[IRP] edits in the privacy section

Katitza Rodriguez katitza
Thu Jan 14 16:52:09 EET 2010


Dear Lisa,

Thank you very much for your explanation. The process is now clear.  
The language I added is on the link you provide here. Thanks. I tried  
not to use Google products (when I am "able" to do so), so I am not  
familiar with Googles docs (nor I will open an account and sign on).

Due to the fact that the Council of Europe is a member of the Steering  
Committee, I proposed to focus on Convention 108 (and its protocol  
2001). We can then discuss further documents/recommendations, etc.

All the best,

Katitza




On Jan 14, 2010, at 6:33 AM, Lisa Horner wrote:

> Hi
>
> Thanks for your comments Katitza.  As making sure that the Charter  
> aligns with international standards is one of the tasks of the  
> expert group, they?ll take all of this on board.  If people have  
> thoughts about which standards/directives we should be working to,  
> please do send them through to the list or make notes on the wiki.   
> I?m not a privacy expert and so can?t comment in this instance.
>
> Please note that the Charter is here:
> http://docs.google.com/Doc?id=ajcs86p9dx2s_488rpfcbcc
>
> There?s been some confusion over the different versions, so please  
> make sure you?re editing the right one.  I?ve changed the link on  
> the homepage at www.internetrigtsandprinciples.com so that it links  
> right through to the correct version.
>
> Thanks,
>
> Lisa
>
> From: irp-bounces at lists.internetrightsandprinciples.org [mailto:irp-bounces at lists.internetrightsandprinciples.org 
> ] On Behalf Of Katitza Rodriguez
> Sent: 13 January 2010 23:04
> To: irp
> Cc: Cedric Laurant
> Subject: Re: [IRP] edits in the privacy section
>
> Dear Lisa, Dear Meryem:
>
> Happy New Year. I want to submit some comments to the Privacy  
> Section. Cedric Laurant and I submit some comments the other day.  
> While editing the text, I start asking myself  that the overall  
> Privacy Section needs some thoughts.
>
> Please, noted that in comparison to other rights of the charter, in  
> this section we have International Legal Frameworks. ie. The 1995  
> Data Protection Directive, 1980 OECD Privacy Guidelines, the  
> Convention 108 of the Council of Europe. Those instruments places  
> obligations on those public and private organizations who collect  
> and process personal information and gives RIGHTS to those  
> individual whose personal information is collected.
>
> The old text, wrote by APC, is based in the EU Directive. The APC  
> text (not the IRP text) use a common language based on that  
> framework. Is that the objective? If its yes, we need an editor. It  
> is ok to add more concrete actions that we want to see in the text  
> but as minimum, we should mirror the language of the Directive/ 
> Convention 108?
>
> Meryem: As you will be working in the charter, can you take on board  
> my comments? I would appreciate. Maybe Cedric is willing to do so?
>
> all the best,
>
> Katitza
> P.D I am happy to reviewed/revised the clean version after those  
> editions.
>
> On Jan 13, 2010, at 3:12 PM, Katitza Rodriguez wrote:
>
>
> Dear Max:
>
> I am confuse reading the Privacy section of the charter. I would  
> like to suggest that you use the language from the Madrid Privacy  
> Declaration. Some of this language does not make sense. On the  
> anonymity front, please, include the need for genuine Privacy  
> Enhancing Techniques that minimize or eliminate the collection of  
> personally identifiable information. We need to be sure whether  
> those methods safeguard privacy and anonymity. Pls. read EPIC: Re- 
> Identification: Concerning the Re-Identification of Consumer  
> Information  http://epic.org/privacy/reidentification/
>
> Also, I do not see any mentioned to the international legal  
> framework. The 1995 Data Protection Directive, 1980 OECD Privacy  
> Guidelines, the Convention 108 of the Council of Europe. Those  
> instruments places obligations on those public and private  
> organizations who collect and process personal information and gives  
> rights to those individual whose personal information is collected.
>
> Are you re-writing those rights?
>
> My 2 cents,
>
> All the best and Happy New Year,
>
> Katitza
>
>
> On Jan 13, 2010, at 12:57 PM, Max Senges wrote:
>
>
> hi everybody
>
> i have made a number of edits in the privacy section and would like  
> to ask a fundamental question
>
> 1) I thought it would be good to raise ease of access,  
> comprehensiveness and usability of privacy settings:
> "Privacy policy and settings of all services should be easy to find  
> and the management of privacy settings should be comprehensive and  
> optimized for usability."
>
> 2) The following sentence seems rather ambiguous to me (esp. what is  
> meant by "hidden mechanism") and I suggest to remove or amend it:
> "Social media networks must disclose when hidden mechanisms are  
> being employed to harvest email personal data bases."
>
> 3) "Service providers have a responsibility to make clear in which  
> legal jurisdiction(s) the user's personal data is being hosted, so  
> that the user can make informed decisions."
> I have raised this before and even though I see how this is an  
> important point, I think it needs to be formulated differently/  
> thought through a bit more. If I create a file/data-point in the  
> cloud say while I am in Germany, then I go on a trip and the file  
> "moves with me" to servers in Asia... etc. etc. how can there be a  
> final decision which jurisdiction is concerned? I mean wouldn't it  
> make more sense to be determined in a case by case logic?
>
> 4) "Unless otherwise explicitly agreed, data should be deleted when  
> it is no longer necessary for the purposes for which it was  
> collected, or for legal reasons." I would think that it's important  
> to limit this paragraph to personal data and ask for anonymization:  
> "Unless otherwise explicitly agreed,  personal data should be  
> deleted or anonymized when it is no longer necessary for the  
> purposes for which it was collected, or for legal reasons"
>
> 5) "People must be free to communicate without arbitrary  
> surveillance or interception, or the threat of surveillance or  
> interception. This includes the use of technologies such as deep  
> packet inspection and the exercise of control over individuals such  
> as in instances of domestic violence and cyberstalking."
>      This paragraph seems to be mixing several points. The main  
> points have been raised in other paragraphs and while I totally  
> agree to the first sentence i think the second is controversial.  
> E.g. deep packet inspection is a particular technology and we said  
> we dont want to mention particular technologies.
>
> 6) "Service providers should communicate clearly with users the  
> circumstances under which personal data will be shared with  
> governments and/or with other private entities. Simultaneously  
> provide options for unscribing from such networks. " I don't get the  
> latter sentence. Unsubscribe from the Internet? i'd suggest we delete.
>
>
>
> Looking forward to your input
> Max
>
>
>
>
> --
>
>
> "The future is here. Its just not widely distributed yet."
> William Gibson
>
> ...........................................................................
>
> Max Senges
> Berlin
>
> www.maxsenges.com
>
> Mobile: 01622122755
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