Alissa,
No hats on, these are my personal views.
I have now read the draft. My overall comment is that I am not convinced if
this is needed and am sympathetic to the views expressed on the mailing list
that this is solving a problem the IETF doesn't have.
Comments below.
Bob
General comments:
If the IETF is to have a privacy policy, I would prefer it to be much simpler
and of the form where it first starts with a general statement that the IETF
does it's work in public and almost all information information supplied to the
IETF is made public and will be available on the IETF (and other related) web
sites. I would then list the exceptions. For example, credit card information
for meeting registration and social tickets, and information for "letters of
invitation". Note: As I read the draft, there is very little that actually
falls into the private category. This leads to to wonder about the scope of
the problem this draft is solving.
The IETF goes to great length to tell people about how we do our work and what
is considered a public contribution, via the Note Well. I would be surprised
if anyone thought otherwise. Doing our work in public is essential to how the
IETF works.
Detailed Comments:
I have issues with the Introduction. The first sentence says:
In keeping with the goals and objectives of this standards body, the
IETF is committed to the highest degree of respect for the privacy of
IETF participants and site visitors.
This makes it sound like the highest priority of the IETF is Privacy. I don't
think this is true as I described above. The vast majority of what the IETF
does in Public. There is very little that is Private. The IETF is careful
about what needs to be kept private and does not disclose it.
The Introduction says:
This policy explains how the IETF applies the Fair
Information Practices -- a widely accepted set of privacy principles
[1] -- to the data we obtain.
I don't know if it is appropriate that the IETF apply these practices. Or if
there are other practices that would be more appropriate. The IETF is
different from other organizations in that much of our data is public and not
private.
The rest of the Introduction appears to be a summary of the first reference:
[1] Organization for Economic Cooperation and Development, "OECD
Guidelines on the Protection of Privacy and Transborder Flows of
Personal Data", http://www.oecd.org/document/18/
0,3343,en_2649_34255_1815186_1_1_1_1,00.html, 1980.
I don't know anything about this web page, who produced it, how stable it is,
etc, etc. It is fairly long, around 21 pages. I don't know if this is
appropriate for the IETF. I think it would better to not include this
information as it is hard to judge how appropriate it is. Also, some of the
practices seem to be at odds with normal IETF practices. For example, it
implies that individuals have complete control of the data the IETF makes
public. This isn't true in most cases.
Section 2 and 3
A lot these section is a summary of what is defined in other places (References
2, 3, 4, 5, 7, 8). Other parts of the text are fairly generic, such as the
information that a web server can learn about a web client. Not thing very
IETF specific here. I don't see very much value repeating this.
Section 4
The first paragraph:
The IETF does not sell, rent, or exchange any information that we
collect about our participants or site visitors. However, we will
disclose information under the following circumstances:
The first two "sell & rent" is true, but the "exchange" is not true as you
state later in the section. Much of the data we collect is exchanged.
Section 5
I am not really qualified to comment on the specifics here, such as how long
credit card or letter of invitation information needs to be retained. I would
have thought that all financial data needs to be kept for some number of years.
This describes our current operational practices regarding log files.
Including specific times for retention will make it hard to change this in the
future. Also, if log files are going to be covered, what happens to the
backups? Are we required to scrub the backups? This would be difficult and
expensive. What about backups of credit card information?
Section 10
In the acknowledgment section you cite the IAOC. The IAOC has not done any
formal review of this draft. It is better if you cite the people in the IAOC
you have discussed this with you and not list the IAOC.
Now that I have written this, you can cite me if you choose :-)
Section 11
I think most of the references are Normative, not Informative. That is, this
draft depends on these documents.
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