XDI.ORG Privacy Statement
- This Version: http://www.xdi.org/docref/legal/xdi-org-privacy-policy-v2-2004-10-20.html
- Latest Version: http://www.xdi.org/docref/legal/xdi-org-privacy-policy.html
- Previous Versions: http://www.xdi.org/docref/legal/xdi-org-privacy-policy-v1-2004-06-08.html
XDI.ORG is an international public trust organization that exists for the benefit of the entire Internet community. XDI.ORG is devoted to the work of creating an environment of trust for Internet users, and that means we are striving to enhance the privacy and security techniques available to you as an Internet user.
In keeping with its purpose and principles, XDI.ORG takes your privacy interests very seriously.
- We actively protect the privacy of visitors to the XDI.ORG website, participants in discussion lists, email correspondents, and others who interact directly with XDI.ORG.
- We also protect the privacy of information concerning i-name registrants and others when we have access to it, however briefly, in the course of carrying out XDI.ORG’s governance and development responsibilities.
- Finally, through a chain of agreements beginning with the XDI.ORG Intellectual Property Rights (“IPR”) Agreement and the XDI.ORG Global Service Provider (“GSP”) Agreement, we seek to ensure that i-brokers and other Global Service Providers, along with their subcontractors or licensees, do the following:
- communicate their own privacy practices clearly and conspicuously and
- implement broadly accepted “Fair Information Practices” in handling personal information.
We want to make sure that you are informed concerning what personal information is collected about you, who uses it and for what purposes, what choices you have concerning communications with you and data sharing with others, how your personal information is secured, how you can access and update or correct the information about you, and how you can control what information about you appears in the public i-name registry.
Please note that while we repeatedly refer in this Privacy Statement to privacy in the sense of protecting the confidentiality of information relating to individual persons (“Personal Information”), we also take similar steps to protect the confidentiality of information about corporations and other organizations that register for global i-names or i-numbers or otherwise participate in the XDI community.
As the XDI community and technology evolve, we will strive to update this Privacy Statement, as published on our principal website, www.xdi.org.
2. Notice Regarding Children
Our websites and email discussion lists are not designed for children, and we do not monitor postings or communications among participants in discussion groups for content that would be inappropriate for minors. We do not encourage the registration of i-names by minors without the permission and participation of a parent or legal guardian, established to the satisfaction of the relevant i-broker. We will not knowingly communicate with a child under the age of 13 without parental permission. Any questions concerning this policy should be directed to firstname.lastname@example.org.
XDI.ORG models its treatment of personal information on internationally accepted principles of “Fair Information Practices.” XDI.ORG requires Global Service Providers and others with whom we contract to apply these Fair Information Practices in developing their own specific policies and procedures for handling Personal Information.
Fair Information Practices are described in international conventions and guidelines as well as in national privacy laws and guidelines, prominently including the following:
- OECD Guidelines on the Protection of Privacy and Transborder Flows of Personal Data (1980)
- Council of Europe Convention No. 108 for the Protection of Individuals with regard to Automatic Processing of Personal Data (1981)
- United Nations Guidelines Concerning Computerized Personal Data Files (1990)
- European Union “Data Protection Directive,” Directive 95/46/EC (1995)
(http://europa.eu.int/comm/internal_market/privacy/law_en.htm) (the basis for national laws in the European Union, the European Economic Area, and in many jurisdictions outside the EU and EEA)
- US Federal Trade Commission “Fair Information Practice Principles” (1998)
- US-EU Safe Harbor Privacy Principles (2000)
- Canadian Standards Association Model Code for the Protection of Personal Information (CAN/CSA-Q830-96), incorporated as Schedule 1 (Section 5) of the Canadian federal Personal Information Privacy and Electronic Documents Act (“PIPEDA”) (2000)
- Australian National Privacy Principles, found in the Privacy Amendment (Private Sector) Act 2000
- Japanese Personal Information Protection Act (2003)
(unofficial English translation available at http://www.privacyexchange.org/japan/japanindex.html)
- Principles of confidentiality and security are also found in legislation concerning privacy in the specific context of the transmission and storage of electronic communications, such as the US Electronic Communications Privacy Act of 1986, as amended (http://cio.doe.gov/Documents/ECPA.HTM), and the 2002 EU Directive on Privacy and Electronic Communications, Directive 2002/58/EC (http://europa.eu.int/eur-lex/pri/en/oj/dat/2002/l_201/l_20120020731en00370047.pdf)
The various conventions, laws, and guidelines around the world dealing with Fair Information Practices are very similar in principle and intent, even though they differ somewhat in details and terminology. The common principles can be summarized as these:
- Purpose and collection limitation: Personal information should be collected by fair and lawful means, preferably with the knowledge of the individual, and it should be used and disclosed only for legitimate, announced purposes.
- Data quality and accuracy: The personal information collected should be relevant, complete, and not excessive for the intended purpose. The information should come from reliable sources. The information should be kept as accurate and up-to-date as needed for the intended purposes, and it should be retained no longer than needed for those purposes.
- Notice and awareness: Individuals normally have a right to know when personal information about them is being collected, stored, used, or disclosed to others. They should be told what kinds of information are collected, who has access to it, how it will be used, how it will be protected, and what options they have with regard to its collection and use.
- Choice and consent: Individuals should be given choices, wherever feasible, as to what personal information is collected and how it is used. To illustrate, there are legal and business requirements as to what information must be collected, stored, and disclosed to banks or intermediaries when they order a service and pay for it by credit card, but further use of some of those personal details (for example, to create a marketing mailing list) should be subject to an opt-in or opt-out choice by the individual.
- Access and objection: Individuals should be given a reasonable opportunity (a) to review the information that has been collected about them, (b) to challenge its accuracy or completeness, and (c) to object to its further processing.
- Security: The personal information should be protected at all times by appropriate technical and organizational security safeguards to prevent loss or misuse, destruction or alteration of the data, or unauthorized access or disclosure. (Note that OASIS standards and XDI.ORG Global Services Specifications may prescribe particular security measures for certain XRI or XDI functions, but this general principle applies in all cases where personal information is handled.)
- Accountability, enforcement, and recourse: Organizations that handle personal information should appoint responsible persons to develop privacy and security policies, train relevant staff and contractors, and take appropriate steps to ensure that their privacy and security policies are effective and enforced. They should provide contact points for questions and complaints by individuals and ensure that there is some practical form of recourse and redress for persons injured by privacy lapses or abuses.
4. XDI.ORG Practices
XDI.ORG’s specific privacy practices, described in the following sections, are designed to take account of the principles of Fair Information Practices listed above. We encourage your questions and comments so that we can ensure that these privacy practices are as comprehensive and effective as possible.
We use log files, as most website servers do, to record certain technical information about visits to our website, including the IP address and the DNS name of the access provider (such as your Internet Service Provider), the type of browser used, referring and exit pages, platform type (where available), a date and time stamp, and possibly the number and sequence of pages visited. Unless your IP address or associated DNS name identify you specifically, none of this information reveals who you are, and we do not link it to other data in an effort to discover the identity of a site visitor. XDI.ORG staff and consultants use this information solely to administer the site, analyze trends, and track the use of the site in the aggregate so that we can make improvements to better meet user needs. Any log data that we publish, such as the total number of hits or users in a given period, is disclosed only in an aggregate form that does not reveal personally identifiable information. XDI.ORG deletes its log files monthly and strongly recommends all licensee sites to do the same.
XDI.ORG may record information about queries submitted to XDI.ORG website search facilities to better understand how visitors use the website's search features. As with other forms of Web access, this information generally cannot be associated with any particular user. In any case, search query information is not disclosed to anyone outside the relevant XDI.ORG staff, except in an aggregate or anonymized form.
Please remember that any comments or documents that you post on an XDI.ORG website, including the wiki website, should be considered public and may ultimately be viewed by site visitors and also accessed by spiders, web crawlers, or search engines. Use care in posting comments and documents, because any personal information that you post on a website is likely to become public information!
6. External Links
XDI.ORG websites may contain links to websites operated by other parties. XDI.ORG does not control those external websites and cannot be responsible for their privacy practices.
Please use discretion in sending email messages to XDI.ORG staff or role accounts (such as “postmaster”). XDI.ORG will endeavor to store, use, and disclose email only as needed to answer your requests and perform our oversight, administrative, standards-development, and educational functions. But electronic mail is not a reliably secure medium of communication, and XDI.ORG cannot guarantee the confidentiality of email messages in transit or stored on the servers of ISPs, employers, or others to whom emails may be manually or automatically routed and who are outside the direct control of XDI.ORG. If you feel a message is particularly sensitive, you might consider sending it from a private email account or device, addressing only known individuals, and perhaps protecting the contents by using a strong public key encryption technology such as PGP. Here is a link to XDI.ORG's PGP Key.
To receive an XDI.ORG publication or subscribe to an XDI.ORG email list, you must provide your email address -- without it, you won't receive anything from us. Although XDI.ORG does not require subscribers to provide their names, your email program or Internet Service Provider may automatically include your name with the email containing your subscription request. If so, XDI.ORG will record your name with your email address, only for the purpose of ensuring that you are not confused with someone else when we have to manually sort out subscription problems. We will delete your name from the email list database at your request, and we will delete your email address at any time from the email list database if you follow the posted instructions for “unsubscribing” (please allow a few days for an unsubscribe request to take effect).
XDI.ORG holds the names and email addresses of correspondents and email list subscribers in the strictest confidence and will not disclose personal information about email senders or email list subscribers without their permission, unless required by law. XDI.ORG email servers and archives, email subscription lists, and email subscriber databases are accessed by only a few XDI.ORG staff members, for the purpose of maintaining them, and we take every reasonable precaution to protect them against unauthorized access, theft, tampering, and misuse (electronic or otherwise).
The XDI.ORG email lists use “cookies” only if you choose to change the default subscriber options for email list participation, and then only to ensure that those options are given effect.
Aggregate information about XDI.ORG email subscription lists (such as the total number of subscribers) may be published to promote XDI.ORG, but XDI.ORG will not publish identifying information about individual subscribers without their permission.
8. Discussion Lists & Archives
XDI.ORG maintains discussion lists with Web-based archives. Although XDI.ORG keeps email list subscriber information in the strictest confidence, as discussed above, participating in discussion lists may reveal some information about you to all subscribers. This will include your email address and name (if the name is automatically displayed with your emails or revealed by the email address itself), as well as the content or your email message and email signature (if any). (You could, of course, participate using an email address and server that do not reveal your name.)
Users should consider any discussion list a public forum and exercise caution in disclosing any personal information. You are not likely to know all the other subscribers to an email discussion list, and subscribers may disclose messages to others. And although XDI.ORG takes steps to prevent automated programs from harvesting email addresses and other information, third parties may still find a way to access email addresses or messages sent to an email discussion list.
XDI.ORG may ask website users or email list subscribers to participate in surveys. In all cases, participation will be voluntary. If a survey asks for personal information, answering those questions will be optional. Survey responses will be seen only by XDI.ORG personnel and any contractors or consultants assisting XDI.ORG in conducting the survey. Survey results will be made public only in the aggregate, without reference to individuals, unless an individual gives us permission to quote and attribute his or her response.
10. I-Names and I-Numbers
A key purpose of XDI technology is to allow i-name or i-number registrants to control the sharing of their contact details and other Personal Information with others. XDI.ORG and OASIS have developed standards and specifications to enable this privacy-enhancing technology, but it is implemented through i-brokers or other XDI service providers that have their own commercial relations with i-name and i-number registrants.
XDI.ORG is the community governance authority for a set of global i-name and i-number registries offered to the public as XDI Global Services. These global public registries are operated by contractors to XDI.ORG called Global Service Providers. Neither XDI.ORG nor Global Service Providers collect registration information directly from global i-name or i-number registrants. These registrations are performed by i-brokers accredited by a Global Service Provider to i-broker accreditation standards determined by XDI.ORG.
When you register a global i-name or i-number with an accredited i-broker, you will be asked to provide the information that you want listed in the global public registry, such as a pointer to your current i-broker and an account authenticaton credential such as a password. You may also be asked by your i-broker to provide certain information that will not be listed in the global public registry but wil be stored only by your i-broker, such as your true identity and (where applicable) affiliation, your contact and payment details, and possibly other relevant information that would allow the i-broker to confirm your identity when you make any requests to change, transfer, or terminate your registration, directory listing, or other services.
Global Service Providers (initially, Cordance Corporation) are required to provide clear and conspicuous privacy statements that apply the principles of Fair Information Practices [link to our discussion above]. They are also obliged to require the same of i-brokers whom they accredit and and others with whom they subcontract to provide XDI Global Services. As a consequence, an i-broker or its contractor (such as Identity Commons and 2idi in the case of the Early Global Services(EGS) program) should also publish or furnish you with its own privacy statement. We encourage you to review that privacy statement before registering with a particular i-broker, since their roles, practices, and options may differ. You will need to communicate directly with the i-broker, rather than with XDI.ORG, to indicate your preferences with respect to any optional data collection, data sharing, or contacts.
11. Registrant information held by XDI.ORG.
XDI.ORG obtains, uses, and stores Personal Information about registrants - when available -- only to the extent necessary for its governance and development purposes, such as authenticating change requests, correcting technical problems, resolving disputes, and complying with applicable laws. For these purposes, XDI.ORG does not routinely use Personal Information beyond what is found in the global public registry and the resolution data associated with an i-name or i-number, such as the Uniform Resource Identifier (URI) of the host i-broker (where applicable). In connection with changes and disputes, XDI.ORG may from time to time request additional identifying information from i-brokers or Global Service Providers, and the arbitrators or parties to a dispute may provide XDI.ORG with information relevant to dispute resolution proceedings.
XDI.ORG employs technical and organizational safeguards, including password access controls and physical security, to protect Personal Information as long as it is in our possession, and we retain Personal Information only as long as needed for our governance and development purposes.
Unless you give us permission, XDI.ORG will not share your Personal Information with third parties except as necessary to fulfill its governance and development responsibilities. The categories of third parties that might receive Personal Information from XDI.ORG for these purposes include XDI.ORG’s contractors and consultants, the affected i-brokers or Global Service Providers, law enforcement agencies, arbitrators, and parties to litigation.
XDI.ORG will not use, sell, rent, or otherwise disclose Personal Information for marketing purposes without your permission.
12. Legal Requests for Personal Information
Please be advised that, as in the case of domain name registrars and Internet Service Providers, XDI.ORG, an i-broker, or a Global Service Provider could be legally compelled in some circumstances to disclose Personal Information that they may hold, such as the identity of an i-name registrant, to law enforcement authorities or to parties in civil litigation.
13. Contacting XDI.ORG about Personal Information
Please go to your i-broker’s website to make change, transfer, or termination requests with respect to your i-name registration and global public registry entries. To review, correct, or ask for the deletion of any Personal Information that XDI.ORG itself may have, please email email@example.com, or send a letter to XDI.ORG, 4855 Wikiup Bridgeway, Santa Rosa, CA 95404. We may ask for additional information to establish who you are and to facilitate our search for relevant data, which we will do to the extent it is indexed or reasonably searchable by name or i-name.
In the event of litigation over alleged privacy breaches by XDI.ORG, we submit to personal jurisdiction in the courts of general jurisdiction in our state of incorporation (currently the State of Washington, USA) and in the Commonwealth of Virginia, USA.