New paper on Wi-Fi positioning systems

Regular readers will have come across (or participated in shaping) some of my work over the last year as I looked at the different ways that device identity and personal identity collide in mobile location technology.

In the early days following Google&#39s Street View WiFi snooping escapades, I became increasingly frustrated that public and official attention centered on Google&#39s apparently accidental collection of unencrypted network traffic when there was a much worse problem staring us in the face.

Unfortunately the deeper problem was also immensely harder to grasp since it required both a technical knowledge of networked devices and a willingness to consider totally unpredicted ways of using (or misusing) information.

As became clear from a number of the conversations with other bloggers, even many highly technical people didn&#39t understand some pretty basic things – like the fact that personal device identifiers travel in the clear on encrypted WiFi networks… Nor was it natural for many in our community to think things through from the perspective of privacy threat analysis.

This got me to look at the issues even more closely, and I summarized my thinking at PII 2010 in Seattle.

A few months ago I ran into Dr. Ann Cavoukian, the Privacy Commissioner of Ontario, who was working on the same issues.  We decided to collaborate on a very in-depth look at both the technology and policy implications, aiming to produce a document that could be understood by those in the policy community and still serve as a call to the technical community to deal appropriately with the identity issues, seeking what Ann calls “win-win” solutions that favor both privacy and innovation.

Ann&#39s team deserves all the credit for the thorough literature research and clear exposition.  Ann expertly describes the policy issues and urges us as technologists to adopt Privacy By Design principles for our work. I appreciate having had the opportunity to collaborate with such an innovative group.  Their efforts give me confidence that even difficult technical issues with social implications can be debated and decided by the people they affect.

Please read WiFi Positioning Systems: Beware of Unintended Consequences and let us know what you think – I invite you to comment (or tweet or email me) on the technical, policy and privacy-by-design aspects of the paper.

WSJ: Federal Prosecutors investigate smartphone apps

If you have kept up with the excellent Wall Street Journal series on smartphone apps that inappropriately collect and release location information, you won&#39t be surprised at their latest chapter:  Federal Prosecutors are now investigating information-sharing practices of mobile applications, and a Grand Jury is already issuing subpoenas.  The Journal says, in part:

Federal prosecutors in New Jersey are investigating whether numerous smartphone applications illegally obtained or transmitted information about their users without proper disclosures, according to a person familiar with the matter…

The criminal investigation is examining whether the app makers fully described to users the types of data they collected and why they needed the information—such as a user&#39s location or a unique identifier for the phone—the person familiar with the matter said. Collecting information about a user without proper notice or authorization could violate a federal computer-fraud law…

Online music service Pandora Media Inc. said Monday it received a subpoena related to a federal grand-jury investigation of information-sharing practices by smartphone applications…

In December 2010, Scott Thurm wrote Your Apps Are Watching You,  which has now been “liked” by over 13,000 people.  It reported that the Journal had tested 101 apps and found that:

… 56 transmitted the phone&#39s unique device identifier to other companies without users’ awareness or consent.  Forty-seven apps transmitted the phone&#39s location in some way. Five sent a user&#39s age, gender and other personal details to outsiders.  At the time they were tested, 45 apps didn&#39t provide privacy policies on their websites or inside the apps.

In Pandora&#39s case, both the Android and iPhone versions of its app transmitted information about a user&#39s age, gender, and location, as well as unique identifiers for the phone, to various advertising networks. Pandora gathers the age and gender information when a user registers for the service.

Legal experts said the probe is significant because it involves potentially criminal charges that could be applicable to numerous companies. Federal criminal probes of companies for online privacy violations are rare…

The probe centers on whether app makers violated the Computer Fraud and Abuse Act, said the person familiar with the matter. That law, crafted to help prosecute hackers, covers information stored on computers. It could be used to argue that app makers “hacked” into users’ cellphones.

[More here]

The elephant in the room is Apple&#39s own approach to location information, which should certainly be subject to investigation as well.   The user is never presented with a dialog in which Apple&#39s use of location information is explained and permission is obtained.  Instead, the user&#39s agreement is gained surreptitiously, hidden away  on page 37 of a 45 page policy that Apple users must accept in order to use… iTunes.  Why iTunes requires location information is never explained.  The policy simply states that the user&#39s device identifier and location are non-personal information and that Apple “may collect, use, transfer, and disclose non-personal information for any purpose“.

Any purpose?

Is it reasonable that companies like Apple can  proclaim that device identifiers and location are non-personal and then do whatever they want with them?  Informed opinion seems not to agree with them.  The International Working Group on Data Protection in Telecommunications, for example, asserted precisely the opposite as early as 2004.  Membership of the Group included “representatives from Data Protection Authorities and other bodies of national public administrations, international organisations and scientists from all over the world.”

More empirically, I demonstrated in Non-Personal information, like where you live that the combination of device identifier and location is in very many cases (including my own) personally identifying.  This is especially true in North America where many of us live in single-family dwellings.

[BTW, I have not deeply investigated the approach to sharing of location information taken by other smartphone providers – perhaps others can shed light on this.]

A Privacy Bill of Rights proposed for the US

The continuing deterioration of privacy and multi-party security due to short-sighted and unsustainable practices within our industry has begun to have the inevitable result, as reported by this article in the New York TImes.

A Commerce Department task force called for the creation of a ‘Privacy Bill of Rights’ for online consumers and the establishment of an office within the department that would work to strengthen privacy policies in the United States and coordinate initiatives with other countries.

The department’s Internet Policy Task Force, in a report released on Thursday, said the “Privacy Bill of Rights” would increase transparency on how user information was collected online, place limits on the use of consumer data by companies and promote the use of audits and other forms of enforcement to increase accountability.

The new protections would expand on the framework of Fair Information Practice Principles that address data security, notice and choice — or the privacy policies many users agree to on Web sites — and rights to obtaining information on the Internet.

The simple concept of notice and choice is not adequate as a basis for privacy protections,” said Daniel J. Weitzner, the associate administrator for the office of policy analysis and development at the Commerce Department’s National Telecommunications and Information Administration [emphasis mine – Kim].

The article makes the connection to the Federal Trade Commission&#39s “Do Not Track” proposal:

The F.T.C., in its report on online privacy this month, also called for improvements to the practice principles, but focused on installing a “do not track” mechanism that would allow computer users to opt out of having their information collected surreptitiously by third-party companies.

That recommendation caused concern in the online advertising industry, which has said that such a mechanism would hamper the industry’s growth and could potentially limit users’ access to free content online.

[The prospect of an online advertising industry deprived of its ability to surreptitiously collect information on us causes tears to well in my eyes.  I can&#39t continue!  I need a Kleenex!]

The proposed Privacy Policy Office would work with the administration, the F.T.C. and other agencies on issues surrounding international and commercial data privacy issues but would not have enforcement authority.

“America needs a robust privacy framework that preserves consumer trust in the evolving Internet economy while ensuring the Web remains a platform for innovation, jobs and economic growth,” the commerce secretary, Gary F. Locke, said in a statement. “Self-regulation without stronger enforcement is not enough. Consumers must trust the Internet in order for businesses to succeed online.”

All of this is, in my view, just an initial reaction to behaviors that are seriously out of control.  As information leakage goes, the surreptitious collection of information” to which the NYT refers is done at a scale that dwarfs Wiki Leaks, even if the subjects of the information are mere citizens rather than lofty officials of government.

I will personally be delighted when it is enshrined in law that a company can no longer get you to click on a privacy policy like this one and claim it is consent to sell your location to anyone it pleases.

Gov2.0 and Facebook ‘Like’ Buttons

I couldn&#39t agree more with the points made by identity architect James Brown in a very disturbing piece he has posted at The Other James Brown

James explains how the omnipresent Facebook  widget works as a tracking mechanism:  if you are a Facebook subscriber, then whenever you open a page showing the widget, your visit is reported to Facebook.

You don&#39t have to do anything whatsoever – or click the widget – to trigger this report.  It is automatic.  Nor are we talking here about anonymized information or simple IP address collection.  The report contains your Facebook identity information as well as the URL of the page you are looking at.

If you are familiar with the way advertising beacons operate, your first reaction might be to roll your eyes and yawn.  After all, tracking beacons are all over the place and we&#39ve known about them for years.

But until recently, government web sites – or private web sites treating sensitive information of any kind – wouldn&#39t be caught dead using tracking beacons. 

What has changed?  Governments want to piggyback on the reach of social networks, and show they embrace technology evolution.  But do they have procedures in place that ensure that the mechanisms they adopt are actually safe?  Probably not, if the growing use of the Facebook ‘Like’ button on these sites demonstrates.  I doubt those who inserted the widgets have any idea about how the underlying technology works – or the time or background to evaluate it in depth.  The result is a really serious privacy violation.

Governments need to be cautious about embracing tracking technology that betrays the trust citizens put in them.  James gives us a good explanation of the problem with Facebook widgets.  But other equally disturbing threats exist.  For example, should governments be developing iPhone applications when to use them, citizens must agree that Apple has the right to reveal their phone&#39s identifier and location to anyone for any purpose?    

In my view, data protection authorities are going to have to look hard at emerging technologies and develop guidelines on whether government departments can embrace technologies that endanger the privacy of citizens.

Let&#39s turn now to the details of James’ explanation.  He writes:

I am all for Gov2.0.  I think that it can genuinely make a difference and help bring public sector organisations and people closer together and give them new ways of working.  However, with it comes responsibility, the public sector needs to understand what it is signing its users up for.image

In my post Insurers use social networking sites to identify risky clients last week I mentioned that NHS Choices was using a Facebook ‘Like’ button on its pages and this potentially allows Facebook to track what its users were doing on the site.  I have been reading a couple of posts on ‘Mischa’s ramblings on the interweb’ who unearthed this issue here and here and digging into this a bit further to see for myself, and to be honest I really did not realise how invasive these social widgets can be.

Many services that government and public sector organisations offer are sensitive and personal. When browsing through public sector web portals I do not expect that other organisations are going to be able to track my visit – especially organisations such as Facebook which I use to interact with friends, family and colleagues.

This issue has now been raised by Tom Watson MP, and the response from the Department of Health on this issue of Facebook is:

“Facebook capturing data from sites like NHS Choices is a result of Facebook’s own system. When users sign up to Facebook they agree Facebook can gather information on their web use. NHS Choices privacy policy, which is on the homepage of the site, makes this clear.”

“We advise that people log out of Facebook properly, not just close the window, to ensure no inadvertent data transfer.”

I think this response is wrong on a number of different levels.  Firstly at a personal level, when I browse the UK National Health Service web portal to read about health conditions I do not expect them to allow other companies to track that visit; I don&#39t really care what anybody&#39s privacy policy states, I don&#39t expect the NHS to allow Facebook to track my browsing habits on the NHS web site.

Secondly, I would suggest that the statement “Facebook capturing data from sites like NHS Choices is a result of Facebook’s own system” is wrong.  Facebook being able to capture data from sites like NHS Choices is a result of NHS Choices adding Facebook&#39s functionality to their site.

Finally, I don&#39t believe that the “We advise that people log out of Facebook properly, not just close the window, to ensure no inadvertent data transfer.” is technically correct.

(Sorry to non-technical users but it is about to a bit techy…)

I created a clean Virtual Machine and installed HTTPWatch so I could see the traffic in my browser when I load an NHS Choices page.  This machine has never been to Facebook, and definitely never logged into it.  When I visit the NHS Choices page on bowel cancer the following call is made to Facebook:

http://www.facebook.com/plugins/like.php?href=http%3A%2F%2Fwww.nhs.uk%2fconditions%2fcancer-of-the-colon-rectum-or-bowel%2fpages%2fintroduction.aspx&layout=button_count&show_faces=true&width=450&action=like&colorscheme=light&height=21

 

AnonFacebook

So Facebook knows someone has gone to the above page, but does not know who.

 

Now go Facebook and log-in without ticking the ‘Keep logged in’ checkbox and the following cookie is deposited on my machine with the following 2 fields in it: (added xxxxxxxx to mask the my unique id)

  • datr: s07-TP6GxxxxxxxxkOOWvveg
  • lu: RgfhxpMiJ4xxxxxxxxWqW9lQ

If I now close my browser and go back to Facebook, it does not log me in – but it knows who I am as my email address is pre-filled.

 

Now head over back to http://www.nhs.uk/conditions/cancer-of-the-colon-rectum-or-bowel/pages/introduction.aspx and when the Facebook page is contacted the cookie is sent to them with the data:

  • datr: s07-TP6GxxxxxxxxkOOWvveg
  • lu: RgfhxpMiJ4xxxxxxxxWqW9lQ

FacebookNotLoggedIn

 

So even if I am not logged into Facebook, and even if I do not click on the ‘Like’ button, the NHS Choices site is allowing Facebook to track me.

Sorry, I don&#39t think that is acceptable.

[Update:  I originally misread James’ posting as saying the “keep me logged in” checkbox on the Facebook login page was a factor in enabling tracking – in other words that Facebook only used permanent cookies after you ticked that box.  Unfortunately this is not the case.  I&#39ve updated my comments in light of this information.

If you have authenticated to Facebook even once, the tracking widget will continue to collect information about you as you surf the web unless you manually delete your Facebook cookies from the browser.  This design is about as invasive of your privacy as you can possibly get…]

 

Android OEMs will need to use Google Location Service

Over at Daring Fireball, John Gruber tells us about Google&#39s approach to controlling content on Android, quoting a brief by Skyhook Wireless in the “complaint and jury demand” they filed against Google recently.

John discusses a couple of aspects of the filing, which he describes as “not long, and… written in pretty straightforward plain language, regarding Google’s control over which devices have access to the Android Market”.   In particular he calls our attention to the way Google is tying Android to it&#39s location service – the one made famous during the StreetView WiFi scandal:

23. On information and belief, Google has notified OEMs that they will need to use Google Location Service, either as a condition of the Android OS-OEM contract or as a condition of the Google Apps contract between Google and each OEM. Though Google claims the Android OS is open source, by requiring OEMs to use Google Location Service, an application that is inextricably bundled with the OS level framework, Google is effectively creating a closed system with respect to location positioning. Google’s manipulation suggests that the true purpose of Android is, or has become, to ensure that “no industry player can restrict or control the innovations of any other”, unless it is Google.

He bookends this with an ironic quote from Vic Gundotra, Google&#39s Vice-President for Engineering:

If you believe in openness, if you believe in choice, if you believe in innovation from everyone, then welcome to Android.

If Google is actually forcing OEMs to hook their users into its world-wide location database it adds one more sinister note to the dark architecture of StreetView location services.

[Thanks to Cameron Westland for the heads up]

Kim Komando on location services

Kim Komando has a great piece at USA Today where she explains geotagging through the experiences of two women who also happened to be using the foursquare location service.  This article is one of the first of what I expect will become a torrent as the media learns the implications of geolocation:

Sylvia was dining out with a friend. The restaurant manager interrupted her dinner to tell her she had a phone call. It was from a complete stranger who tracked her online. He had described her to the manager.

Louise was at a bar with colleagues. A stranger began talking to her. He knew a lot about her personal interests. Then, he pulled out his phone and showed her a photo. It was a picture of Louise that he found online.

Both of these stories are true. And they&#39re very unnerving. There is also a common thread. The women were tracked by something known as “geotagging.”

Geotagging adds GPS coordinates to your online posts or photos. You may be exposing this information without even knowing it. Geotagging is particularly popular with photos; many smartphones automatically geotag photos.

Photos can be plotted on a map for easy organization and viewing. But if you post photos online, and you could reveal your home address or child&#39s school. You&#39ve given a criminal a treasure map.

Layers of information

A geotagged photo is the most obvious threat to your privacy and safety. But, in Louise&#39s and Sylvia&#39s cases, there was more going on. Both used the location-based social-networking service Foursquare.

Location-based social-networking services are designed to help you meet up with family and friends. When you&#39re out and about, you check in with the site. At the coffee shop? Check in so friends nearby can find you.

Unless you have a stalker, these services aren&#39t particularly dangerous on their own. You need to think about the layers of information you leave online. As you use more services, it&#39s easier for criminals to track you.

Let&#39s say you post a photo of your new house to a photo site. The photo is geotagged. You&#39ve linked your photo account to Facebook. And you use Foursquare or Twitter on the go; updates are sent to your Facebook account.

One night you go to the movies. You send a tweet as you wait in line. When you get home, you discover you&#39ve been robbed. The burglar used your photo to find your address. He learned more about you on Facebook. Your tweet tipped him off to your location.

Thanks to a movie site, he knew exactly how long the movie ran. He scoped out your house and neighborhood on Google Street View. He devised a plan to get in and out fast and undetected.

Protecting yourself

If you use these services, protect yourself. Use a little common sense. First, don&#39t geotag photos of your house or your children. In fact, it&#39s best to disable geotagging until you specifically need it.

On the iPhone 4, tap Settings, then General, and then Location Services. You can select which applications can access GPS data. These options aren&#39t available in older iPhone software, so tap Settings, then General, then Reset. Tap Reset Location Warnings. You&#39ll be prompted if an application wants to access GPS data. You can then disallow it.

In Android, start the Camera app and open the menu at the left. Go into the settings and turn off geotagging or location storage, depending on which version of Android is on your phone. On a BlackBerry, click the Camera icon. Press the Menu button and select Options. Set the Geotagging option to Disabled. Save your settings.

You can also use an EXIF editor to remove location information from photos. EXIF data is information about a photo embedded in the file. Visit www.komando.com/news for free EXIF editors.

Don&#39t check in on Foursquare or similar sites from home. And make sure your Twitter program is not including GPS coordinates in your tweets.

For many people, Facebook ties everything together. Reconsider linking other accounts to Facebook. Pay close attention to your privacy settings. Only trusted friends should know when you are or aren&#39t at home. Finally, if you have contacts you don&#39t fully trust, it&#39s time to do a purge.

[Kim Komando hosts the nation&#39s largest talk radio show about computers and the Internet. To get the podcast or find the station nearest you, visit www.komando.com/listen. To subscribe to Kim&#39s free e-mail newsletters, sign up at www.komando.com/listen.. Contact her at C1Tech@gannett.com. ]

It is well worth reading Foursquare&#39s privacy policy – which is well thought out and makes Foursquare a paragon of virtue when compared to the contract with the devil you sign when you install iTunes, for example.  I&#39ll explore this more going forward.

Non-Personal Information – like where you live?

Last week I gave a presentation at PII 2010 in Seattle where I tried to summarize what I had learned from my recent work on WiFi location services and identity.  During the question period  an audience member asked me to return to the slide where I recounted how I had first encountered Apple&#39s new location tracking policy:

 

My questioner was clearly a bit irritated with me,  Didn&#39t I realize that the “unique device identifier” was just a GUID – a purely random number?  It wasn&#39t a MAC address.  It was not personally identifying.

The question really perplexed me, since I had just shown a slide demonstrating how if you go to this well-known web site (for example) and enter a location you find out who lives there (I used myself as an example, and by the way, “whitepages” releases this information even though I have had an unlisted number…).

I pointed out the obvious:  if Apple releases your location and a GUID to a third party on multiple occasions, one location will soon stand out as being your residence… Then presto, if the third pary looks up the address in a “Reverse Address” search engine, the “random” GUID identifies you personally forever more.  The notion that location information tied to random identifiers is not personally identifiable information is total hogwash.

My questioner then asked, “Is your problem that Apple&#39s privacy policy is so clear?  Do you prefer companies who don&#39t publish a privacy policy at all, but rather just take your information without telling you?”  A chorus of groans seemed to answer his question to everyone&#39s satisfaction.  But I personally found the question thought provoking.  I assume corporations publish privacy policies – even those as duplicitous as Apple&#39s – because they have to.  I need to learn more about why. 

[Meanwhile, if you&#39re wondering how I could possibly post my own residential address on my blog, it turns out I&#39ve moved and it is no longer my address.  Beyond that, the initial “A” in the listing above has nothing to do with my real name – it&#39s just a mechanism I use to track who has given out my personal information.]