An Analysis of P3P Deployment

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

2. 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

3. 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

4. P3P Specifications

5. 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

6. 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

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

8. 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

9. 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

10. 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

11. 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 500 • 500 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

12. 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 www.froogle.com web sites in April 2003 • Sites offer products for sale • Yahooligans • 900 sites obtained by crawling www.yahooligans.com in April 2003 • Sites for children ages 7-12 • Firstgov • 344 government sites indexed at www.firstgov.gov in April 2003 • 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

13. P3P Adoption on May 2003

14. 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

15. 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

16. 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

17. Privacy Bird Evaluation (Cont.)

18. 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

19. Types of Data Collected

20. 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 (email 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

21. Data Usage

22. 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 • Email 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.

23. Data Recipients and Sharing

24. 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

25. Choice Options

26. 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

27. Access Provisions

28. 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

29. Dispute Resolution Options and Remedies

30. 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

31. Data Retention Policies

32. 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

33. 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