Showing posts with label Identity. Show all posts
Showing posts with label Identity. Show all posts

Friday, September 23, 2011

Old data learns new tricks: Managing patient security and privacy on a new data-sharing playground


Data is quickly becoming one of the health industry’s most treasured commodities. Yet, health organizations are acutely aware that sensitive data can be easily compromised. In just the last year and a half, a breach of personal health information occurred, on average, every other day. Breaches erode productivity and patient trust. They’re costly, unpredictable, and unfortunately quite common. More than half of healthcare organizations surveyed by PwC have had at least one privacy/security-related issue in the last two years

·        Download: Old data learns new tricks (1.24mb)
·       Download: Old data learns new tricks: Chart pack (58kb)

Monday, September 19, 2011

NYTimes on ID

Call It Your Online Driver’s License

By NATASHA SINGER  NYT   9/18/11

Consumers who still pay bills via snail mail. Hospitals leery of making treatment records available online to their patients. Some state motor vehicle registries that require car owners to appear in person — or to mail back license plates — in order to transfer vehicle ownership.

But the White House is out to fight cyberphobia with an initiative intended to bolster confidence in e-commerce.

The plan, called the National Strategy for Trusted Identities in Cyberspace and introduced earlier this year, encourages the private-sector development and public adoption of online user authentication systems. Think of it as a driver’s license for the Internet. The idea is that if people have a simple, easy way to prove who they are online with more than a flimsy password, they’ll naturally do more business on the Web. And companies and government agencies, like Social Security or the I.R.S., could offer those consumers faster, more secure online services without having to come up with their own individual vetting systems.

“What if states had a better way to authenticate your identity online, so that you didn’t have to make a trip to the D.M.V.?” says Jeremy Grant, the senior executive adviser for identity management at the National Institute of Standards and Technology, the agency overseeing the initiative.

But authentication proponents and privacy advocates disagree about whether Internet IDs would actually heighten consumer protection — or end up increasing consumer exposure to online surveillance and identity theft.

If the plan works, consumers who opt in might soon be able to choose among trusted third parties — such as banks, technology companies or cellphone service providers — that could verify certain personal information about them and issue them secure credentials to use in online transactions.

Industry experts expect that each authentication technology would rely on at least two different ID confirmation methods. Those might include embedding an encryption chip in people’s phones, issuing smart cards or using one-time passwords or biometric identifiers like fingerprints to confirm substantial transactions. Banks already use two-factor authentication, confirming people’s identities when they open accounts and then issuing depositors with A.T.M. cards, says Kaliya Hamlin, an online identity expert known by the name of her Web site, Identity Woman.

The system would allow Internet users to use the same secure credential on many Web sites, says Mr. Grant, and it might increase privacy. In practical terms, for example, people could have their identity authenticator automatically confirm that they are old enough to sign up for Pandora on their own, without having to share their year of birth with the music site.

The Open Identity Exchange, a group of companies including AT&T, Google, Paypal, Symantec and Verizon, is helping to develop certification standards for online identity authentication; it believes that industry can address privacy issues through self-regulation. The government has pledged to be an early adopter of the cyber IDs.

But privacy advocates say that in the absence of stringent safeguards, widespread identity verification online could actually make consumers more vulnerable. If people start entrusting their most sensitive information to a few third-party verifiers and use the ID credentials for a variety of transactions, these advocates say, authentication companies would become honey pots for hackers.

“Look at it this way: You can have one key that opens every lock for everything you might need online in your daily life,” says Lillie Coney, the associate director of the Electronic Privacy Information Center in Washington. “Or, would you rather have a key ring that would allow you to open some things but not others?”

Even leading industry experts foresee challenges in instituting across-the-board privacy protections for consumers and companies.

For example, people may not want the banks they might use as their authenticators to know which government sites they visit, says Kim Cameron, whose title is distinguished engineer at Microsoft, a leading player in identity technology. Banks, meanwhile, may not want their rivals to have access to data profiles about their clients. But both situations could arise if identity authenticators assigned each user with an individual name, number, e-mail address or code, allowing companies to follow people around the Web and amass detailed profiles on their transactions.

“The whole thing is fraught with the potential for doing things wrong,” Mr. Cameron says.

But next-generation software could solve part of the problem by allowing authentication systems to verify certain claims about a person, like age or citizenship, without needing to know their identities. Microsoft bought one brand of user-blind software, called U-Prove, in 2008 and has made it available as an open-source platform for developers.

Google, meanwhile, already has a free system, called the “Google Identity Toolkit,” for Web site operators who want to shift users from passwords to third-party authentication. It’s the kind of platform that makes Google poised to become a major player in identity authentication.

But privacy advocates like Lee Tien, a senior staff lawyer at the Electronic Frontier Foundation, a digital rights group, say the government would need new privacy laws or regulations to prohibit identity verifiers from selling user data or sharing it with law enforcement officials without a warrant. And what would happen if, say, people lost devices containing their ID chips or smart cards?

“It took us decades to realize that we shouldn’t carry our Social Security cards around in our wallets,” says Aaron Titus, the chief privacy officer at Identity Finder, a company that helps users locate and quarantine personal information on their computers.

Carrying around cyber IDs seems even riskier than Social Security cards, Mr. Titus says, because they could let people complete even bigger transactions, like buying a house online. “What happens when you leave your phone at a bar?” he asks. “Could someone take it and use it to commit a form of hyper identity theft?”

For the government’s part, Mr. Grant acknowledges that no system is invulnerable. But better online identity authentication would certainly improve the current situation — in which many people use the same one or two passwords for a dozen or more of their e-mail, e-tail, online banking and social network accounts, he says.

Mr. Grant likens that kind of weak security to flimsy locks on bathroom doors.

“If we can get everyone to use a strong deadbolt instead of a flimsy bathroom door lock,” he says, “you significantly improve the kind of security we have.”

But not if the keys can be compromised.
A version of this article appeared in print on September 18, 2011, on page BU4 of the New York edition with the headline: Call It Your Online Driver’s License.

Tuesday, September 13, 2011

Jeff Rosen in NYTimes: Protect Our Right to Anonymity

By Jeffrey Rosen  September 12, 2011   NYT
 IN November, the Supreme Court will hear arguments in a case that could redefine the scope of privacy in an age of increasingly ubiquitous surveillance technologies like GPS devices and face-recognition software.

The case, United States v. Jones, concerns a GPS device that the police, without a valid warrant, placed on the car of a suspected drug dealer in Washington, D.C. The police then tracked his movements for a month and used the information to convict him of conspiracy to sell cocaine. The question before the court is whether this violated the Fourth Amendment to the Constitution, which prohibits unreasonable searches and seizures of our “persons, houses, papers, and effects.”

It’s imperative that the court says yes. Otherwise, Americans will no longer be able to expect the same degree of anonymity in public places that they have rightfully enjoyed since the founding era.

Two federal appellate courts have upheld the use of GPS devices without warrants in similar cases, on the grounds that we have no expectation of privacy when we are in public places and that tracking technology merely makes public surveillance easier and more effective.

But in a visionary opinion in August 2010, Judge Douglas H. Ginsburg, of the United States Court of Appeals for the District of Columbia Circuit, disagreed. No reasonable person, he argued, expects that his public movements will be tracked 24 hours a day, seven days a week, and therefore we do have an expectation of privacy in the “whole” of our public movements.
“Unlike one’s movements during a single journey,” Judge Ginsburg wrote, “the whole of one’s movements over the course of a month is not actually exposed to the public because the likelihood anyone will observe all those movements is effectively nil.”

Judge Ginsburg realized that ubiquitous surveillance for a month is impossible, in practice, without technological enhancements like a GPS device, and that it is therefore qualitatively different than the more limited technologically enhanced public surveillance that the Supreme Court has upheld in the past (like using a beeper to help the police follow a car for a 100-mile trip).

The Supreme Court case is an appeal of Judge Ginsburg’s decision. If the court rejects his logic and sides with those who maintain that we have no expectation of privacy in our public movements, surveillance is likely to expand, radically transforming our experience of both public and virtual spaces.

For what’s at stake in the Supreme Court case is more than just the future of GPS tracking: there’s also online surveillance. Facebook, for example, announced in June that it was implementing face-recognition technology that scans all the photos in its database and automatically suggests identifying tags that match every face with a name. (After a public outcry, Facebook said that users could opt out of the tagging system.) With the help of this kind of photo tagging, law enforcement officials could post on Facebook a photo of, say, an anonymous antiwar protester and identify him.

There is also the specter of video surveillance. In 2008, at a Google conference on the future of law and technology, Andrew McLaughlin, then the head of public policy at Google, said he expected that, within a few years, public agencies and private companies would be asking Google to post live feeds from public and private surveillance cameras all around the world. If the feeds were linked and archived, anyone with a Web browser would be able to click on a picture of anyone on any monitored street and follow his movements.

To preserve our right to some degree of anonymity in public, we can’t rely on the courts alone. Fortunately, 15 states have enacted laws imposing criminal and civil penalties for the use of electronic tracking devices in various forms and restricting their use without a warrant. And in June, Senator Ron Wyden, Democrat of Oregon, and Representative Jason Chaffetz, Republican of Utah, introduced the Geolocation Privacy and Surveillance Act, which would provide federal protection against public surveillance.

Their act would require the government to get a warrant before acquiring the geolocational information of an American citizen or legal alien; create criminal penalties for secretly using an electronic device to track someone’s movements; and prohibit commercial service providers from sharing customers’ geolocational information without their consent — a necessary restriction at a time of increasing cellphone tracking by private companies.

It’s encouraging that Democrats and Republicans in Congress are coming together to preserve the expectations of anonymity in public that Americans have long taken for granted. Soon, liberal and conservative justices on the Supreme Court will have an opportunity to meet the same challenge.

If they fail to rise to the occasion, our public life may be transformed in ways we can only begin to imagine.

Jeffrey Rosen, a law professor at George Washington University, is an editor of the forthcoming book “Constitution 3.0: Freedom and Technological Change.”

Monday, July 18, 2011

Privacy Isn't Dead. Just Ask Google+.

July 18, 2011, 12:59 pm
Privacy Isn’t Dead. Just Ask Google+.
By NICK BILTON
http://bits.blogs.nytimes.com/2011/07/18/privacy-isnt-dead-just-ask-google/?smid=tw-nytimesbits&seid=auto#h[]

Some people have a very hard time trusting Facebook.

After dozens of privacy problems over the years, they’ve grown extremely weary of what the company is doing with my personal information.  I, for one, rarely use Facebook anymore, beyond a rare comment or “Like.”

My Facebook fears stem from the several instances when the company has added new features to the site and chose to automatically opt-in hundreds of millions of users, most of whom don’t even know they’ve been signed up for the new feature. I’ve also been sapped by the company’s hyper-confusing privacy policy, which requires users to navigate a labyrinth of buttons and menus when hoping to make their personal information private.

For Facebook, these breaches on people’s personal privacy rarely result in any repercussions: the negative press is usually temporary, and users have mostly stayed with the service, saying that there isn’t a viable alternative social network to talk to family and friends.
That is, until now.

Enter Google+, which started last month and has already grown to 10 million users. Rather than focus on new snazzy features — although it does offer several — Google has chosen to learn from its own mistakes, and Facebook’s. Google decided to make privacy the No. 1 feature of its new service.

I learned this lesson accidentally last week. When I signed up for Google+, I quickly posted a link to a New York Times article I wanted to share with people. Several hours later my Google+ link lay dormant. No comments. No +1 clicks. And no resharing the link.

It wasn’t until later that I realized that my post had been made private by default; a Google+ user has to specifically say they want to share a post publicly. By doing this, Google has chosen to opt users out of being public, rather than the standard practice by most other services to automatically opt users in.

This isn’t to say Google is perfect. Last year the company has had its fair share of privacy problems. This happened most recently when it started Google Buzz, a social networking service, which turned into a privacy disaster and resulted in calls in Congress to investigate the company.

With Google’s latest offering, it seems that the company not only learned its lesson about the importance of privacy for consumers online, but also realized that Facebook hasn’t learned about the importance of this issue either.

Wednesday, July 13, 2011

How Google and Data-Mining Drive Economic Inequality in Our Nation

Nathan Newman, July 11, 2011  Huffington Post

This is the first part in a three-part series that will run this week at HuffPost on why lost privacy online matters for economic equity in our economy.
Why has economic inequality increased so radically in the United States over the last generation?
General explanations range from globalization to the decline in trade unions to rising returns to education -- and therefore the loss of income to the less educated. These all no doubt play a role, but in an age of information what is unquestionably true is that control of that information is extremely unequal -- and that inequality drives broader economic inequality in our economy.

Information is power and as companies know more and more about us, while the products they sell become more opaque and complicated -- think mortgage-based Collateralized Debt Obligations (CDOs) -- inequality in information begets a massive transfer of wealth from individuals to corporations and to their shareholders. Companies figure out not just what to sell you but the maximum price you and other people like you will pay for that product.

Privacy is About Economic Power and Inequality: The debate on privacy online is therefore not about whether you think it's creepy that corporations are tracking your online activities. You may not have a strong "ick" factor from corporate surveillance per se -- I don't myself -- but what you should care about is that lost privacy is converted by those companies into information that ultimately drives greater economic inequality in our country.

One original promise of the Internet was that "no one knows you're a dog on the Internet" but we have instead evolved through data-mining and online surveillance into a world where not only do companies know what you are, they know where you are and what you are most interested in. For the economically privileged, that may not seem like much of a problem and even a benefit since companies may be able to service your needs more effectively. But for those who already suffer discrimination and exploitation, whether because of race, poverty or other factors, it means that the Internet can just magnify and target that discriminatory treatment and exploitation.

Which brings us to the Federal Trade Commission antitrust investigation into Google. The problem with Google is not that users don't have enough competing options on search engines but that Google's dominance of search and other online products allows them to extract the most massive quantities of private information from users of any corporation. And as I described in my piece back in March, You're Not Google's Customer, You're the Product, Google's real customers are the whole array of corporations who buy access to that user information to know how to effectively market their products and increase their profits.

Google at the Nexus of the Marketing of Privacy: Google is the key nexus in the information age, pricing individual privacy and monetizing it for the benefit of global corporations. They are the dominant middleman between hundreds of millions of people -- even approaching billions globally -- and the corporations using that Google-generated profiling to market their products and extract profit for their shareholders.

And it is that global market power over private individual data by Google that antitrust regulators need to investigate in order to counteract the rising inequality in the information economy. The cost of lost privacy driven by Google is corporate data-mining and manipulated prices across a whole array of markets and the exacerbation of multiple forms of discrimination in the marketplace. Google's monopoly dominance of personal information thereby helps leverage the broader corporate dominance of our lives by the companies using its data.

Why Free is a Bad Deal: The first step in how lost privacy increases economic inequality begins at the moment users give away their private information in the first place. Google offers the enticement of free services in exchange for users turning over a whole range of basic personal data and even what their basic desires are in the form of the whole record of what they search for on Google's pages.

What could be better than free, most users think, as they take the deal offered? It's a bit like how early bank customers might have felt, being told the bank would keep their money safe for free, only later figuring out that the bank was making tons of money lending that money to other people. The free Google tools into which users drop their private information are like the vault banks offered to store your money: it's not a service but a honeypot that allows both banks and Google to resell what users deposit there. Bank customers now expect actual payment in the form of interest for money deposited in banks but most Google customers don't even recognize that their private information has a monetary value that has economic value.
To put it another way, the fact that users are de facto involved in barter with Google, trading privacy for individual tools, should tell you this is an exploitative situation. Like most barter economies, pricing is opaque and creates massive opportunities for economic arbitrage by the sophisticated side of the barter transaction -- i.e. Google. Essentially, Google users are the primitive tribes of the Internet, accepting the shiny trinkets of Gmail and free search in exchange for their privacy.

Google then takes that private information and monetizes it with advertisers who pay very precise dollar terms in the modern part of the Google economy. And those advertisers pay prices far above the costs spent by Google on the tools provided to users -- as highlighted by Google's massive profits year after year. That advertising side of Google's internal economy is actually a monument to converting privacy into a modern currency, with sophisticated auctions for key words and phrases based on particular user demographics and backgrounds that the advertiser may be looking for. One analyst describes this as less the sale of privacy itself by Google, but rather the sale of a "privacy derivative", where companies invest in Google's appraisal of customers' needs and wants.(See Karl T. Muth's Googlestroika: Privatizing Privacy for more on how Google monetizes user privacy).

So the first step in the transfer of wealth via Google is from users selling their privacy for too little and Google arbitraging user ignorance for profit. If Google had less dominance of the online advertising field, there would be far greater pressure for Google to develop as sophisticated a market for users to be compensated for their privacy as the markets in which it resells that lost privacy.

To get some sense of the value of user information, look at the recent controversy over another big Internet player, namely Apple, when it demanded that sellers of subscriptions to apps on the iPhone had to give Apple not just 30% of sales, but sole control of user information as well. Lauren Idvik at Mashable noted that publishers like the Financial Times may not have liked the 30% cut Apple wanted from subscriptions, but "the main problem is that Apple will not share subscriber data with publishers, long one of publishers' most valuable assets, particularly to advertisers." Think about it -- your personal data is worth potentially more than 30% of the cost of what you are purchasing and most users give it away for free to companies like Google and Apple.

And Google is looking to leverage its position at the nexus of the Internet to further expand its data collection of users -- and the opportunities for marketing that data in Internet commerce. Most recently, Google is making a play for inserting what's called NFC technology into every smartphone and turn them into wireless credit cards -- and a substitute for every other card you carry -- that would make all commerce easier for users, while giving Google information on every transaction you make and providing even more expanded data on user shopping habits. Google is marching from dominance over information about online commerce to trying to dominate information about offline shopping as well.

In part 2 of this series, I'll look at why this personal information is so valuable to advertisers and how it empowers what economists call "price discrimination" and just plain old racial discrimination. Part 3 will look at the role of Google in the subprime mortgage debacle and its aftermath, as well as the broader antitrust implications of the company's dominant role as an intermediary for behavioral targeting of consumers by advertisers.

Nathan Newman, a lawyer and Ph.D., has an extensive history of supporting local policy campaigns, from coalition organizing work to drafting legislation. Previously Executive Director of Progressive States, an Associate Counsel at the Brennan Center for Justice, Program Director of NetAction's Consumer Choice Campaign, and co-director of the UC-Berkeley Center for Community Economic Research, he has also been a labor and employment lawyer, freelance columnist and technology consultant. He received his J.D. from Yale Law School and his Ph.D. in Sociology from the University of California at Berkeley and has written extensively about public policy and the legal system in a range of academic and popular journals, including publishing a book, Net Loss: Internet Prophets, Private Profits and the Costs to Community, detailing the relationship between telecommunications public policy and local economic development. His writing and organizing has been cited in the New York Times, USA Today. San Jose Mercury News, Baltimore Sun, Wired, Village Voice, ZDNet, CNet News, San Francisco Chronicle, TheStreet.com, Chronicle of Higher Education, MIT’s Technology Review, The Nation and the American Prospect. He runs his own site at www.nathannewman.org and a technology policy site, www.tech-progress.org.

Friday, July 1, 2011

FTC: Consumer Confidence in Internet Marketplace Depends on Privacy Protections FTC Tells Senate Commerce Committee

: 06/29/2011

The Federal Trade Commission today told Congress that consumers must be confident that their privacy will be protected if they are to be willing to take advantage of all the benefits offered by the Internet marketplace.

Commission testimony to the Senate Committee on Commerce, Science and Transportation, delivered by Commissioner Julie Brill, states that, “Privacy has been an important component of the Commission’s consumer protection mission for 40 years. During this time, the Commission’s goal in the privacy arena has remained constant: to protect consumers’ personal information and ensure that they have the confidence to take advantage of the many benefits offered by the dynamic and ever-changing marketplace.”

The FTC’s testimony states that the FTC has taken a three-pronged approach to preserving consumers’ privacy – law enforcement actions, consumer and business education efforts and policy initiatives.

It notes that in the last 15 years, the agency has brought more than 300 privacy-related actions, including: 34 data security cases; 84 Fair Credit Reporting Act cases; 97 spam cases; 15 spyware cases; and 16 cases enforcing the Children’s Online Privacy Protection Act.
In addition, the testimony states that the agency has distributed millions of copies of consumer and business education materials that address basic privacy issues and security and privacy threats.

Policy initiatives to advance the agency’s privacy agenda include three privacy roundtables that involved privacy experts, business representatives, and academics who examined the implications of new technologies and business practices on consumer privacy. Based on the roundtable discussions, FTC staff issued a preliminary report proposing a privacy framework with three main concepts, the testimony states.

“Staff recommended that companies should adopt a ‘privacy by design’ approach by building privacy protections into their everyday business practices, such as collecting or retaining only the data they need to provide a requested service or transaction, and implementing reasonable security for such data,” according to the testimony.

The staff report also called for companies to provide an easy way for consumers to control the collection and use of their personal information. “One example of how choice may be simplified for consumers is through a universal, one-stop choice mechanism for online behavioral tracking, often referred to as “Do Not Track.” The testimony explained that “any Do Not Track system should not undermine the benefits that online behavioral advertising has to offer, by funding online content and services and providing personalized advertisements that many consumers value.” Any Do Not Track mechanism should be “flexible” and “should allow companies to explain the benefits of tracking and to take the opportunity to convince consumers not to opt out of tracking,” and “could include an option that enables consumers to control the types of advertising they want to receive and the types of data they are willing to have collected about them, in addition to providing the option to opt out completely.” The testimony notes that the industry “appears to be receptive to the demand for simple choices.”

In addition, the staff report recommended that “companies should improve their privacy notices so that consumers, advocacy groups, regulators, and others can compare data practices and choices across companies, thus promoting competition,” the testimony states.

The testimony notes that while the FTC has not taken positions advocating any particular legislative proposals, it favors data security legislation “that would (1) impose data security standards on companies, and (2) require companies, in appropriate circumstances, to provide notification to consumers when there is a security breach.” The testimony states that the Commission is committed to protecting consumers privacy -both online and off, and looks forward to working with Congress to achieve that goal

The Commission vote to issue the testimony was 5-0, with Commissioner J. Thomas Rosch issuing a separate statement recommending that the Commission and Congress learn more about Do Not Track before proceeding.

The Federal Trade Commission works for consumers to prevent fraudulent, deceptive, and unfair business practices and to provide information to help spot, stop, and avoid them. To file a complaint in English or Spanish, visit the FTC’s online Complaint Assistant or call
1-877-FTC-HELP (1-877-382-4357). The FTC enters complaints into Consumer Sentinel, a secure, online database available to more than 2,000 civil and criminal law enforcement agencies in the U.S. and abroad. The FTC’s website provides free information on a variety of consumer topics. Like the FTC on
Facebook and follow us on Twitter.
MEDIA CONTACT:
      Claudia Bourne Farrell Office of Public Affairs 202-326-2181

Friday, June 24, 2011

Peter Swire: Why privacy legislation is hot now

By Peter Swire - 06/23/11 07:50 PM ET

More than at any time in the past decade, privacy hearings and proposed legislation are spreading across Capitol Hill. Until now, you could always make money betting against a privacy law passing in Congress. Today, many experts are saying that momentum is building for major legislation, although the shape of that legislation is still unclear.

This round of privacy action is driven by three historic trends, plus other factors that are coming together now.

First is location data. While Apple’s Steve Jobs called the Android a “probe in your pocket,” Apple itself has been brought before both the Senate Judiciary and Commerce committees to try to explain why it was collecting detailed location information on the iPhone. For the first time in history, most Americans are carrying a tracking device — a cell phone — with them in their daily lives. There is great uncertainty about who gets to see that tracking information, including for advertising and law enforcement purposes.

Second is social networking. Facebook has gone from nothing to half a billion users in only a few years. The social networks point out that users voluntarily put that incredible amount of material up on the sites. But this is all so new that the rules of the road are not yet clear.

Third is online behavioral advertising. The Wall Street Journal ran a major series showing the astonishing range of ways that companies can track your activity on the Web — even if you turn off cookies and try to stay anonymous. The companies say that this data is benign, because computers simply choose which ads to show you. Privacy advocates, though, say that these databases give unprecedented insight into what we read and how we think, leading to a scary potential of misuse down the road.

Along with these three mega-trends, Congress is seriously considering federal data-breach legislation, to harmonize state laws and address the Sony PlayStation and other high-profile recent breaches. Major cloud computing companies and civil liberties groups are supporting the Digital Due Process Coalition, which favors a judicial search warrant before law enforcement can gain access to the exabytes of data stored in the cloud. And, there is pressure on the international front, as the European Union considers tightening its own data privacy laws and as India, Mexico and other countries are in the process of putting EU-style privacy laws on the books.

A flashpoint for action could be children’s privacy, where family-values Republicans and consumer-protection Democrats can most easily come together politically. Mark Zuckerberg has publicly discussed bringing under-13s directly into Facebook, but no one knows with what rules. Reps. Edward Markey (D-Mass.) and Joe Barton (R-Texas) have released a discussion draft of the “Do Not Track Kids Act of 2011” to offer the choice not to have behavioral advertising and related tracking for those under the age of 13. And no one knows who will get to see the location information of children — parents will and stalkers won’t, but there are still-to-be-developed rules for those in-between. On June 27, the Center for American Progress will host an event highlighting children’s privacy issues, called “Tracking: Where you are, what you see, and what you do.”

The biggest legislative question might be whether to go with general privacy principles or sector-specific rules. For the first time in history, the administration itself has come out in favor of broad-based privacy legislation for the private sector. The closest fit to the administration vision is the Kerry-McCain “Commercial Privacy Bill of Rights,” which notably would provide individuals with the legal right to opt out of having their information shared for marketing purposes. This sort of general legislation contrasts with sector-specific proposals, such as a recent bill by Sens. Al Franken (D-Minn.) and Richard Blumenthal (D-Conn.) that targets smartphone location information.

With the convergence of all of these technical changes, the current period most resembles the late 1990s. At that time, Congress approved sector-specific laws for medical privacy (HIPAA) and financial services (Gramm-Leach-Bliley), but held off on a general law to protect privacy on the Internet. With so many sectors having specific laws by now, however, the time may well be ripe for a bill that provides basic privacy protections more generally.

Swire was chief counselor for privacy to former President Clinton and served in the National Economic Council under President Obama. He is now a law professor at Ohio State and a fellow with the Center for American Progress and the Future of Privacy Forum.

Thursday, June 16, 2011

Dispelling the Myths Surrounding De-identification: Anonymization Remains a Strong Tool for Protecting Privacy

Dispelling the Myths Surrounding De-identification: Anonymization Remains a Strong Tool for Protecting Privacy

Introduction

Recently, the value of de-identification of personal information as a tool to protect privacy has come into question. Repeated claims have been made regarding the ease of re-identification. We consider this to be most unfortunate because it leaves the mistaken impression that there is no point in attempting to de-identify personal information, especially in cases where de-identified information would be sufficient for subsequent use, as in the case of health research.

The goal of this paper is to dispel this myth — the fear of re-identification is greatly overblown. As long as proper de-identification techniques, combined with re-identification risk measurement procedures, are used, de-identification remains a crucial tool in the protection of privacy. De-identification of personal data may be employed in a manner that simultaneously minimizes the risk of re-identification, while maintaining a high level of data quality. De-identification continues to be a valuable and effective mechanism for protecting personal information, and we urge its ongoing use.

In this paper we illustrate the importance of de-identifying personal information before it is used or disclosed, and at times, prior to its collection. We will demonstrate that, contrary to what has been suggested in recent articles, re-identification of properly de-identified information is not in fact an “easy” or “trivial” task. It requires concerted effort, on the part of skilled technicians. The paper will also describe a tool that minimizes the risk of the re-identification of de-identified information while also enabling a high level of data quality to be maintained. Our objective is to shatter the myth that de-identification is not a strong tool to protect privacy and to ensure that organizations that collect, use and disclose personal information understand the importance of de-identification for the protection of privacy, and continue to use this tool to the greatest extent possible to minimize potential risks. While our primary focus in this paper is on the value of de-identification in the context of personal health information that is used and disclosed for secondary purposes, the same arguments apply in the broader context of personal information.

Friday, April 29, 2011

Why the Online Identity & Data Ownership Debate Matters


There has been quite a bit of media attention the past week around the news that iPhones and iPads are recording and storing location data in an unencrypted manner. Apple replied that it’s not tracking iPhone location, it’s maintaining a database of surrounding Wi-Fi hotspots and cell towers so the iPhone can calculate its location when requested.Anyway, the little window of raised awareness and interest in data mining and privacy compelled me to want to write a bit about it.

I’ve been exploring many angles over the past few years of how humanity and our technologies are co-evolving, – how social media tools are offering us new ways to collaborate, to see ourselves through different lenses, to intentionally evolve our consciousness, and to explore new forms of value exchange.

I was invited to participate in the Internet Identity Workshop in Silicon Valley next week, and the Privacy Identity Innovation conference later in May, so my new learning objective has been to get a grasp on online identity and personal data ownership.  It’s really quite fascinating, and there is a real sense of urgency for awareness to be raised around what’s happening and what it means.

The Big Picture
We’re aware that the data we generate is “owned” (or at least maintained) by someone else – the government issues us our identification, the doctor’s office has our health records, the credit agencies know our financial history. We assume our information is private and secure.
But now with so much activity happening online and increasingly on mobile devices, we’re generating a digital representation of ourselves that not only expresses our interests, desires, needs, purchasing behaviors, and the range of social connections and relationships, but also the contextual information of our location in physical space and time.This is important because we’re generating a detailed profile of ourselves that reveals much more about us that we may realize.

What is Revealed: Macro Level
A recent article in the Wall Street Journal, The Really Smart Phone, discusses research conducted by scientists, and the interesting patterns of human behavior they were able to abstract from data collected from smartphones. For example, by analyzing people’s movement records, they were able to predict someone’s future whereabouts with 93.6% accuracy. They’re able to notice symptoms of mental illness, predict stock market fluctuations, and even chart the spread of ideas throughout society, revealing a “god’s-eye view of human behavior.” With billions of people on the planet now carrying a mobile device, we’re able to access data about human complexity that was simply not possible before.

What is Revealed: Micro Level
In a New York Times piece from the other day, Show Us the Data. (It’s Ours, After All.), professor of economics and behavioral science Richard Thaler writes about the vast amount of personal data that is being aggregated about us and sold to third parties.

In terms of consumption, this data is useful for companies in order to target you with highly personalized recommendations, advertising and offers. On a personally empowering level, it could potentially offer us a wealth of information about ourselves to assist us with intelligent decision-making. For example, by looking at medical records and family history, we might receive tailored recommendations for exercise plans or food choices. The problem is – we often don’t have access to this data.

What’s at Stake
There’s a lot of talk about “privacy” on the web right now, and I’m still not completely sure I understand the extent of the argument. If by privacy we mean security, and wanting protection of sensitive data like financial records or social security numbers, I completely agree. But if privacy concerns are around the fear of someone finding out about that bizarre fetish we have or the flavor of porn we prefer, I wonder how much that matters. While that information may be taboo in some circles, it’s actually infinitely less interesting than the data we reveal about ourselves publicly that’s being mined and sold online every day.

(check out this tongue in cheek video by The Onion – “CIA’s Facebook Program Dramatically Cut Agency’s Costs)

Most of the activity done online, from browsing websites to chatting with friends, is being recorded by someone. Your “private” conversations in Facebook are mined, as are your shopping habits on Amazon, or your preferences or personal connections on any number of services.

The issue with these things, moreso than that they are happening, is that we don’t have access to that data that we generate. Challenging this unfortunate reality was the big thrust that led to the formation of the Personal Data Ecosystem Consortium, a coalition of individuals and organizations who realize what’s at stake if we don’t reclaim the data that is ours.

Essentially, by third parties locking in our “digital self” into each of their services, we are losing massive collective intelligence opportunites for innovation, value creation, knowledge building, and citizen engagement as a global society.

We have multiple accounts and multiple levels of relationships within and across those social networks. When we click around on sites we are leaving a trail of ‘digital exhaust’, defining our habits, preferences, curiosities, and explorations. We don’t have control/access/ownership of this data, but 3rd parties do. Each of these pieces, and all the contextual information around it, is INCREDIBLY VALUABLE, but currently fragmented, fractured, and scattered. Shouldn’t we have access to it ALL, so we can connect the dots and make effecitve and meaningful choices?

Why can’t I just export my data, activity, and relationships from each service, and be in control of who gets to see it, which parts they get to access, and how they use it once I give them permission?

Why isn’t there an easy way for me to have an overview of everything about me, and be able to selectively share information about myself, my interests, my capacities, my needs, or my resources?

The Future We Deserve
At the moment, commercial entities know more about our preferences and behaviors online than we do. With all the services out there that facilitate social interaction, there is still no easy way to connect with people with whom we share affinities, and then to effectively exchange information with them or collaborate in a meaningful way.

Our online identity and data *should* be our right to control, so that we are empowered to make better decisions about our lives and well-being, find potential collaborators or kindred spirits, or generally create more meaningful and valuable relationships. It’s worth asking:

What would a people-centric web look like?

What if it felt more like walking through a town commons and less like walking through a shopping mall?

How could identity and trust be built into the architecture of the internet?

To contain the length here, I’ll flesh out some ideas about all this in an upcoming post -“A Framework for Building Online Intelligence”

In the meantime, I’d love to hear your thoughts about identity and personal data ownership.
see also:

Personal leverage for personal data - doc searlsDatabuse: Digital Privacy and the Mosaic

Wednesday, April 27, 2011

"Data trading is the new information economy"

Welcome to the age of data
By: Molly Wood, CNET, April 25, 2011
 In Daniel Suarez's book "Freedom," he describes a world in which members of a revolutionary "darknet" use glasses with heads-up displays to literally visualize the publicly available information about every person on earth.

It floats above them as a callout: Social Security numbers, bank balances, cell phone numbers, addresses, purchasing history, baby pictures, social network posts. That data is visible by anyone with the means to harvest it, and it can be manipulated at will by malicious hackers (like Loki, the Suarez character who "data curse" on someone who annoys him), by governments, and by companies.


Hopefully, you've all realized that Suarez's vision is hardly one of the future: it's a vision of the present. Welcome to the age of data. It's time to get control of your assets.
Caption: Yeah, dude. They're watching you.

Yeah, dude. They're watching you.
This week's iPhone location tracking scandal is just the latest glaring spotlight on how much of your personal information is gushing out the door, whether unprotected on your own devices and ripe for the picking, or into corporate and botnet servers worldwide. And despite reports of a Steve Jobs e-mail declaring that Apple doesn't track anyone, Apple's general counsel told a congressional inquiry in June 2010 that "(t)o provide the high-quality products and services that its customers demand, Apple must have access to the comprehensive location-based information."
Apple is hardly alone in demanding this level of comprehensive personal information. The iOS location-tracking revelations come on the heels of a federal investigation into mobile application data sharing. Investigators charge that seemingly harmless apps like Pandora are, while they're streaming you highly customized media, are also sending "age, gender, location and phone identifiers to various ad networks," according to the Wall Street Journal. The Journal report found that the majority of the 101 apps it tested sent some personal information to a third-party data broker, largely without your knowledge.


Subsequent investigations found that most Android phones transmit some user information, including location data, back to the mother ship, as well, with Google saying only that the data wasn't "traceable to a specific user." (The merits of that argument are up for debate, to say the least.) Even Microsoft is gathering location data on Windows phones.

Sadly, this informational espionage should hardly come as a surprise.
Caption: The iPhone 4: talk about a Trojan Horse.
The iPhone 4: talk about a Trojan Horse.
(Credit: EMMANUEL DUNAND/AFP/Getty Images)
The new cost of "free"
Personal information is the currency of the post-technological age, and the cost of "free" has never been higher. Your data, on an increasingly minute and personal level, powers every Web or network-based company, from start-up to monolith.
Google maintains literally acres of servers dedicated to storing your communications--from e-mail to texts to the transcripts of your voice mail; your browsing and shopping habits; your blog posts; your photos; your calendar appointments; and of course, your intensely personal search histories. If you're logged in to a Google service, that information is all tied to your IP address. Only the thinnest of artificial technical barriers--a sort of loose privacy honor system--keeps Google from combining the data into a scarily accurate digital version of you (like the first digital Cylon, if you will).
But pity poor Google, which must gather all this information by increasingly intrusive means, like the DoubleClick ad cookie that tracks your browsing all across the Web, surreptitious Wi-Fi sniffing, and sending location information about you back to its data centers even when you're not running location apps.

On the other side of the aisle lies Facebook, which has cleverly cajoled 500 million users (and growing) into giving up virtually all the same information for free. Profiles, Places, Deals, and of course, the ever-present Like button, which lets you easily record your preferences for everything from opinions to shoes to celebrities and bands...you can almost imagine Facebook whispering a little "thank you" every time you click that little blue button.

Want to understand why Google is so desperate to get into social that it's tied part of every employee's bonus to the success or failure of that strategy in 2011? It has nothing to do with helping you share your photos and restaurant check-ins, and everything to do with data collection--and data connections.
Caption: Connected, we stand.
Connected, we stand.
(Credit: Google)
The real magic of the new world of data collection is far more than just hoovering up reams of anonymous or semi-anonymous information. The real magic is in using that data to draw connections between action and reaction, consideration and purchase, brand and affinity, and to sip from the holiest of all commerce grails: recommendation.

The Web as real-time recommendation engine is the ultimate goal of initiatives ranging from the Amazon recommendation queue to Netflix's $1 million prize to the team who improved its recommendation algorithm by 10 percent or more to Facebook's original Beacon program.
Foursquare is working hard to integrate recommendations into its check-in service; Yahoo just spent a reported $20 million to $30 million on a TV check-in and recommendation service called IntoNow that's just 12 weeks old. It's a pretty simple equation: if they can figure out what you like, they can sell you more of what you like.

And the key to recommendation is scale. You can't do the math until you aggregate as many likes, dislikes, check-ins, one, two, and four stars as possible. All of these services depend, first and foremost, on you providing the data for them to crunch. And thanks to your life online, and, increasingly, the phone in your pocket, that data is as ever-present as the air we breathe.

Who's buying?
See, but Google, Facebook, and Apple are the companies we "trust," like we trusted that Pandora was just delivering great '80s tunes on my now-dusty Bon Jovi station. So, where's all our information going? To a silent but deadly collection of data brokers, marketers, and data aggregation services.

These ranks include Epsilon, recently the subject of what Computer World called "the hack of the century." No one knows how many e-mail addresses were exposed in the Epsilon breach, or the full scope of what else may have been revealed, but it has more than 2,000 clients and handles 40 billion e-mails a year. Its database of active shoppers (which included those who opted out but were retained in the database, if not actively emailed) was a gold mine for hackers and spear phishers, and there are 25 more companies where they came from--and that's just email marketing. Merlin Information Services: for all your massive personal information database needs
What should you do?
What can you do? The short answer is, not a lot. Sure, you can go opt out of every data broker on the list, you can stay off the grid, you can give false names and live on cash. But the real question is: do you need to? Or, should we accept that we're in the age of data and embrace--nay, demand--that the data transparency go both ways?

Take the time to own your own data and clear the Web of any information you'd rather not be out there--you can at least try to opt out of sites like Spokeo and other aggregators, if only to protect the most sensitive information. And you don't have to trust the cloud. Ironically, despite its aggregation of information at a scale that would make Skynet envious, Google has engineers in-house who've created the Data Liberation Front, which lets you freely export your own information from the big G. Facebook lets you download everything you've ever posted (surprising, right?).

If you just want to back up and retain your data, services like Backupify index your cloud data and back it up, while Greplin lets you index the cloud services and search them, too (yes, I'm aware that both sites may engage in the same kind of ad targeting or data brokering I'm complaining about: read your terms of service, folks!).

And hey, as long as start-ups are making money brokering data, I'd like to see one that lets you see, say, your Data Score. If Greplin or Backupify can index your cloud information, why can't a company index it and parse it? A Data Score could tell you how risky your overshares are: does it make you unemployable, or just questionable? It could tell you what data is unintentionally public, like the cell phone number you thought you were hiding behind Facebook's byzantine wall of privacy settings. It could even perform a TurboTax like audit, and warn you when publicly available information about you might lead to easy identity theft or obvious phishing attempts.

The best disaster mitigation is preparedness. At some point, data trading is the new information economy, our privacy expectations will adjust accordingly, and yes, there are benefits. But we shouldn't stumble blindly into it--we ought to at least be willing and informed partners in managing our digital identities. Then we can click the ad for those perfect nude pumps in relative peace. After all, they do go with everything.

Tuesday, April 26, 2011

What Does Your Phone Know About You? More Than You Think

Figuring that I've got nothing to hide or steal, I'd always privileged convenience over any privacy and security protocols. Not anymore.

I plugged my phone into my computer and opened an application called Lantern, a forensics program for investigating iPhones and iPads. Ten minutes later, I'm staring at everything my iPhone knows about me. 14,000 text messages, 1,350 words in my personal dictionary, 1,450 Facebook contacts, tens of thousands of locations pings, every website I've ever visited, what locations I've mapped, my emails going back a month, my photos with geolocation data attached and how many times I checked my email on March 24 or any day for that matter. Want to reconstruct a night? Lantern has a timeline that combines all my communications and photos in one neat interface. While most of it is invisible during normal operations, there is a record of every single thing I've done with this phone, which also happens to form a pretty good record of my life.

Figuring that I've got nothing to hide or steal, I'd always privileged convenience over any privacy and security protocols. Not anymore. Immediately after trying out Lantern, I enabled the iPhone's passcode and set it to erase all data on the phone after 10 failed attempts. This thing remembers more about where I've been and what I've said than I do, and I'm damn sure I don't want it falling into anyone's hands.

Last week, two separate news items highlighted the importance of what your phone knows. First, the American Civil Liberties Union in Michigan went public with its Freedom of Information Act request for data on how the state police are using a hardware system called Cellebrite UFED. The ACLU suggested that state troopers were using the UFED during routine traffic stops. While the $4,000-8,000 price tag of the systems would suggest it's unlikely that many cops have the systems in their cars, even the possibility of such a practice has got to set Fourth Amendment alarm bells ringing from here to 1791. Here's a word of advice: if a law enforcement official ever asks for your phone, just say no.

In a June 2008 article, Cellebrite bragged that it had sold 3,500 Cellebrite devices in the eleven months the UFED had been on the market. Throw in other common devices from companies like Cellebrite, Parabens, Micro Systemation and Katana Forensics, makers of Lantern, and you can begin to see the scale of mobile phone data extraction that must be occurring across the nation's law enforcement landscape.

I don't say that to suggest that the police are doing anything wrong. Like computers, phones certainly seem like fair game for investigators. They're scrambling like the rest of us to keep up with a rapidly changing mobile technology landscape that's forcing strange ethical choices onto them. Let's say someone was texting while driving, which may be against the law in your state. They might want that evidence, so they extract the data from the phone and when they look at it, lo and behold, there are several time-tagged photos of the person getting high earlier that day. Suddenly, a minor ticket gets turned into a DUI.

We're not sure how the courts are going to decide whether evidence like this is admissible because it's complicated. Doctrines like 'plain view' -- that cops can seize evidence without a warrant if they can see it -- require informational friction and human embodiment to make sense. With a searchable stash of a phone's data, what is in plain view? What isn't? It's just so easy to find out more than you asked.

The other big mobile data news last week came out of O'Reilly's Where 2.0 conference during which two researchers showed in dramatic fashion that the iPhone keeps a location log of where the phone has been, a fact which Apple had declined to tell anyone and which had first been discovered by the same guy who created the Lantern software that opened up my phone for inspection.

Alex Levinson built Lantern from his living room in Rochester, New York. He's still a student at Rensselaer Polytechnic Institute, but he tells me that his room is "basically an information security and forensic laboratory." He ticks off the equipment at his disposal: 4 MacBooks, a couple other laptops, two desktop boxes running different operating systems, two iPhones, a couple Droids, a Blackberry, all kinds of wireless and networking equipment and terabytes of storage. He may also know Apple's iOS as well as anyone in the world. A mere 48 hours after Apple released the iPhone 4, Levinson had patched Lantern to support the upgrade. He waited in line for ten hours and spent the next two days poking around the file system that sits underneath the ultraslick user experience.

That's one reason he was the first to notice that Apple had begun storing its location data in the new, more easily accessible way. But all that time spent rummaging around under the iPhone's hood also led him to develop an actual philosophy about the difference between mobile and computer forensics. In mobile, he said, no one directly interacts with the file system. You don't pull up documents and save and delete them the way we do with computer.

"How are those new interactions producing evidence that would be relevant to what I'm doing?" Levinson asked rhetorically.  For him, that means knowing every single thing a phone can output for him. "Take a basic phone, maybe a Razr," he said. "I would map out every single data point within the phone. We've got text messages. We've got pictures. We've also got picture messaging, which could be a subset. We've got call logs. We might have baseband logs." Then, he'd start to correlate one thing with another. If there are timestamps and locations, every message or photo can be fixed in space and time.

"You're beginning to create a forensic model of the human use of the device," he said. "The software's goal is to recereate a rich forensic timeline of how this device was used so the analyst can put their shoes in place of the user and see what happened with this device."
Indeed, using Lantern, it's remarkably easy to reconstruct what happened to me on, say, April 13, my birthday, and the next day, when I celebrated the release of my book at an Atlantic party.

I missed a call from my best friend at 12:30 a.m. wishing me a happy birthday. I got up at 7:04 a.m., which I know because I sent him back a text message. I got several more birthday greetings and phone calls. Then I had a meeting with Richard Florida and some other Atlantic people during which I Googled several things related to the meeting. Then I went on a radio show in Colorado, which I know both because my calendar shows it, but also because I searched the radio station. Then I took a cab to Union Station (I texted, "On my way to Union Station") and snapped a picture of a tour bus that we passed which claimed to be "American-Owned & Operated." I got to New York around 7:45 p.m., when I Googled my hotel's address. The next morning, I went to WNYC at 160 Varick Street to be interviewed by Brian Lehrer, all of which is obvious from my Internet history, text messages and photos. Then I met with a prospective job candidate at Le Pain Quotidien according to my calendar and spent an hour researching RandTXT.com. Then I went to my book party at a private home, and took some photos, which Lantern pinpointed perfectly.

You could export most of this sequence to a Google Earth layer and look at it plotted with a time slider. Without trying to, I'd left a trail spelling out exactly what I did for 48 hours. Mobile forensics and mobile privacy don't have to sit in opposition, but what you can find with the former should inform our views about the latter. And you can suddenly find a ton with relatively simple tools.

The big deal about location data isn't the data itself; rather, the location data makes all the other information that can be extracted exponentially more useful. That's why mobile forensics is different, and why our devices may be where the bubbling privacy concerns of the last decade come to a head.

If our phones have become our outboard brains, we've actually put ourselves in a very difficult privacy position. Even searching a suspect's house could never yield a full inventory of that person's friends and acquaintances, the entire record of their voice and text communications -- and all the web pages he'd ever looked at. Now, law enforcement or a government official can have all of that in two minutes and physical access to one's cell phone.

Or as Cellebrite USA's CEO Aviad Ofrat excitedly told a trade magazine a couple years ago, "mobile device forensics is the future. With the wealth of data even a casual user has stored in his or her cellphone, smartphone, or PDA, it is quickly becoming THE one piece of evidence that is interrogated immediately."

Because where we go, so go our phones.

I'll be publishing part two of this series tomorrow after I visit the National Institute of Standards and Technology's mobile forensic tool testing lab in Gaithersburg, Maryland.

Wednesday, April 20, 2011

National Identity Strategy Envisions a More Trustworthy

Guest blog post by Leslie Harris, President and CEO of the Center for Democracy & Technology

Today the Administration released an ambitious, long-term strategy document called the National Strategy for Trusted Identities in Cyberspace (NSTIC). The Strategy puts forth a vision where individuals can choose to use a smaller number of secure, privacy-preserving, and convenient online identities. This would be a shift away from today’s norm of numerous usernames, passwords, and online accounts scattered across the Web.

Importantly, the Administration has turned to the private sector to make this vision a reality. The Strategy is not a national ID program—in fact, it’s not an ID “program” at all. It is a call for leadership and innovation from private companies. The government’s role must now be to advocate for its citizens and to support the development of a fair and useful system.

Why should the American people care about a “strategy” for Internet identity?

First, a growing number of our Internet transactions require an identity. We’re continually prompted to create new accounts to participate in online social networking, shopping, banking, and forums. Most of us have no idea how our identifying information will be used or shared. It certainly doesn’t help that we have to offer a fresh set of information to every new service that comes along. Without a new approach, this trend will continue. We deserve better control over our identity and stronger assurances that it will not be misused. Innovation isn’t slowing down; we have to catch up.

Secondly, services that will make our lives easier and more convenient—sometimes involving highly sensitive information—are still waiting to come fully online.  Health care and government services are slowly staking out an Internet presence, but they will remain at the starting line until a reliable and trustworthy platform for establishing and confirming user identity exists.

We’re pleased to see the Strategy has made individuals its first priority. The Administration must remain firmly dedicated to an identity ecosystem that is voluntary, protective of privacy, affords users a wide variety of choices for whether and how they will convey their identity online, and compliant with a full set of Fair Information Practice Principles. This effort must also be built on the foundation of comprehensive privacy legislation. We encourage the Administration to incorporate its existing support for baseline privacy legislation with the Strategy’s implementation.

Finally, the Strategy recognizes that anonymity and pseudonymity—crucial elements of our privacy and First Amendment rights—are and must remain vital characteristics of the Internet alongside any new identity ecosystem.

The Strategy is the beginning of a long journey through complicated technology standards and policy rules. If its vision is realized, consumers, businesses, and governments all have a lot to gain. It will only succeed, however, with meaningful engagement from all stakeholders. We are eager to see the Strategy’s implementation plan and hope the Strategy leads to a productive partnership.