes “third-party” sites

Web Site Selection (Cont.) Alexia Top 500 domains by Alexia Traffic Ranking on Feb.4, 2003 Includes non-US domains and adult sites Froogle 1,017 sites obtained by crawling the web sites in April 2003www.froogle.com Sites offer products for sale Yahooligans 900 sites obtained by crawling in April 2003www.yahooligans.com Sites for children ages 7-12 Firstgov 344 government sites indexed at in April 2003www.firstgov.gov Includes US federal and state government sites and sites for some quasi- government organizations News 2,429 sites by news.google.com in April 2003 Includes a variety of news-reporting organizations from the US and other countries

P3P Adoption on May 2003

P3P Adoption (Cont.) P3P adoption increasing over time Highest for the most popular web sites Key Measures site lists higher than Netscore Presence of “third-party” sites  To avoid having their cookies blocked by IE6 Alexa top 500 list lowest International nature Large number of adults sites One third of the P3P-enabled sites had errors flagged by W3C P3P Validator 7% had errors that prevented their evaluation by Privacy Bird evaluation engine Omit required components of a P3P policy Improperly referencing data elements

Privacy Bird Evaluation Definition of not sharing data Sites share data only with agents that use it only to complete the transaction for which it was provided or with delivery companies Data sharing occurs only under an opt-in policy 3 standard settings Low Trigger a red bird – policy does not match the preferences  Collects health/medical info  Share it with other companies  Use it for analysis, marketing or to make decisions what content or ads the user sees  Engage in marketing but do not provide a way to opt-out

Privacy Bird Evaluation (Cont.) Medium Same as low Sites sharing PII (physical contact info, online contact info, government-issued identifier), financial info, or purchase info with other companies Sites collecting PII but provide no access provisions High Same as medium Sites sharing any personal info (including non-identified info) with other companies Use it to determine the user’s habits, interests, or other characteristics Sites contacting users for marketing Sites using financial or purchase info for analysis, marketing, or to make decisions that may affect what content or ads the user sees

Privacy Bird Evaluation (Cont.)

Red bird on 24% of the evaluated sites No opt-out of marketing and/or telemarketing ability offered Most popular sites receive both green bird on low setting and red bird on high setting Green bird - Greater awareness of the importance of the “choice” principle Red bird - Most offer rich ecommerce environments that rely heavily on targeted marketing and profiling visitors Red birds on Froogle and Yahooligans most likely Collect health and medical info

Types of Data Collected

Types of Data Collected (Cont.) Most collected data Computer info and click stream info HTTP protocol used for retrieving content from website Demographic data Less by Froogle and gov’t web sites Online contact info, physical contact info, interactive data, unique ids Mostly by news web sites Preference info, purchase info, and state management info (cookies) Fewer collected financial info (excludes purchase process) Least collected data Content ( msgs, bulletin board postings, etc.) Government-issued identifiers Health information Political information Location information (ie. GPS positioning data) Information not falling into any other pre-defined categories No government websites collect government-issued identifiers

Data Usage

Data Usage (Cont.) Almost all websites used data for Completion and support of the activity for which data was provided Web site and system administration Research and development Majority of sites used data for and postal mail marketing One-time tailoring of the site content Two-forms of pseudonymous profiling Fewer sites used data for Telemarketing Profiling in which individuals are identified by name or other PII Very few sites used data for Historical preservation (Not by government sites) Other purposes that do not fall into these categories News web sites use data for almost every purpose.

Data Recipients and Sharing

Data Recipients and Sharing (Cont.) Half the websites share PII with parties other than agents who use data for the purpose for which it was provided Most likely by News web sites Froogle list sites with delivery company Least likely by Government web sites

Choice Options

Choice Options (Cont.) Top sites most likely to engage in marketing than less popular sites Top sites most likely to offer choices (opt-in/out) Internal choices (telemarketing and other marketing) offered more opt-out than opt-in Third-party choices offered more opt-in than opt-out

Access Provisions

Access Provisions (Cont.) 92% of sites collecting identified data provides some access provisions Most provides access to both contact info and other data Smaller number provides access to only contact info or to all identified data Very few provides no access None provides access only to non-contact info

Dispute Resolution Options and Remedies

Individuals can contact customer service to resolve their disputes on most sites About one-third offered resolution via independent organization (ie. Privacy seal provider) by most popular sites Very few indicated resolution of dispute under an applicable law Almost none indicated resolution in court

Data Retention Policies

Data Retention Policies (Cont.) Majority did not have a data retention policy for all of the data they collected Government web sites more likely to have a policy of not retaining info or to have a retention policy based on a legal requirement

Conclusion P3P adoption is increasing over time, especially for the most popular web sites Yahooligans (sites for children) most likely to offer opt-in policies Large number of websites with technical errors in their P3P policies Debates continue about the need for further privacy legislation and the effectiveness of industry self-regulation in the privacy area. Essential to have good statistics and privacy policies US government web sites began posting P3P policies to comply with the privacy requirements of section 208 of the E-Government Act of 2002 Continue web sweeps of gov’t web sites to monitor compliance with these requirements