Identity Management As A Service

A few weeks ago at the European Identity and Cloud Conference I gave a keynote called Conflicting Visions of Cloud Identity. It was the first time that I reported publicly on the work I've been doing over the last year on understanding what cloud computing means for identity – and vice versa.

The keynote led to many interesting exchanges with others at the conference. The conversations ranged from violent agreement to “animated dissidence” – and most important, to the discussion of many important nuances.

It became clear to me that a lot of us involved with information technology could really benefit from an open exchange about these issues. We have the chance to accelerate and align our understanding and to explore the complexities and opportunities.

So today I'd like to take a first step in that direction and lay out a few high level ideas that I'll flesh out more concretely in upcoming posts.  I hope these will goad some of you into elaborating, pushing back, and taking our conversation in other completely different directions.

Preparing for dramatic change

To me, the starting point for this conversation is that Identity Management and the way it is delivered will change dramatically over the next decade as organizations respond to new economic and social imperatives by adopting cloud technology.

We all need to understand this change.

Organizations will find they need new identity management capabilities to take full advantage of the cloud. They will also find that the most reliable and cost-effect way to obtain these capabilities is through Identity Management as a Service – i.e. using the cloud to master the cloud.

We can therefore predict with certainty that almost all organizations will subscribe to identity services that are cheaper, broader in scope and more capable than the systems of today.

Enterprises will use these services to manage authentication and authorization of internal employees, the supply chain, and customers (including individuals), leads and prospects. Governments will use them when interacting with other government agencies, enterprises and citizens.

Identity Management As A Service will require that we move beyond the models of identity management that have guided our thinking to date. A new service-based model will emerge combining more advanced capabilities with externalization of operations to achieve reduction in risk, effort and cost.

Redefining Identity Management

The term “Identity Management” will be redefined to include everything needed to provide and consume identity in our increasingly networked and federated world.  This is so profound that it constitutes a “reset”.

As a category, Identity Management will expand to encompass all aspects of identity:

  • registration of people, organizations, devices and services;
    management of credentials;
  • collection and proofing of attributes;
  • claims issuance;
  • claims acceptance;
  • assignment of roles;
  • management of groups;
  • cataloging of relationships;
  • maintenance of personalization information;
  • storage and controlled publication of information through directory;
  • confidential auditing; and
  • assurance of compliance.

The baseline capability of Identity Management will be to enhance the security and privacy of both organizations and individuals.

There will be a new market of next-generation identity management service providers with characteristics shaped by the importance of identity for both the protection of assets and the enhancement of relationships as we enter the era of the social enterprise.

Meanwhile, the current market for identity management products will be challenged by the simplification, cost reduction and increased innovation possible in the cloud.

Going forward, the term Identity Management As A Service will come up so often that we need an acronym.  For the time being I'm going to adopt the one my friend Eric Norlan proposed over six years ago : IDMaaS. While we're at it, it is worth looking at Eric's prescient article in ZDNet - he wrote it back in 2006 when he was a partner at Digital ID World. Eric reports on a conversation where Jamie Lewis (then CEO of the Burton Group) argued that “companies would find identity data too important to hand-over to others” – a view that certainly described the way enterprises felt at that time.  These issues are still critically important, though many profound evolutions have, I think, transformed the variables in the equations.  These new variables will be ones we want to drill into going forward.

Microsoft and IDMaaS

One of the reasons I want to share my thoughts about Identity Management as a Service now is that they constitute part of the theoretical framework that lies behind many of the decisions about the kind of organizational identity service we at Microsoft are offering. 

I'm therefore really excited to say that today we are able to start bringing you up to speed on exactly what that is.  Here's a quote from today's blog post by my close colleague and friend John Shewchuk, the Technical Fellow who plays a key role in getting our cloud identity offering engineered right: 

What is Windows Azure Active Directory?

We have taken Active Directory, a widely deployed, enterprise-grade identity management solution, and made it operate in the cloud as a multitenant service with Internet scale, high availability, and integrated disaster recovery.

Since we first talked about it in November 2011, Windows Azure Active Directory has shown itself to be a robust identity and access management service for both Microsoft Office 365 and Windows Azure–based applications.

In the interim, we have been working to enhance Windows Azure Active Directory by adding new, Internet-focused connectivity, mobility, and collaboration capabilities that offer value to applications running anywhere and on any platform. This includes applications running on mobile devices like iPhone, cloud platforms like Amazon Web Services, and technologies like Java.

The easiest way to think about Windows Azure Active Directory is that Microsoft is enabling an organization’s Active Directory to operate in the cloud. Just like the Active Directory feature in the Windows Server operating system that operates within your organization, the Active Directory service that is available through Windows Azure is your organization’s Active Directory. Because it is your organization’s directory, you decide who your users are, what information you keep in your directory, who can use the information and manage it, and what applications are allowed to access that information. And if you already have on-premises Active Directory, this isn’t an additional, separate copy of your directory that you have to manage independently; it is the same directory you already own that has been extended to the cloud.

Meanwhile, it is Microsoft’s responsibility to keep Active Directory running in the cloud with high scale, high availability, and integrated disaster recovery, while fully respecting your requirements for the privacy and security of your information.

John's post is called Reimagining Active Directory for the Social Enterprise.  It's done in two parts, and following that John will join into our broader conversation about the identity management reset.   I hope the combination of our two blogs can help animate an industry-wide discussion while providing a specific channel through which people can get the information they need about Microsoft's identity service offering.

Later this week:  The Changing Model of Identity Management.  I hope to see you there.

 

Attorneys General swarm Google

By now everyone has seen the “this stuff matters” box on Google's search page.   The “This stuff matters” message is pretty interesting – it sounds like Google understands our concerns and is taking them seriously.  On that basis I expect many people – fearing another 80 page privacy policy – will just move on to get their search result.

Google has its way with us

But some will actually take the time to follow the link.  And what they'll see actually is important.

First, they'll find out that beginning this Thursday Google will amalgamate all the information it has about their activities and postings on all of Google's sites and services into a single account profile.  This in spite of the fact that most people put content on those sites and entered queries into Google search pages thinking the information was limited to the specific context in which they were participating.

Second, they'll find out that as customers they have no choice about the matter.  Even though in many cases they have helped create the knowledge and content that makes Google successful, their option if they dislike the policy is to completely stop using Google sites by Wednesday February 29th 2012. 

Of course all of this is perfectly in keeping with the creepy “Real Names” initiative forced upon us a few months ago.  At that time, we were told “Real Names” only applied to “certain Google sites” – like Google+.  What a surprise that so little time later, ALL account and profile information from ALL Google properties is being amalgamated under a single privacy and identity policy!  As we predicted, Real Names is slithering into the whole fabric of the company's offerings, whether specific sites benefit from what will often be “over-identification” or not.

Happily, one group of people who actually bothered to look into the change were the Attorneys General of the United States.  Today they published a cogent and devastating letter that does an admirable job of enumerating the many deeply disturbing implications of Google's latest identity initiative.  It begins,

“Google’s new privacy policy is troubling for a number of reasons. On a fundamental level, the policy appears to invade consumer privacy by automatically sharing personal information consumers input into one Google product with all Google products. Consumers have diverse interests and concerns, and may want the information in their Web History to be kept separate from the information they exchange via Gmail. Likewise, consumers may be comfortable with Google knowing their Search queries but not with it knowing their whereabouts, yet the new privacy policy appears to give them no choice in the matter, further invading their privacy. It rings hollow to call their ability to exit the Google products ecosystem a “choice” in an Internet economy where the clear majority of all Internet users use – and frequently rely on – at least one Google product on a regular basis.”

The Attorneys General then go on to discuss the contagion between Google's consumer offerings and their enterprise ones…  What does this kind of identity grab mean for companies and governments who have put corporate and state information under Google's stewardship?  Can the companies who steward the resources of the World Wide Web change their privacy and other policies in radical and even maniacal ways without regard to the policies in effect when those resources were created?   Can they simply tell those who have bought into previous promises to either accept their brave new world or “take a walk”?  As the attorneys put it,

“This invasion of privacy will be costly for many users to escape. For users who rely on Google products for their business – a use that Google has actively promoted1 – avoiding this information sharing may mean moving their entire business over to different platforms, reprinting any business cards or letterhead that contained Gmail addresses, re-training employees on web-based sharing and calendar services, and more. The problem is compounded for the many federal, state, and local government agencies that have transitioned to Google Apps for Government at the encouragement of your company, and that now will need to spend taxpayer dollars determining how this change affects the security of their information and whether they need to switch to different platforms.”

I urge everyone to read the letter in full and think deeply about the consequences.  

Not long ago, John Fontana suggested we get together to discuss the degree to which the Laws of Identity remain relevant seven years after they were published.  I look forward to that conversation.  Google's actions show there are still companies who could benefit from reading them.  After all, it is clearly breaking three Laws of Identity:

  • Law 1:  User Control and Consent.  Users should never have identity information merged or divulged without their consent.
  • Law 2:  Minimal Disclosure for a Constrained Use.  It is wrong to link all information pertaining to a user across different contexts when it was provided for specific uses.
  • Law 4:  Directed Identity.  Systems should not create unnecessary correlation across different contexts unless people opt to do that.  They thus should be able support identitfiers that are limited to specific scopes – as has been the case at Google's sites until now.

And the Attorneys General are onto it…

Attorneys General Swarm Google

Disintermediation: an Amazon parable

New York TImes Technology ran a story yesterday about the publishing industry that is brimming with implications for almost everyone in the Internet economy.  It is about Amazon and what marketing people call “disintermediation”.  Not the simple kind that was the currency of the dot.com boom;  we are looking here at a much more advanced case:

SEATTLE — Amazon.com has taught readers that they do not need bookstores. Now it is encouraging writers to cast aside their publishers.

Amazon will publish 122 books this fall in an array of genres, in both physical and e-book form. It is a striking acceleration of the retailer’s fledging publishing program that will place Amazon squarely in competition with the New York houses that are also its most prominent suppliers.

It has set up a flagship line run by a publishing veteran, Laurence Kirshbaum, to bring out brand-name fiction and nonfiction…

Publishers say Amazon is aggressively wooing some of their top authors. And the company is gnawing away at the services that publishers, critics and agents used to provide…

Of course, as far as Amazon executives are concerned, there is nothing to get excited about:

“It’s always the end of the world,” said Russell Grandinetti, one of Amazon’s top executives. “You could set your watch on it arriving.”

But despite the sarcasm, shivers of disintermediation are going down the spines of many people in the publishing industry:

“Everyone’s afraid of Amazon,” said Richard Curtis, a longtime agent who is also an e-book publisher. “If you’re a bookstore, Amazon has been in competition with you for some time. If you’re a publisher, one day you wake up and Amazon is competing with you too. And if you’re an agent, Amazon may be stealing your lunch because it is offering authors the opportunity to publish directly and cut you out. ” [Read whole story here.]

If disintermediation is something you haven't thought about much, you might start with a look at wikipedia:

In economics, disintermediation is the removal of intermediaries in a supply chain: “cutting out the middleman”. Instead of going through traditional distribution channels, which had some type of intermediate (such as a distributor, wholesaler, broker, or agent), companies may now deal with every customer directly, for example via the Internet. One important factor is a drop in the cost of servicing customers directly.

Note that the “removal” normally proceeds by “inserting” someone or something new into transactions.  We could call the elimination of bookstores “first degree disintermediation” – the much-seen phenomenon of replacement of the existing distribution channel.   But it seems intuitively right to call the elimination of publishers “second degree disintermediation” – replacement of the mechanisms of production, including everything from product development through physical manufacturing and marketing, by the entities now predominating in distribution.  

The parable here is one of first degree disintermediation “spontaneously” giving rise to second degree disintermediation, since publishers have progressively less opportunity to succeed in the mass market without Amazon as time goes on.  Of course nothing ensures that Amazon's execution will cause it to succeed in a venture quite different from its current core competency.  But clearly the economic intrinsics stack the deck in its favor. Even without displacing its new competitors it may well skim off the most obvious and profitable projects, with the inevitable result of underfunding what remains.

I know.  You're asking what all this has to do with identityblog.

In my view, one of the main problems of reusable identities is that in systems like SAML, WS-Federation and Live ID, the “identity provider” has astonishing visibility onto the user's relationship with the relying parties (e.g. the services who reuse the identity information they provide).  Not only does the identity provider know what consumers are visiting what services; it knows the frequency and patterns of those visits.   If we simply ignore this issue and pretend it isn't there, it will become an Achilles Heel.

Let me fabricate an example so I can be more concrete.  Suppose we arrive at a point where some retailer decides to advise consumers to use their Facebook credentials to log in to its web site.  And let's suppose the retailer is super successful.  With Facebook's redirection-based single sign-on system, Facebook would be able to compile a complete profile of the retailer's customers and their log-on patterns.  Combine this with the intelligence from “Like” buttons or advertising beacons and Facebook (or equivalent) could actually mine the profiles of users almost as effectively as the retailer itself.  This knowledge represents significant leakage of the retailer's core intellectual property – its relationships with its customers.

All of this is a recipe for disintermediation of the exact kind being practiced by Amazon, and at some point in the process, I predict it will give rise to cases of spine-tingling that extend much more broadly than to a single industry like publishing. 

By the time this becomes obvious as an issue we can also predict there will be broader understanding of “second degree disintermediation” among marketers.  This will, in my view, bring about considerable rethinking of some current paradigms about the self-evident value of unlimited integration into social networks.  Paradoxically disintermediation is actually a by-product of the privacy problems of social networks.  But here it is not simply the privacy of end users that is compromised, but that of all parties to transactions. 

This problem of disintermediation is one of the phenomena leading me to conclude that minimal disclosure technologies like U-Prove and Idemix will be absolutely essential to a durable system of reusable identities.  With these technologies, the ability of the identity provider to disintermediate is broken, since it has no visibility onto the transactions carried out by individual users and cannot insert itself into the relationship between the other parties in the system. 

Importantly, while disintermediation becomes impossible, it is still possible to meter the use of credentials by users without any infringement of privacy, and therefore to build a viable business model.

I hope to write more about this more going forward, and show concretely how this can work.

A social network or the name police – but not both

It seems a number of people take the use of “real names” on the Internet as something we should all just accept without further thought.  But a recent piece by Gartner Distinguished Analyst Bob Blakley shows very clearly why at least a bit of thought is actually called for – at least amongst those of us building the infrastructure for cyberspace: 

… Google is currently trying to enforce a “common name” policy in Google+. The gist of the policy is that “your Google+ name must be “THE” name by which you are commonly known”.

This policy is insane. I really mean insane; the policy is simply completely divorced from the reality of how names really work AND the reality of how humans really work, and it’s also completely at odds with what Google is trying to achieve with G+.  (my emphasis – Kim)

The root of the problem is that Google suffers from the common – but false – belief that names are uniquely and inherently associated with people. I’ve already explained why this belief is false elsewhere, but for the sake of coherence, I’ll summarize here.

There isn’t a one-to-one correspondence between people and names. Multiple people share the same name (George Bush, for example, or even me: George Robert Blakley III), and individual people have multiple names (George Eliot, George Sand, George Orwell, or Boy George – or even me, George Robert “Bob” Blakley III). And people use different names in different contexts; King George VI was “Bertie” to family and close friends.

THERE IS NO SUCH THING AS A “REAL” NAME.

A name is not an attribute of a person; it is an identifier of a person, chosen arbitrarily and changeable at will. In England, I can draw up a deed poll in my living room and change my name at any time I choose, without the intervention or assistance of any authority. In California, I apparently don’t even need to write anything down: I can change my name simply by having people call me by the new name on the street.

COMMON NAMES ARE NOT SINGULAR OR UNIQUE.

Richard Garriott is COMMONLY known as “Richard Garriott” in some contexts (check Wikipedia), and COMMONLY known as Lord British in other contexts (go to a computer gaming convention). Bob Wills and Elvis are both “The King”.

Despite these complexities, Google wants to intervene in your choice of name. They want veto power over what you can call yourself.

Reversing the presumption that I choose what to be called happens – in the real world – only in circumstances which diminish the dignity of the individual. We choose the names of infants, prisoners, and pets. Imposing a name on someone is repression; free men and women choose their names for themselves.

But the Google+ common name policy isn’t even consistently repressive; it sometimes vetoes names which ARE “common” in the sense Google intends (Violet Blue is an example), it sometimes accepts plausible names based on clearly fraudulent evidence, and it even “verifies” fraudulent names.

Google+’s naming policy isn’t failing because it’s poorly implemented, or because Google’s enforcement team is stupid. It’s failing because what they’re trying to do is (1) impossible, and (2) antisocial.

(2) is critical. Mike Neuenschwander has famously observed that social software is being designed by the world’s least sociable people, and Google+ seems to be a case in point. Google wants to be in the “social” business. But they’re not behaving sociably. They’re acting like prison wardens. No one will voluntarily sign up to be a prisoner. Every day Google persists in their insane attempt to tell people what they can and can’t call themselves, Google+ as a brand becomes less sociable and less valuable. The policy is already being described as racist and sexist; it’s also clearly dangerous to some disadvantaged groups.

If you want to be the host of a social network, you’ve got to create a social space. Creating a social space means making people comfortable. That’s hard, because people don’t fit in any set of little boxes you want to create – especially when it comes to names. But that’s table stakes for social – people are complicated; deal with it. Facebook has an advantage here; despite its own idiotic real-names policy and its continual assaults on privacy, the company has real (i.e. human) sociability in its DNA – it was created by college geeks who wanted to get dates; Google+ wasn’t, and it shows.

If Google’s intention in moving into social networking is to sell ads, Google+’s common names policy gives them a lock on the North American suburban middle-aged conservative white male demographic. w00t.

The Google+ common name policy is insane. It creates an antisocial space in what is supposed to be a social network. It is at odds with basic human social behavior; its implementation is NECESSARILY arbitrary and infuriating, and it is actively damaging the Google+ brand and indeed the broader Google brand.

The problem is not flawed execution; it is that the policy itself is fundamentally unsound, unworkable, and unfixable.

Google can be a social network operator, or they can be the name police. They can’t be both. They need to decide – soon. If I were Google, I’d scrap the policy – immediately – and let people decide for themselves what they will be called.

 [Read the whole piece.  BTW,  Mike Neuenschwander has hit the nail on the head yet again.]

24 year old student lights match: Europe versus Facebook

If you are interested in social networks, don't miss the slick video about Max Schrems’ David and Goliath struggle with Facebook over the way they are treating his personal information.  Click on the red “CC” in the lower right-hand corner to see the English subtitles.

Max is a 24 year old law student from Vienna with a flair for the interview and plenty of smarts about both technology and legal issues.  In Europe there is a requirement that entities with data about individuals make it available to them if they request it.  That's how Max ended up with a personalized CD from Facebook that he printed out on a stack of paper more than a thousand pages thick (see image below). Analysing it, he came to the conclusion that Facebook is engineered to break many of the requirements of European data protection.  He argues that the record Facebook provided him finds them to be in flagrante delicto.  

The logical next step was a series of 22 lucid and well-reasoned complaints that he submitted to the Irish Data Protection Commissioner (Facebook states that European users have a relationship with the Irish Facebook subsidiary).  This was followed by another perfectly executed move:  setting up a web site called Europe versus Facebook that does everything right in terms using web technology to mount a campaign against a commercial enterprise that depends on its public relations to succeed.

Europe versus Facebook, which seems eventually to have become an organization, then opened its own YouTube channel.  As part of the documentation, they publicised the procedure Max used to get his personal CD.  Somehow this recipe found its way to reddit  where it ended up on a couple of top ten lists.  So many people applied for their own CDs that Facebook had to send out an email indicating it was unable to comply with the requirement that it provide the information within a 40 day period.

If that seems to be enough, it's not all.  As Max studied what had been revealed to him, he noticed that important information was missing and asked for the rest of it.  The response ratchets the battle up one more notch: 

Dear Mr. Schrems:

We refer to our previous correspondence and in particular your subject access request dated July 11, 2011 (the Request).

To date, we have disclosed all personal data to which you are entitled pursuant to Section 4 of the Irish Data Protection Acts 1988 and 2003 (the Acts).

Please note that certain categories of personal data are exempted from subject access requests.
Pursuant to Section 4(9) of the Acts, personal data which is impossible to furnish or which can only be furnished after disproportionate effort is exempt from the scope of a subject access request. We have not furnished personal data which cannot be extracted from our platform in the absence of is proportionate effort.

Section 4(12) of the Acts carves out an exception to subject access requests where the disclosures in response would adversely affect trade secrets or intellectual property. We have not provided any information to you which is a trade secret or intellectual property of Facebook Ireland Limited or its licensors.

Please be aware that we have complied with your subject access request, and that we are not required to comply with any future similar requests, unless, in our opinion, a reasonable period of time has elapsed.

Thanks for contacting Facebook,
Facebook User Operations Data Access Request Team

What a spotlight

This throws intense light on some amazingly important issues. 

For example, as I wrote here (and Max describes here), Facebook's “Like” button collects information every time an Internet user views a page containing the button, and a Facebook cookie associates that page with all the other pages with “Like” buttons visited by the user in the last 3 months. 

If you use Facebook, records of all these visits are linked, through cookies, to your Facebook profile – even if you never click the “like” button.  These long lists of pages visited, tied in Facebook's systems to your “Real Name identity”, were not included on Max's CD. 

Is Facebook prepared to argue that it need not reveal this stored information about your personal data because doing so would adversely affect its “intellectual property”? 

It will be absolutely amazing to watch how this issue plays out, and see just what someone with Max's media talent is able to do with the answers once they become public. 

The result may well impact the whole industry for a long time to come.

Meanwhile, students of these matters would do well to look at Max's many complaints:

no

date

topic

status

files

01

18-AUG-2011

Pokes.
Pokes are kept even after the user “removes” them.

Filed with the Irish DPC

Complaint (PDF)
Attachments (ZIP)

02

18-AUG-2011

Shadow Profiles.
Facebook is collecting data about people without their knowledge. This information is used to substitute existing profiles and to create profiles of non-users.

Filed with the Irish DPC

Complaint (PDF)
Attachments (ZIP)

03

18-AUG-2011

Tagging.
Tags are used without the specific consent of the user. Users have to “untag” themselves (opt-out).
Info: Facebook announced changes.

Filed with the Irish DPC

Complaint (PDF)
Attachments (ZIP)

04

18-AUG-2011

Synchronizing.
Facebook is gathering personal data e.g. via its iPhone-App or the “friend finder”. This data is used by Facebook without the consent of the data subjects.

Filed with the Irish DPC

Complaint (PDF)
Attachments (ZIP)

05

18-AUG-2011

Deleted Postings.
Postings that have been deleted showed up in the set of data that was received from Facebook.

Filed with the Irish DPC

Complaint (PDF)
Attachments (ZIP)

06

18-AUG-2011

Postings on other Users’ Pages.
Users cannot see the settings under which content is distributed that they post on other’s pages.

Filed with the Irish DPC

Complaint (PDF)
Attachments (ZIP)

07

18-AUG-2011

Messages.
Messages (incl. Chat-Messages) are stored by Facebook even after the user “deleted” them. This means that all direct communication on Facebook can never be deleted.

Filed with the Irish DPC

Complaint (PDF)
Attachments (ZIP)

08

18-AUG-2011

Privacy Policy and Consent.
The privacy policy is vague, unclear and contradictory. If European and Irish standards are applied, the consent to the privacy policy is not valid.

Filed with the Irish DPC

Complaint (PDF)
Attachments (ZIP)

09

18-AUG-2011

Face Recognition.
The new face recognition feature is an inproportionate violation of the users right to privacy. Proper information and an unambiguous consent of the users is missing.

Filed with the Irish DPC

Complaint (PDF)
Attachments (ZIP)

10

18-AUG-2011

Access Request.
Access Requests have not been answered fully. Many categories of information are missing.

Filed with the Irish DPC

Complaint (PDF)
Attachments (ZIP)

11

18-AUG-2011

Deleted Tags.
Tags that were “removed” by the user, are only deactivated but saved by Facebook.

Filed with the Irish DPC

Complaint (PDF)
Attachments (ZIP)

12

18-AUG-2011

Data Security.
In its terms, Facebook says that it does not guarantee any level of data security.

Filed with the Irish DPC

Complaint (PDF)
Attachments (ZIP)

13

18-AUG-2011

Applications.
Applications of “friends” can access data of the user. There is no guarantee that these applications are following European privacy standards.

Filed with the Irish DPC

Complaint (PDF)
Attachments (ZIP)

14

18-AUG-2011

Deleted Friends.
All removed friends are stored by Facebook.

Filed with the Irish DPC

Complaint (PDF)
Attachments (ZIP)

15

18-AUG-2011

Excessive processing of Data.
Facebook is hosting enormous amounts of personal data and it is processing all data for its own purposes.
It seems Facebook is a prime example of illegal “excessive processing”.

Filed with the Irish DPC

Complaint (PDF)
Attachments (ZIP)

16

18-AUG-2011

Opt-Out.
Facebook is running an opt-out system instead of an opt-in system, which is required by European law.

Filed with the Irish DPC

Complaint (PDF)
Attachments (ZIP)

 

24-AUG-2011

Letter from the Irish DPC.

 

Letter (PDF)

 

15-SEPT-2011

Letter to the Irish DPC concerning the new privacy policy and new settings on Facebook.

 

Letter (PDF)

17

19-SEPT-2011

Like Button.
The Like Button is creating extended user data that can be used to track users all over the internet. There is no legitimate purpose for the creation of the data. Users have not consented to the use.

Filed with the Irish DPC

Complaint (PDF)
Attachments (ZIP)

18

19-SEPT-2011

Obligations as Processor.
Facebook has certain obligations as a provider of a “cloud service” (e.g. not using third party data for its own purposes or only processing data when instructed to do so by the user).

Filed with the Irish DPC

Complaint (PDF)
Attachments (ZIP)

19

19-SEPT-2011

Picture Privacy Settings.
The privacy settings only regulate who can see the link to a picture. The picture itself is “public” on the internet. This makes it easy to circumvent the settings.

Filed with the Irish DPC

Complaint (PDF)
Attachments (ZIP)

20

19-SEPT-2011

Deleted Pictures.
Facebook is only deleting the link to pictures. The pictures are still public on the internet for a certain period of time (more than 32 hours).

Filed with the Irish DPC

Complaint (PDF)
Attachments (ZIP)

21

19-SEPT-2011

Groups.
Users can be added to groups without their consent. Users may end up in groups that lead other to false impressions about a person.

Filed with the Irish DPC

Complaint (PDF)
Attachments (ZIP)

22

19-SEPT-2011

New Policies.
The policies are changed very frequently, users do not get properly informed, they are not asked to consent to new policies.

Filed with the Irish DPC

Complaint (PDF)
Attachments (ZIP)

 

Arrogant bullies versus Superheroine

Does ANYONE who has thought about digital identity in the last five years NOT know about Identity Woman?  I don't think so!

I personally know hundreds – I'll even say thousands –  of influential people around the world (in Europe, Asia and North America, in big companies and tiny startups, in government, the Academic world and NGOs,  in non-profit and for-profit ventures) who see Identity Woman as I do:  the soul of a very broad and interactive technical community, a moral force for good and excellence, and a smart innovator.  Besides that, did I say, a great lady and a superheroine?

Identity Woman is a super-talented facilitator – who operates outside the box. She has thrown herself into the task of getting a whole world of self-directed people working on identity for companies big and small to understand each other – and even to learn from and motivate each other.

So what would you think of someone who took it upon themselves to stop her from calling herself “Identity Woman”?  Does the word “control freak” come to mind?  How about “bully”.  Or maybe “megalomaniac”?

Or how about Google Plus – the supposedly cool and privacy friendly new social network.

It turns out Google Plus is not cool enough to tolerate even a single “Identity Woman”, in spite of her overwhealmingly positive reputation and the fact that an exact search on her name returns 390,000 hits on Google's own search engine!

This is not a good day.  I'm sick and tired of seeing social network moguls pushing people around because we help them grow powerful.  Enough already!  Social networks are big because they are OUR networks.  They need to be run in ways that respect the nature of a free society.  This is going to become a social battleground.

Go over to Identity Woman's site for the whole sad story. It teaches a lot about the need for a whole spectrum of identity requirements.  Sure, there are times when people need to present “natural” identities that reflect what their parents called them.   But in real life we don't necessarily do that in our informal interactions.  We use nicknames and partial names and sometimes keep our names to ourselves.  Social networks need to grasp these nuances.  And those trying to limit our behaviors and squeeze our potential should just back off.

[More on this theoretical issue here.]

Linked In strikes out

According to this piece in Digital Trend, LinkedIn has “opted” 100 million of us into sharing private information within advertisements. This includes posting our names and photos as advertisers’ helpers.

“When a LinkedIn user views a third-party advertisement on the social network, they will see user profile pictures and names of connections if that connection has recommended or followed a brand. Any time that a user follows a brand, they unwittingly become a cheerleader for the company or organization if it advertises through LinkedIn.”

And in case that doesn't surprise you, how about this:

“In order to opt out of social advertising, the LinkedIn user has to take four steps to escape third-party advertisements:

“Hover over the user name in the top right hand corner of any LinkedIn page and click ‘Settings’. On the Settings page, click ‘Account’. On the Account tab, click ‘Manage Social Advertising’. Uncheck the box next to “LinkedIn may use my name, photo in social advertising.” and click the save button.”

What a mistake.

I know there are many who think that if Facebook can take the huddled masses to the cleaners, why shouldn't everyone?

It seems obvious that the overwhelming majority of people who participate in Facebook are still a few years away from understanding and reacting to what they have got themselves into.

But Linked In's membership is a lot more savvy about the implications of being on the site – and why they are sharing information there. Much of their participation has to do with future opportunities, and everyone is sensitive about the need to control and predict how they will be evaluated later in their career. Until yesterday I for one had been convinced that Linked In was smart enough to understand this.

But apparently not.  And I think it will turn out that many of the professionals who until now have been happy to participate will choke on the potential abuse of their professional information and reputation – and Linked In's disregard for their trust.

My conclusion?  Linked in has just thrown down the gauntlet and challenged us, as a community of professionals, to come up with safe and democratic ways to network.

This much is obvious: we need a network that respects the rights of the people in it. Linked In just lost my vote.

Who is harmed by a “Real Names” policy?

Skud at Geek Feminism Blog has created a wiki documenting work she and her colleagues are doing to “draft a comprehensive list” of those who would be harmed by a policy banning pseudonymity and requiring “real names”.

The result is impressive.  The rigour Skud and colleagues have applied to their quest has produced an information payload that is both illuminating and touching.

Those of us working on identity technology have to internalize the lessons here.  Over-identification is ALWAYS wrong.  But beyond that, there are people who are especially vulnerable to it.  They have to be treated as first class citizens with clear rights and we need to figure out how to protect them.  This goes beyond what we conventionally think of as privacy concerns (although perhaps it sheds light on the true nature of what privacy is – I'm still learning).

Often people argue in favor of “Real Names” in order to achieve accountability.  The fact is that technology offers us other ways to achieve accountability.  By leveraging the properties of minimal disclosure technology, we can allow people to remain anonymous and yet bar them from given environments if their behavior gets sufficiently anti-social.

But enough editorializing.  Here's Skud's intro.  Just remember that in this case the real enlightenment is in the details, not the summary.

This page lists groups of people who are disadvantaged by any policy which bans Pseudonymity and requires so-called “Real names” (more properly, legal names).

This is an attempt to create a comprehensive list of groups of people who are affected by such policies.

The cost to these people can be vast, including:

  • harassment, both online and offline
  • discrimination in employment, provision of services, etc.
  • actual physical danger of bullying, hate crime, etc.
  • arrest, imprisonment, or execution in some jurisdictions
  • economic harm such as job loss, loss of professional reputation, etc.
  • social costs of not being able to interact with friends and colleagues
  • possible (temporary) loss of access to their data if their account is suspended or terminated

The groups of people who use pseudonyms, or want to use pseudonyms, are not a small minority (some of the classes of people who can benefit from pseudonyms constitute up to 50% of the total population, and many of the others are classes of people that almost everyone knows). However, their needs are often ignored by the relatively privileged designers and policy-makers who want people to use their real/legal names.

Wait a minute.  Just got a note from the I Can't Stop Editorializing Department: the very wiki page that brings us Skud's analysis contains a Facebook “Like” button.  It might be worth removing it given that Facebook requires “Real Names”, and then transmits the URL of any page with a “Like” button to Facebook so it can be associated with the user's “Real Name” – whether or not they click on the button or are logged into Facebook.

Head over to the Office of Inadequate Security

First of all, I have to refer readers to the Office of Inadequate Security, apparently operated by databreaches.net. I suggest heading over there pretty quickly too – the office is undoubtedly going to be so busy you'll have to line up as time goes on.

So far it looks like the go-to place for info on breaches – it even has a twitter feed for breach junkies.

Recently the Office published an account that raises a lot of questions:

I just read a breach disclosure to the New Hampshire Attorney General’s Office with accompanying notification letters to those affected that impressed me favorably. But first, to the breach itself:

StudentCity.com, a site that allows students to book trips for school vacation breaks, suffered a breach in their system that they learned about on June 9 after they started getting reports of credit card fraud from customers. An FAQ about the breach, posted on www.myidexperts.com explains:

StudentCity first became concerned there could be an issue on June 9, 2011, when we received reports of customers travelling together who had reported issues with their credit and debit cards. Because this seemed to be with 2011 groups, we initially thought it was a hotel or vendor used in conjunction with 2011 tours. We then became aware of an account that was 2012 passengers on the same day who were all impacted. This is when we became highly concerned. Although our processing company could find no issue, we immediately notified customers about the incident via email, contacted federal authorities and immediately began a forensic investigation.

According to the report to New Hampshire, where 266 residents were affected, the compromised data included students’ credit card numbers, passport numbers, and names. The FAQ, however, indicates that dates of birth were also involved.

Frustratingly for StudentCity, the credit card data had been encrypted but their investigation revealed that the encryption had broken in some cases. In the FAQ, they explain:

The credit card information was encrypted, but the encryption appears to have been decoded by the hackers. It appears they were able to write a script to decode some information for some customers and most or all for others.

The letter to the NH AG’s office, written by their lawyers on July 1, is wonderfully plain and clear in terms of what happened and what steps StudentCity promptly took to address the breach and prevent future breaches, but it was the tailored letters sent to those affected on July 8 that really impressed me for their plain language, recognition of concerns, active encouragement of the recipients to take immediate steps to protect themselves, and for the utterly human tone of the correspondence.

Kudos to StudentCity.com and their law firm, Nelson Mullins Riley & Scarborough, LLP, for providing an exemplar of a good notification.

It would be great if StudentCity would bring in some security experts to audit the way encryption was done, and report on what went wrong. I don't say this to be punitive, I agree that StudentCity deserves credit for at least attempting to employ encryption. But the outcome points to the fact that we need programming frameworks that make it easy to get truly robust encryption and key protection – and to deploy it in a minimal disclosure architecture that keeps secrets off-line. If StudentCity goes the extra mile in helping others learn from their unfortunate experience, I'll certainly be a supporter.

The Idiot's Guide to Why Voicemail Hacking is a Crime

Pangloss sent me reeling recently with her statement that “in the wake of the amazing News of the World revelations, there does seem to be some public interest in a quick note on why there is (some) controversy around whether hacking mesages in someone's voicemail is a crime.”

What?  Outside Britain I imagine most of us have simply assumed that breaking into peoples’ voicemails MUST be illegal.   So Pangloss's excellent summary of the situation – I share just enough to reveal the issues – is a suitable slap in the face of our naivete:

The first relevant provision is RIPA (the Regulation of Investigatory Powers Act 2000) which provides that interception of communications without consent of both ends of the communication , or some other provision like a police warrant is criminal in principle. The complications arise from s 2(2) which provides that:

“….a person intercepts a communication in the course of its transmission by
means of a telecommunication system if, and only if … (he makes) …some or all of the contents of the communication available, while being transmitted, to a person other than the sender or intended recipient of the communication”. [my itals]

Section 2(4) states that an “interception of a communication” has also to be “in the course of its transmission” by any public or private telecommunications system. [my itals]

The argument that seems to have been been made to the DPP, Keir Starmer, on October 2010, by QC David Perry, is that voicemail has already been transmitted and is thus therefore no longer “in the course of its transmission.” Therefore a RIPA s 1 interception offence would not stand up. The DPP stressed in a letter to the Guardian in March 2011 that this interpretation was (a) specific to the cases of Goodman and Mulcaire (yes the same Goodman who's just been re-arrested and inded went to jail) and (b) not conclusive as a court would have to rule on it.

We do not know the exact terms of the advice from counsel as (according to advice given to the HC on November 2009) it was delivered in oral form only. There are two possible interpretations of even what we know. One is that messages left on voicemail are “in transmission” till read. Another is that even when they are stored on the voicemail server unread, they have completed transmission, and thus accessing them would not be “interception”.

Very few people I think would view the latter interpretation as plausible, but the former seem to have carried weight with the prosecution authorities. In the case of Milly Dowler, if (as seems likely) voicemails were hacked after she was already deceased, there may have been messages unread and so a prosecution would be appropriate on RIPA without worrying about the advice from counsel. In many other cases eg involving celebrities though, hacking may have been of already-listened- to voicemails. What is the law there?

When does a message to voicemail cease to be “in the course of transmission”? Chris Pounder pointed out in April 2011 that we also have to look at s 2(7) of RIPA which says

” (7)For the purposes of this section the times while a communication is being transmitted by means of a telecommunication system shall be taken to include any time when the system by means of which the communication is being, or has been, transmitted is used for storing it in a manner that enables the intended recipient to collect it or otherwise to have access to it.”

A common sense interpretation of this, it seems to me (and to Chris Pounder ) would be that messages stored on voicemail are deemed to remain “in the course of transmission” and hence capable of generating a criminal offence, when hacked – because it is being stored on the system for later access (which might include re-listening to already played messages).

This rather thoroughly seems to contradict the well known interpretation offered during the debates in the HL over RIPA from L Bassam, that the analogy of transmission of a voice message or email was to a letter being delievered to a house. There, transmission ended when the letter hit the doormat.

Fascinating issues.  And that's just the beginning.  For the full story, continue here.