The Platform for Privacy Preferences 1.0 (P3P1.0)
Specification
The Platform for Privacy Preferences 1.0 (P3P1.0)
Specification
W3C Recommendation 16 April 2002
obsoleted 30 August 2018
This Version:
Latest Version:
Previous Version:
Editor:
Massimo Marchiori
W3C
MIT
University of Venice
, (
massimo@w3.org
Authors:
Lorrie Cranor
, AT&T
Marc Langheinrich
, ETH
Zurich
Massimo Marchiori
, W3C
/ MIT / University of Venice
Martin Presler-Marshall
IBM
Joseph
Reagle
, W3C/MIT
Please refer to the
errata
for this document, which may include some normative corrections.
See also
translations
W3C
MIT
INRIA
Keio
), All Rights Reserved. W3C
liability
trademark
document
use
and
software
licensing
rules apply.
Abstract
This is the specification of the Platform for Privacy Preferences (P3P).
This document, along with its normative references, includes all the
specification necessary for the implementation of interoperable P3P
applications.
Status of This Document
This section describes the status of this document at the time of its
publication. Other documents may supersede this document. The latest status of
this document series is maintained at the W3C.
This specification is obsolete and should no longer be used as a basis for implementation.
The P3P specification became a
W3C Recommendation
in April 2002. It was designed to enable "Web sites to express their privacy
practices in a standard format that can be retrieved automatically and interpreted easily by user agents," and "P3P user agents"
to inform users of these practices as a basis for decisions. Both detailed ("full") policy expressions and performance-optimized
"compact" policy expressions were specified.
It was envisioned that P3P would enable an expanded ecosystem in which web sites would consistently inform web user agents of
personal data collection intentions and web users would configure their individual user agents to accept some practices automatically
without the user having to read the policy or to prompt the user for further instruction when the site's practice exceeded the users' prior
election.
Since 2002 P3P has had only limited deployment; its utility depends both on adoption by web sites and informative implementation in
user agents. When Microsoft Internet Explorer was updated to use the presence of a compact P3P policy as a broad gate for deciding on
the user's behalf to allow or reject third-party cookies, web site administrators chose to copy general policies rather than encode specific
policies that reflected their sites' own privacy practices. In addition, no enforcement action followed when a site's policy expressed in
P3P failed to reflect their actual privacy practices.
In 2018, according to
BuiltWith metrics
, fewer than 6% of the 10,000 most frequently visited websites support P3P. Though there was an
increase among the top million sites at the beginning of 2018, that increase quickly leveled off. No current (2018) user agents are
known to provide interpretation of or implement decisions based upon P3P policies. While new data protection regulations taking effect in
2018 may bring new interest in machine-processable mechanisms similar to P3P, W3C concludes that P3P itself has not seen sufficient ecosystem
uptake to continue to recommend that the community implement the 2002 specification.
For purposes of the W3C Patent Policy this
Obsolete Recommendation
has the same status as an active Recommendation; it retains licensing
commitments and remains available as a reference for old implementations but is no longer recommended for future implementation.
A list of current public W3C Technical Reports can be found at
Table of Contents
Introduction
The P3P1.0 Specification
Goals and Capabilities of
P3P1.0
Example of P3P in Use
P3P Policies
P3P User Agents
Implementing P3P1.0 on Servers
Future Versions of P3P
About this Specification
Terminology
Referencing Policies
Overview and Purpose of Policy
References
Locating Policy Reference Files
Well-Known Location
HTTP Headers
The HTML
link
Tag
The XHTML
link
Tag
HTTP ports and other
protocols
Policy Reference File Syntax and Semantics
Example Policy Reference
File
Policy Reference File Definition
Policy reference file
processing
Significance of
order
Wildcards in policy
reference files
The
META
and
POLICY-REFERENCES
elements
Policy reference file lifetimes
and the
EXPIRY element
Motivation and
mechanism
The
EXPIRY
element
Use of HTTP
headers
Error handling for policy
reference file lifetimes
The
POLICY-REF
element
The
INCLUDE
and
EXCLUDE
elements
The
HINT
element
The
COOKIE-INCLUDE
and
COOKIE-EXCLUDE
elements
The
METHOD
element
Applying a Policy to a URI
Forms and Related Mechanisms
Additional Requirements
Non-ambiguity
Multiple Languages
The Safe Zone
Policy and Policy Reference File
Processing by User Agents
Security of Policy Transport
Policy Updates
Absence of Policy Reference
File
Asynchronous
Evaluation
Example Scenarios
Policy Syntax and Semantics
Example policies
English language policies
XML encoding of policies
Policies
The
POLICIES
element
The
POLICY
element
The
TEST
element
The
ENTITY
element
The
ACCESS
element
The
DISPUTES
element
The
REMEDIES
element
Statements
The
STATEMENT
element
The
CONSEQUENCE
element
The
NON-IDENTIFIABLE
element
The
PURPOSE
element
The
RECIPIENT
element
The
RETENTION
element
The
DATA-GROUP
and
DATA
elements
Categories and the
CATEGORIES
element
Extension Mechanism: the
EXTENSION
element
User Preferences
Compact Policies
Referencing Compact
Policies
Compact Policies Vocabulary
Compact
ACCESS
Compact
DISPUTES
Compact
REMEDIES
Compact
NON-IDENTIFIABLE
Compact
PURPOSE
Compact
RECIPIENT
Compact
RETENTION
Compact
CATEGORIES
Compact
TEST
Compact Policy Scope
Compact Policy Lifetime
Transforming a P3P Policy to a Compact
Policy
Transforming a Compact Policy to a P3P
Policy
Data schemas
Natural Language Support for Data
Schemas
Data Structures
The
DATA-DEF
and
DATA-STRUCT
elements
Categories in P3P Data
Schemas
P3P Data Schema Example
Use of data element names
Persistence of data
schemas
Basic Data Structures
Dates
Names
Logins
Certificates
Telephones
Contact Information
Postal
Telecommunication
Online
Access Logs and Internet
Addresses
URI
ipaddr
Access Log Information
Other HTTP Protocol
Information
The base data schema
User Data
Third Party Data
Business Data
Dynamic Data
Categories and Data
Elements/Structures
Fixed-Category Data
Elements/Structures
Variable-Category Data
Elements/Structures
Using Data Elements
Appendices
Appendix 1: References (Normative)
Appendix 2: References
(Non-normative)
Appendix 3: The P3P base data schema Definition
(Normative)
Appendix 4: XML Schema Definition
(Normative)
Appendix 5: XML DTD Definition (Non-normative)
Appendix 6: ABNF Notation (Normative)
Appendix 7: P3P Guiding Principles
(Non-normative)
Appendix 8: Working Group Contributors
(Non-normative)
1.
Introduction
The Platform for Privacy Preferences Project (P3P) enables Web sites to
express their privacy practices in a standard format that can be retrieved
automatically and interpreted easily by user agents. P3P user agents will
allow users to be informed of site practices (in both machine- and
human-readable formats) and to automate decision-making based on these
practices when appropriate. Thus users need not read the privacy policies at
every site they visit.
Although P3P provides a technical mechanism for ensuring that users can be
informed about privacy policies before they release personal information, it
does not provide a technical mechanism for making sure sites act according to
their policies. Products implementing this specification MAY provide some
assistance in that regard, but that is up to specific implementations and
outside the scope of this specification. However, P3P is complementary to laws
and self-regulatory programs that can provide enforcement mechanisms. In
addition, P3P does not include mechanisms for transferring data or for
securing personal data in transit or storage. P3P may be built into tools
designed to facilitate data transfer. These tools should include appropriate
security safeguards.
1.1
The P3P1.0 Specification
The P3P1.0 specification defines the syntax and semantics of P3P privacy
policies, and the mechanisms for associating policies with Web resources. P3P
policies consist of statements made using the P3P
vocabulary
for
expressing privacy practices. P3P policies also reference elements of the P3P
base data schema
-- a standard set of
data elements that all P3P user agents should be aware of. The P3P
specification includes a mechanism for defining new data elements and data
sets, and a simple mechanism that allows for extensions to the P3P
vocabulary.
1.1.1 Goals and Capabilities of P3P1.0
P3P version 1.0 is a protocol designed to inform Web users of the
data-collection practices of Web sites. It provides a way for a Web site to
encode its data-collection and data-use practices in a machine-readable XML
format known as a
P3P policy
. The P3P specification defines:
A standard schema for data a Web site may wish to collect, known as the
"P3P base data schema"
A standard set of uses, recipients, data categories, and other privacy
disclosures
An XML format for expressing a privacy policy
A means of associating privacy policies with Web pages or sites, and
A mechanism for transporting P3P policies over HTTP
The goal of P3P version 1.0 is twofold. First, it allows Web sites to
present their data-collection practices in a standardized, machine-readable,
easy-to-locate manner. Second, it enables Web users to understand what data
will be collected by sites they visit, how that data will be used, and what
data/uses they may "opt-out" of or "opt-in" to.
1.1.2 Example of P3P in Use
As an introduction to P3P, let us consider one common scenario that makes
use of P3P. Claudia has decided to check out a store called CatalogExample,
located at http://www.catalog.example.com/. Let us assume that CatalogExample
has placed P3P policies on all their pages, and that Claudia is using a Web
browser with P3P built in.
Claudia types the address for CatalogExample into her Web browser. Her
browser is able to automatically fetch the P3P policy for that page. The
policy states that the only data the site collects on its home page is the
data found in standard HTTP access logs. Now Claudia's Web browser checks this
policy against the preferences Claudia has given it. Is this policy acceptable
to her, or should she be notified? Let's assume that Claudia has told her
browser that this is acceptable. In this case, the homepage is displayed
normally, with no pop-up messages appearing. Perhaps her browser displays a
small icon somewhere along the edge of its window to tell her that a privacy
policy was given by the site, and that it matched her preferences.
Next, Claudia clicks on a link to the site's online catalog. The catalog
section of the site has some more complex software behind it. This software
uses cookies to implement a "shopping cart" feature. Since more information is
being gathered in this section of the Web site, the Web server provides a
separate P3P policy to cover this section of the site. Again, let's assume
that this policy matches Claudia's preferences, so she gets no pop-up
messages. Claudia continues and selects a few items she wishes to purchase.
Then she proceeds to the checkout page.
The checkout page of CatalogExample requires some additional information:
Claudia's name, address, credit card number, and telephone number. Another P3P
policy is available that describes the data that is collected here and states
that her data will be used only for completing the current transaction, her
order.
Claudia's browser examines this P3P policy. Imagine that Claudia has told
her browser that she wants to be warned whenever a site asks for her telephone
number. In this case, the browser will pop up a message saying that this Web
site is asking for her telephone number, and explaining the contents of the
P3P statement. Claudia can then decide if this is acceptable to her. If it is
acceptable, she can continue with her order; otherwise she can cancel the
transaction.
Alternatively, Claudia could have told her browser that she wanted to be
warned only if a site is asking for her telephone number and was going to give
it to third parties and/or use it for uses other than completing the current
transaction. In that case, she would have received no prompts from her browser
at all, and she could proceed with completing her order.
Note that this scenario describes one hypothetical implementation of P3P.
Other types of user interfaces are also possible.
1.1.3
P3P Policies
P3P policies use an XML with namespaces (cf. [
XML
] and
XML-Name
]) encoding of the P3P vocabulary to provide
contact information for the legal entity making the representation of privacy
practices in a policy, enumerate the types of data or data elements collected,
and explain how the data will be used. In addition, policies identify the data
recipients, and make a variety of other disclosures including information
about dispute resolution, and the address of a site's human-readable privacy
policy. P3P policies must cover all relevant data elements and practices.
However, legal issues regarding law enforcement demands for information are
not addressed by this specification. It is possible that a site that otherwise
abides by its policy of not redistributing data to others may be required to
do so by force of law. P3P declarations are positive, meaning that sites state
what they do, rather than what they do not do. The P3P vocabulary is designed
to be descriptive of a site's practices rather than simply an indicator of
compliance with a particular law or code of conduct. However, user agents may
be developed that can test whether a site's practices are compliant with a law
or code.
P3P policies represent the practices of the site. Intermediaries such as
telecommunication providers, Internet service providers, proxies and others
may be privy to the exchange of data between a site and a user, but their
practices may not be governed by the site's policies. In addition, note that
each P3P policy is applied to specific Web resources (Web pages, images,
cookies, etc.) listed in a policy reference file. By placing one or more P3P
policies on a Web site, a company or organization does not make any statements
about the privacy practices associated with other Web resources not mentioned
in their policy reference file, with other online activities that do not
involve data collected on Web sites covered by their P3P policy, or with
offline activities that do not involve data collected on Web sites covered by
their P3P policy.
In cases where the P3P vocabulary is not precise enough to describe a Web
site's practices, sites should use the vocabulary terms that most closely
match their practices and provide further explanations (as stated in
Section 3.2
). However, policies MUST NOT make false or
misleading statements.
1.1.4
P3P User Agents
P3P1.0 user agents can be built into Web browsers, browser plug-ins, or
proxy servers. They can also be implemented as Java applets or JavaScript; or
built into electronic wallets, automatic form-fillers, or other user data
management tools. P3P user agents look for references to a P3P policy at a
well-known location, in P3P headers in HTTP responses, and in P3P
link
tags embedded in HTML content. These references indicate the
location of a relevant P3P policy. User agents can fetch the policy from the
indicated location, parse it, and display symbols, play sounds, or generate
user prompts that reflect a site's P3P privacy practices. They can also
compare P3P policies with privacy preferences set by the user and take
appropriate actions. P3P can perform a sort of "gate keeper" function for data
transfer mechanisms such as electronic wallets and automatic form fillers. A
P3P user agent integrated into one of these mechanisms would retrieve P3P
policies, compare them with user's preferences, and authorize the release of
data only if a) the policy is consistent with the user's preferences and b)
the requested data transfer is consistent with the policy. If one of these
conditions is not met, the user might be informed of the discrepancy and given
an opportunity to authorize the data release themselves.
The P3P1.0 Specification places few requirements on the user interfaces of
P3P user agents. Thus user agent implementers may each make their own choices
about what words and symbols to present to users to provide information about
a Web site's privacy policy. Implementers need not use the definitions found
in this specification verbatim in their user interfaces. They should, however,
make sure that whatever information they present to the user accurately
represents the P3P policies described, as per Appendix 7, "
P3P Guiding Principles
".
1.1.5
Implementing P3P1.0 on Servers
Web sites can implement P3P1.0 on their servers by translating their
human-readable privacy policies into P3P syntax and then publishing the
resulting files along with a policy reference file that indicates the parts of
the site to which the policy applies. Automated tools can assist site
operators in performing this translation. P3P1.0 can be implemented on
existing HTTP/1.1-compliant Web servers without requiring additional or
upgraded software. Servers may publish their policy reference files at a
well-known location
, or they may reference
their P3P policy reference files in HTML/XHTML content using a
link
tag. Alternatively, compatible servers may be configured to
insert a P3P extension header into all HTTP responses that indicates the
location of a site's P3P policy reference file.
Web sites have some flexibility in how they use P3P: they can opt for one
P3P policy for their entire site or they can designate different policies for
different parts of their sites. A P3P policy MUST cover all data generated or
exchanged as part of a site's HTTP interactions with visitors. In addition,
some sites may wish to write policies that cover all data an entity collects,
regardless of how the data is collected.
1.1.6
Future Versions of P3P
Significant sections were removed from earlier drafts of the P3P1.0
specification in order to facilitate rapid implementation and deployment of a
P3P first step. A future version of the P3P specification might incorporate
those features after P3P1.0 is deployed. Such specification would likely
include improvements based on feedback from implementation and deployment
experience as well as four major components that were part of the original P3P
vision but not included in P3P1.0:
a mechanism to allow sites to offer a choice of P3P policies to
visitors
a mechanism to allow visitors (through their user agents) to explicitly
agree to a P3P policy
mechanisms to allow for non-repudiation of agreements between visitors
and Web sites
a mechanism to allow user agents to transfer user data to services
1.2
About this Specification
This document, along with its normative references, includes all the
specification necessary for the implementation of interoperable P3P
applications.
The following key words are used throughout the document and have to be
read as interoperability requirements. This specification uses words as
defined in
RFC2119
KEY
] for defining the significance of each particular
requirement. These words are:
MUST or MUST NOT
This word or the adjective "required" means that the item is an
absolute requirement of the specification.
SHOULD or SHOULD NOT
This word or the adjective "rcommended" means that there may exist
valid reasons in particular circumstances to ignore this item, but the
full implications should be understood and the case carefully weighed
before choosing a different course.
MAY
This word or the adjective "optional" means that this item is truly
optional. One vendor may choose to include the item because a particular
marketplace requires it or because it enhances the product, for example;
another vendor may omit the same item.
The P3P specification defines, with the exception of
section 2.2.2
section 2.2.3
and
section 4
, an
XML with namespaces
syntax (cf. [
XML
] and [
XML-Name
]).
In the following, for the sake of brevity we will liberally talk about "XML",
meaning the more accurate "XML with namespaces".
A BNF-like notation is also used thorough the specification: the [
ABNF
] notation used in this specification is specified in
RFC2234
and summarized in
Appendix 6
. However, note that in the case of
XML syntax, such ABNF syntax is only a grammar representative used to enhance
readability (lacking, for example, all the syntactic flexibilities that are
implicitly included in XML, e.g. whitespace rules, quoting using either single
quote (') or double quote ("),
character escaping
comments, case sensitivity, order of attributes, namespace handling), and as
such it has no normative value. All the XML syntax defined in this
specification MUST conform to the XML Schema for P3P (see
Appendix 4)
, which, together with the other
constraints expressed in this specification using natural
language, constitutes the
normative
definition.
The (non-normative) DTD provided in
Appendix 5
MAY be
used to verify that P3P files are valid. However, there are some valid files
that may be rejected if checked against the DTD due to their use of
namespaces.
As far as the non-XML syntax defined in this specification is concerned (
section 2.2.2
defining P3P's HTTP header,
section 2.2.3
defining usage of P3P in HTML, and
section 4
defining compact policies), instead,
the ABNF notation (together with the other constraints expressed in this
specification using natural language) constitutes the
normative
definition.
1.3
Terminology
Character
Strings consist of a sequence of zero or more characters, where a
character is defined as in the XML Recommendation [
XML
]. A single character in P3P thus corresponds to a
single Unicode abstract character with a single corresponding Unicode
scalar value (see [
UNICODE
]).
Data Element
An individual data entity, such as last name or telephone number. For
interoperability, P3P1.0 specifies a base set of data elements.
Data Category
A significant attribute of a
data element
or
data set
that may be used by a trust engine
to determine what type of element is under discussion, such as physical
contact information. P3P1.0 specifies a set of
data categories
Data Set
A known grouping of
data elements
, such
as "
user.home-info.postal
". The
P3P1.0 base data schema specifies a number of data sets.
Data Schema
A collection of data elements and sets defined using the P3P1.0
DATASCHEMA
element. P3P1.0 defines a standard data schema
called the
P3P base data schema
Data Structure
A hierarchical description of a set of data elements. A data set can
be described according to its data structure. P3P1.0 defines a set of
basic datastructures that are used to describe the data sets in the P3P
base data schema.
Equable Practice
A practice that is very similar to another in that the purpose and
recipients are the same or more constrained than the original, and the
other disclosures are not substantially different. For example, two
sites with otherwise similar practices that follow different -- but
similar -- sets of industry guidelines.
Identified Data
Data that reasonably can be used by the data collector to identify an
individual.
Policy
A collection of one or more privacy statements together with
information asserting the identity, URI, assurances, and dispute
resolution procedures of the service covered by the policy.
Practice
The set of disclosures regarding data usage, including purpose,
recipients, and other disclosures.
Preference
A rule, or set of rules, that determines what action(s) a user agent
will take. A preference might be expressed as a formally defined
computable statement (e.g., the [
APPEL
] preference
exchange language).
Purpose
The reason(s) for data collection and use.
Repository
A mechanism for storing user information under the control of the user
agent.
Resource
A network data object or service that can be identified by a URI.
Resources may be available in multiple representations (e.g. multiple
languages, data formats, size, and resolutions) or vary in other
ways.
Safe Zone
Part of a Web site where the service provider performs only minimal
data collection, and any data that is collected is used only in ways
that would not reasonably identify an individual.
Service
A program that issues policies and (possibly) data requests. By this
definition, a service may be a server (site), a local application, a
piece of locally active code, such as an ActiveX control or Java applet,
or even another user agent. Typically, however, a service is usually a
Web site. In this specification the terms "service" and "Web site" are
often used interchangeably.
Service Provider (Data Controller, Legal Entity)
The person or legal entity which offers information, products or
services from a Web site, collects information, and is responsible for
the representations made in a practice statement.
Statement
A P3P statement is a set of privacy practice disclosures relevant to a
collection of data elements.
URI
A Uniform Resource Identifier used to locate Web resources. For
definitive information on
URI
syntax and semantics,
see [
URI
]. URIs that appear within XML or HTML have
to be treated as specified in [
CHARMODEL
],
section
Character
Encoding in URI References
. This does not apply to URIs appearing in
HTTP header fields; the URIs there should always be fully escaped.
User
An individual (or group of individuals acting as a single entity) on
whose behalf a service is accessed and for which personal data exists.
P3P policies describe the collection and use of personal data about this
individual or group.
User Agent
A program whose purpose is to mediate interactions with services on
behalf of the user under the user's preferences. A user may have more
than one user agent, and agents need not reside on the user's desktop,
but
any agent must be controlled by and act on behalf of only the
user
. The trust relationship between a user and his or her agent
may be governed by constraints outside of P3P. For instance, an agent
may be trusted as a part of the user's operating system or Web client,
or as a part of the terms and conditions of an ISP or privacy
proxy.
2. Referencing Policies
2.1 Overview and Purpose of Policy
References
Locating a P3P policy is one of the first steps in the operation of the P3P
protocol. Services use policy references to state what policy applies to a
specific URI or set of URIs. User agents use policy references to locate the
privacy policy that applies to a Web resource, so that they can process that
policy for the benefit of their user.
Policy references are used extensively as a performance optimization. P3P
policies are typically several kilobytes of data, while a URI that references
a privacy policy is typically less than 100 bytes. In addition to the
bandwidth savings, policy references also reduce the need for computation:
policies can be uniquely associated with URIs, so that a user agent need only
parse and process a policy once rather than process it with every document to
which the policy applies. Furthermore, by placing the information about
relevant policies in a centralized location, Web site administration is
simplified.
A policy reference file is used to associate P3P policies with certain
regions of URI-space. The policy reference file is an XML with namespaces (see
XML
] and [
XML-Name
]) file that can
specify the policy for a single Web document, portions of a Web site, or for
an entire site. The policy reference file may refer to one or more P3P
policies; this allows for a single reference file to cover an entire site,
even if different P3P policies apply to different portions of the site.The
policy reference file is used to make any or all of the following
statements:
The URI where a P3P policy is found
The URIs or regions of URI-space covered by this policy
The URIs or regions of URI-space not covered by this policy
The regions of URI-space for embedded content on other servers that are
covered by this policy
The cookies that are or are not covered by this policy
The access methods for which this policy is applicable
The period of time for which these claims are considered to be
valid
All of these statements are made in the body of the policy reference
file.
2.2 Locating Policy Reference Files
This section describes the mechanisms used to indicate the location of a
policy reference file. Detailed syntax is also given for the supported
mechanisms.
The location of the policy reference file can be indicated using one of
four mechanisms. The policy reference file
may be located in a predefined
"well-known" location
, or
a document may indicate a policy reference file through an HTML
link
tag, or
a document may indicate a policy reference file through an XHTML
link
tag, or
through an HTTP header.
Note that if user agents support retrieving HTML (resp. XHTML) content over
HTTP, they MUST handle mechanisms 1, 2 and 3 (resp. 4) listed above
interchangeably. See also the requirements for
non-ambiguity
Policies are applied at the level of resources. A "page" from the user's
perspective may be composed of multiple HTTP resources; each may have its own
P3P policy associated with it. As a practical note, however, placing many
different P3P policies on different resources on a single page may make
rendering the page and informing the user of the relevant policies difficult
for user agents. Additionally, services are recommended to attempt to craft
their policy reference files such that a single policy reference file covers
any given "page"; this will speed up the user's browsing experience.
For a user agent to process the policy that applies to a given resource, it
must locate the policy reference file for that resource, fetch the policy
reference file, parse the policy reference file, fetch any required P3P
policies, and then parse the P3P policy or policies.
This document does not specify how P3P policies may be associated with Web
resources retrieved by means other than HTTP. However, it does not preclude
future development of mechanisms for associating P3P policies with resources
retrieved using other protocols. Furthermore, additional methods of
associating P3P policies with HTTP resources may be developed in the
future.
2.2.1 Well-Known Location
Web sites using P3P MAY (and, are strongly encouraged to) place a policy
reference file in a "well-known" location. To do this, a policy reference file
would be made available on the site at the path
/w3c/p3p.xml
Note that sites are not required to use this mechanism; however, by using
this mechanism, sites can ensure that their P3P policy will be accessible to
user agents before any other resources are requested from the site. This will
reduce the need for user agents to access the site using safe zone practices.
Additionally, if a site chooses to use this mechanism, the policy reference
file located in the well-known location is not required to cover the entire
site. For example, sites where not all of the content is under the control of
a single organization MAY choose not to use this mechanism, or MAY choose to
post a policy reference file which covers only a limited portion of the
site.
Use of the well-known location for a policy reference file does not
preclude use of other mechanisms for specifying a policy reference file.
Portions of the site MAY use any of the other supported mechanisms to specify
a policy reference file, so long as the
non-ambiguity
requirements
are met.
For example, imagine a shopping-mall Web site run by the MallExample
company. On their Web site (
mall.example.com
), companies offering
goods or services at the mall would get a company-specific subtree of the
site, perhaps in the path
/companies/
company-name
. The
MallExample company may choose to put a policy reference file in the
well-known location which covers all of their site except the
/companies
subtree. Then if the ShoeStoreExample company has some
content in
/companies/shoestoreexample
, they could use one of the
other mechanisms to indicate the location of a policy reference file covering
their portion of the
mall.example.com
site.
One case where using the well-known location for policy reference files is
expected to be particularly useful is in the case of a site which has divided
its content across several hosts. For example, consider a site which uses a
different logical host for all of its Web-based applications than for its
static HTML content. The other mechanisms allowed for specifying the location
of a policy reference file require that some URI on the host being accessed
must be fetched to locate the policy reference file. However, the well-known
location mechanism has no such requirement. Consider the example of an HTML
form located on
www.example.com
. Imagine that the action URI on
that form points to server
cgi.example.com
. The policy reference
file that covers the form is unable to make any statements about the action
URI that processes the form. However, the site administrator publishes a
policy reference file at
that
covers the action URI, thus enabling a user agent to easily locate the P3P
policy that applies to the action URI before submitting the form contents.
2.2.2 HTTP Headers
Any document retrieved by HTTP MAY point to a policy reference file through
the use of a new response header, the
P3P
header ([
P3P-HEADER
]). If a site is using P3P headers, it SHOULD
include this on responses for all appropriate request methods, including
HEAD
and
OPTIONS
requests.
The P3P header gives one or more comma-separated directives. The syntax
follows:
[1]
p3p-header
`P3P: ` p3p-header-field *(`,` p3p-header-field)
[2]
p3p-header-field
policy-ref-field | compact-policy-field | extension-field
[3]
policy-ref-field
`policyref="` URI-reference `"`
[4]
extension-field
token
[`=` (token | quoted-string) ]
Here,
URI-reference
is defined
as per
RFC 2396
URI
],
token
and
quoted-string
are defined by [
HTTP1.1
].
In keeping with the rules for other HTTP headers, the name of the P3P
header may be written with any casing. The contents should be specified using
the casing precisely as specified in this document.
The
policyref
directive gives a URI which specifies the
location of a policy reference file which may reference the P3P policy
covering the document that pointed to the reference file, and possibly others
as well. When the
policyref
attribute is a relative URI, that URI
is interpreted relative to the request URI. Note that fetching the URI given
in the
policyref
directive MAY result in a 300-class HTTP return
code (redirection); user agents MUST interpret those redirects with normal
HTTP semantics. Services should note, of course, that use of redirects will
increase the time required for user agents to find and interpret their
policies. The
policyref
URI MUST NOT be used for any other
purpose beyond locating and referencing P3P policies.
The
compact-policy-field
is used to specify "compact
policies". This is described in
Section 4
User agents which find unrecognized directives (in the
extension-field
s) MUST ignore the unrecognized directives. This
is to allow easier deployment of future versions of P3P.
Example 2.1:
1. Client makes a
GET
request.
GET /index.html HTTP/1.1
Host: catalog.example.com
Accept: */*
Accept-Language: de, en
User-Agent: WonderBrowser/5.2 (RT-11)
2. Server returns content and the
P3P
header pointing to the
policy of the resource.
HTTP/1.1 200 OK
P3P: policyref="http://catalog.example.com/P3P/PolicyReferences.xml"
Content-Type: text/html
Content-Length: 7413
Server: CC-Galaxy/1.3.18
2.2.3 The HTML
link
Tag
Servers MAY serve HTML content with embedded
link
tags (cf.
HTML
]) that indicate the location of the relevant P3P
policy reference file. This use of P3P does not require any change in the
server behavior.
The
link
tag encodes the policy reference information that
could be expressed using the
P3P
header. The
link
tag takes the following form (here, we just produce one possible ABNF format
for the link tag, and suppose the [
HTML
] syntax rules can
be used when using such a tag into an HTML file):
[5]
p3p-link-tag
``
Here,
URI
is defined as per
RFC 2396
URI
].
When the
href
attribute is a relative URI, that URI is
interpreted relative to the request URI.
In order to illustrate with an example the use of the
link
tag, we consider the policy reference expressed in
Example 2.1
using HTTP headers. That example can be
equivalently expressed using the link tag with the following piece of
HTML:
href="http://catalog.example.com/P3P/PolicyReferences.xml">
Finally, note that since the
p3p-link-tag
is embedded in an
HTML document, its character encoding will be the same as that of the HTML
document. In contrast to P3P policy and policy reference documents (see
section 2.3
and
section 3
below), the
p3p-link-tag
need not be encoded using [
UTF-8
]. Note also that the
link
tag is not case
sensitive.
2.2.4 The XHTML
link
tag
Correspondingly to the HTML
link
tag, P3P also supports XHTML
(cf. [
XHTML-MOD
]). Servers MAY serve XHTML content
that, using the
XHTML Link Module
(cf.
Section
5.19
of [
XHTML-MOD
]), indicates the location of
the relevant P3P policy reference file with an embedded XHTML
link
tag. Like in the HTML case, an XHTML
link
tag
can be used to encode the policy reference information that could be expressed
using the
P3P
header, by:
setting its
rel
attribute to "
P3Pv1
setting its
href
attribute to the URI of the relevant P3P
policy reference file
2.2.5 HTTP ports and other protocols
The mechanisms described here MAY be used for HTTP transactions over any
underlying protocol. This includes plain-text HTTP over TCP/IP connections or
encrypted HTTP over SSL connections, as well as HTTP over any other
communications protocol designers wish to implement.
URIs MAY contain network port numbers, as specified in
RFC 2396
URI
]. For the purposes of P3P, different ports on a single
host MUST be considered to be separate "sites". Thus, for example, the policy
reference file at the well-known location for www.example.com on port 80
(http://www.example.com/w3c/p3p.xml) would not give any information about the
policies which apply to www.example.com when accessed over SSL (as the SSL
communication would take place on a different port, 443 by default).
This document does not specify how P3P policies may be associated with
resources retrieved by means other than HTTP. However, it does not preclude
future development of mechanisms for associating P3P policies with resources
retrieved over other protocols. Furthermore, additional methods of associating
P3P policies with resources retrieved using HTTP may be developed in the
future.
2.3 Policy Reference File Syntax and Semantics
This section explains the contents of policy reference files in detail.
2.3.1 Example Policy Reference File
Consider the case of a Web site wishing to make the following
statements:
P3P policy
/P3P/Policies.xml#first
applies to the entire
site, except resources whose paths begin with
/catalog
/cgi-bin
, or
/servlet
P3P policy
/P3P/Policies.xml#second
applies to all
resources whose paths begin with
/catalog
P3P policy
/P3P/Policies.xml#third
applies to all resources
whose paths begin with
/cgi-bin
or
/servlet
except for
/servlet/unknown
No statement is made about what P3P policy applies to
/servlet/unknown
These statements are valid for 2 days.
These statements can be represented by the following XML:
Example 2.2:



/*
/catalog/*
/cgi-bin/*
/servlet/*


/catalog/*


/cgi-bin/*
/servlet/*
/servlet/unknown



Note this example also includes via
EXPIRY
a relative expiry time in the
document (cf.
Section 2.3.2.3.2
).
2.3.2 Policy Reference File Definition
This section defines the syntax and semantics of P3P policy reference
files. All policy reference files MUST be encoded using [
UTF-8
]. P3P servers MUST encode their policy reference files
using this syntax.
2.3.2.1 Policy reference file
processing
2.3.2.1.1 Significance of order
A policy reference file has the
META
element as root. It may
contain multiple
POLICY-REF
elements. If it does contain more
than one element, they MUST be processed by user agents in the order given in
the file. When a user agent is attempting to determine what policy applies to
a given URI, it MUST use the first
POLICY-REF
element in the
policy reference file which applies to that URI.
Note that each
POLICY-REF
may contain multiple
INCLUDE
EXCLUDE
METHOD
COOKIE-INCLUDE
, and
COOKIE-EXCLUDE
elements and that
all of these elements within a given
POLICY-REF
MUST be
considered together to determine whether the
POLICY-REF
applies
to a given URI. Thus, it is not sufficient to find an
INCLUDE
element that matches a given URI, as
EXCLUDE
or
METHOD
elements may serve as modifiers that cause the
POLICY-REF
not to match.
2.3.2.1.2 Wildcards in policy reference
files
Policy reference files make statements about what policy applies to a given
URI. Policy reference files support a simple wildcard character to allow
making statements about regions of URI-space. The character asterisk
('
') is used to represent a sequence of 0 or more of any
character. No other special characters (such as those found in regular
expressions) are supported.
Note that since the asterisk is also a legal character in URIs ([
URI
]), some special conventions have to be followed when
encoding such "extended URIs" in a policy reference file:
URIs represented in policy reference files MUST be properly escaped, as
described in [
URI
],
except
Literal '
's in URIs MUST be escaped in policy
reference files (i.e., they MUST be represented as
%2A
"). Any '
' present in a URI within a
policy reference file will be taken as representing the asterisk
wildcard character.
Consequently, P3P user agents MUST properly un-escape a URI given in
a policy reference file, according to [
URI
], before
trying to match it against an internally represented URI, but only
after recognizing any literal '
' present as the asterisk
wildcard character.
URI escaping and unescaping is very much dependant on the actual scheme
used, and might even differ between individual components within a single
scheme, so no simple rule for which characters need to be escaped can be given
here. Please refer directly to [
URI
] for details on the
standard escaping process. Note that P3P user agents MAY ignore any URI
pattern that does not conform to [
URI
].
The wildcard character MAY be used in the
INCLUDE
and
EXCLUDE
elements, in the
COOKIE-INCLUDE
and
COOKIE-EXCLUDE
elements, and in the
HINT
element.
2.3.2.2 The
META
and
POLICY-REFERENCES
elements

The
META
element contains a complete policy reference
file. Optionally, one
POLICIES
element can follow.
META
can also contain one or more one or more
EXTENSION
elements
(cf.
section 3.5
), as well as an
xml:lang
attribute (see
section 2.4.2
), to indicate the
language in which its content is expressed.
This element MAY contain one or more
POLICY-REF
(policy
reference) elements. It MAY also contain one
EXPIRY
element
(indicating
their expiration time), one or more
HINT
element
, and one or more
EXTENSION
element
(cf.
section 3.5
).
[6]
prf
``
*extension
policyrefs
[policies]
*extension
""
[7]
policyrefs
""
[expiry]
*policyref
*hint
*extension
"
"
Here
PCDATA
is defined in [
XML
].
2.3.2.3 Policy reference file lifetimes and
the
EXPIRY
element
2.3.2.3.1 Motivation and
mechanism
It is desirable for servers to inform user agents about how long they can
use the claims made in a policy reference file. By enabling clients to cache
the contents of a policy reference file, it reduces the time required to
process the privacy policy associated with a Web resource. This also reduces
load on the network. In addition, clients that don't have a valid policy
reference file for a URI will need to use
"safe zone"
practices
for their requests. If clients have policy reference files that
they know are still valid, then they can make more informed decisions on how
to proceed.
In order to achieve these benefits, policy reference files SHOULD contain
an
EXPIRY
element, which indicates the lifetime of the policy
reference file. If the policy reference file does not contain an
EXPIRY
element, then it defaults to 24-hour lifetime.
The lifetime of a policy reference file tells user agents how long they can
rely on the claims made in the policy reference file. By setting the lifetime
of a policy reference file, the publishing site agrees that the policies
mentioned in the policy reference file are appropriate for the lifetime of the
policy reference file. For example, if a policy reference file has a lifetime
of 3 days, then a user agent need not reload that file for 3 days, and can
assume that the references made in that policy reference file are good for 3
days. All of the policy references made in a single policy reference file will
receive the same lifetime. The only way to specify different lifetimes for
different policy references is to use separate policy reference files.
The same mechanism used to indicate the lifetime of a policy reference file
is also used to indicate the lifetime of a P3P policy. Thus P3P
POLICIES
elements SHOULD have an
EXPIRY
element
associated with them as well. This lifetime applies to all P3P policies
contained within that
POLICIES
element. If there is no
EXPIRY
element associated with a P3P policy, then it defaults to
24-hour lifetime.
When picking a lifetime for policies and policy reference files, sites need
to pick a lifetime which balances two competing concerns. One concern is that
the lifetime ought to be long enough to allow user agents to receive
significant benefits from caching. The other concern is that the site would
like to be able to change their policy for new data collection without waiting
for an extremely long lifetime to expire. It is expected that lifetimes in the
range of 1-7 days would be a reasonable balance between these two competing
desires. Sites also need to remember the
policy
update requirements
when updating their policies.
When a policy reference file has expired, the information in the policy
reference file MUST NOT be used by a user agent until that user agent has
successfully revalidated the policy reference file, or has fetched a new copy
of the policy reference file.
Note that while user agents are not obligated to revalidate policy
reference files or policy files that have not expired, they MAY choose to
revalidate those files before their expiry period has passed in order to
reduce the need for using
"safe zone" practices
. A
valid P3P user agent implementation does not need to contain a cache for
policies and policy reference files, though the implementation will have
better performance if it does.
2.3.2.3.2 The
EXPIRY
element
The
EXPIRY
element can be used in a policy reference file
and/or in a
POLICIES
element to state how long the policy
reference file (or
policies
) remains valid. The expiry
is given as either an absolute expiry time, or a relative expiry time. An
absolute expiry time is a time, given in GMT, until which the policy reference
file (or
policies
) is valid. A relative expiry time
gives a number of seconds for which the policy reference file (or
policies
) is valid. This expiry time is relative to the
time the policy reference file (or
policies
) was
requested or last revalidated by the client. This computation MUST be done
using the time of the original request or revalidation, and the current time,
with both times generated from the client's clock. Revalidation is defined in
section 13.3 of [
HTTP1.1
].
The minimum amount of time for any relative expiry time is 24 hours, or
86400 seconds. Any relative expiration time shorter than 86400 seconds MUST be
treated as being equal to 86400 seconds in a client implementation. If a
client encounters an absolute expiration time that is in the past, it MUST act
as if NO policy reference file (or policy) is available. See section 2.4.7 "
Absence of Policy Reference File
" for the required
procedure in such cases.
[8]
expiry
""
[9]
absdate
`date="` HTTP-date `"`
[10]
reldate
`max-age="` delta-seconds `"`
Here, HTTP-date is defined in section 3.3.1 of [
HTTP1.1
], and delta-seconds is defined in
section 3.3.2 of [
HTTP1.1
].
2.3.2.3.3 Requesting Policies and Policy
Reference Files
In a real-world network, there may be caches which will cache the contents
of policies and policy reference files. This is good for increasing the
overall network performance, but may have deleterious effects on the operation
of P3P if not used correctly. There are two specific concerns:
When a user agent receives a policy reference file (or policy), if it
was served from a caching proxy (see e.g. [
CACHING
]) the user agent needs to know how long the
policy reference file or policy resided in the caching proxy. This time
MUST be subtracted from the lifetime of the policy or policy reference
file which uses relative expiry.
When a user agent needs to revalidate a policy reference file (or
policy), it needs to make sure that the revalidation fetches a current
version of the policy reference file (or policy). For example, consider
the case where a user agent holds a policy reference file with a 1 day
relative expiry. If the user agent refetches it from a caching proxy, and
the file has been residing in the caching proxy for 3 days, then the
resulting file is useless.
HTTP 1.1 [
HTTP1.1
] contains powerful
cache-control mechanisms to allow clients to place requirements on the
operations of network caches; these mechanisms can resolve the problems
mentioned above. The specific method will be discussed below.
HTTP 1.0, however, does not provide those more sophisticated cache control
mechanisms. An HTTP 1.0 caching proxy will, in all likelihood, compute a cache
lifetime for the policy reference file (or policies) based on the file's
last-modified date; the resulting cache lifetime could be significantly longer
than the lifetime specified by the
EXPIRY
element. The caching
proxy could then serve the policy reference file (or policies) to clients
beyond the lifetime in the
EXPIRY
; the result would be that
user-agents would receive a useless policy reference file (or policies).
The second problem with an HTTP 1.0 caching proxy is that a user agent has
no way to know how long the reference file may have been stored by the caching
proxy. If the policy reference file (or policies) relies on relative expiry,
it would then be impossible for the user agent to determine if the reference
file's lifetime has already expired, or when it will expire.
Thus, if a user agent is requesting a policy reference file or a policy,
and does not know for certain that there are no HTTP 1.0 caches in the path to
the origin server, then the request MUST force an end-to-end revalidation.
This can be done with the
Pragma: no-cache
HTTP request-header. Note
that neither HTTP nor P3P define a way to determine if there is a HTTP
1.0-compliant cache in any given network path, so unless the user agent has
this information derived from an outside source, it MUST force the end-to-end
revalidation.
If the user agent has some way to know that all caches in the network path
to the origin server are compliant with HTTP 1.1 (or that there are no caches
in the network path to the origin server), then the client MAY do the
following instead of forcing an end-to-end revalidation:
Use cache-control request-headers to ensure that the received response
is not older than its lifetime. This is done with the max-age
cache-control setting, with a maximum age significantly less than the
lifetime of the policy reference file (or policies). For example, a user
agent could send Cache-Control: max-age=43200, thus ensuring that the
response is no more than 12 hours old.
Subtract the age of the response from the lifetime of the policy
reference file (or policies), if it uses a relative expiry time. The age
of the response is given by the Age: HTTP response-header.
Note that it is impossible for a client to accurately predict the amount of
latency that may affect an HTTP request. Thus, if the policy reference file
covering a request is going to expire soon, clients MAY wish to consider
warning their users and/or revalidating the policy reference file before
continuing with the request.
2.3.2.3.4 Error handling for policy reference
file and policy lifetimes
The following situations have their semantics specifically defined:
An absolute expiry date in the past renders the policy reference file
(or policies) useless, as does an invalid or malformed expiry date,
whether relative or absolute. In this case, user agents MUST act as if NO
policy reference file (or
policies
) is available.
See section 2.4.7 "
Absence of Policy Reference
File
" for the required procedure in such cases.
A relative expiration time shorter than 86400 seconds (1 day) is
considered to be equal to 86400 seconds.
When a policy reference file contains more than one
EXPIRY
element, the first one takes precedence for determining the lifetime of
the policy reference file.
2.3.2.4 The
POLICY-REF
element
A policy reference file may refer to multiple P3P policies, specifying
information about each. The
POLICY-REF
element describes
attributes of a single P3P policy. Elements within the
POLICY-REF
element give the location of the policy and specify the areas of URI-space
(and cookies) that each policy covers.
POLICY-REF
contains information about a single P3P policy.
about
(mandatory
attribute)
URI reference
([
URI
]), where the fragment
identifier part denotes the
name
of the policy (given in its
name
attribute), and the URI part denotes the URI where the
policy resides (a policy file, or a policy reference file, see
Section 3.2
). If this is a relative URI reference,
it is interpreted relative to the URI of the policy reference file it
resides in.
[11]
policy-ref
``
*include
*exclude
*cookie-include
*cookie-exclude
*method-element
*extension
`
`
Here,
URI-reference
is defined as per
RFC 2396
URI
].
2.3.2.5 The
INCLUDE
and
EXCLUDE
elements
Each
INCLUDE
or
EXCLUDE
element specifies one
local URI or set of local URIs. A set of URIs is specified if the
wildcard character '*'
is used in the
URI-pattern. These elements are used to specify the portion of the Web site
that is covered by the policy referenced by the enclosing
POLICY-REF
element.
When
INCLUDE
(and optionally,
EXCLUDE
) elements
are present in a
POLICY-REF
element, it means that the policy
specified in the
about
attribute of the
POLICY-REF
element applies to all the URIs at the requested host corresponding to the
local-URI(s) matched by any of the
INCLUDE
s, but not matched by
an
EXCLUDE
element.
A policy referenced in a policy reference file can be applied only to URIs
on the DNS (Domain Name System) host that references it. Thus, for example, a
policy reference file at the well-known location of host www.example.com can
apply policies only to resources on www.example.com. However, if
foo.example.com includes a P3P HTTP header in its responses that references a
policy reference file on bar.example.com, that policy reference file would be
applied to resources on foo.example.com (not bar.example.com or
www.example.com). The same policy reference file might be referenced in P3P
HTTP headers sent by multiple hosts, in which case it may be applied to each
host that references it. The
INCLUDE
and
EXCLUDE
elements MUST specify URI patterns relative to the root of the DNS host to
which they are applied. This requirement does NOT apply to the location of the
P3P policy file (the about attribute on the
POLICY-REF
element).
If a
METHOD
element (
section
2.3.2.8
) specifies one or more methods for an enclosing policy reference,
it follows that all methods
not
mentioned are consequently
not
covered by this policy. In the case that this is the only policy
reference for a given URI prefix, user agents MUST assume that NO policy is in
effect for all methods NOT mentioned in the policy reference file. It is legal
but pointless to supply a
METHOD
element without any
INCLUDE
or
COOKIE-INCLUDE
elements.
It is legal, but pointless, to supply an
EXCLUDE
element
without any
INCLUDE
elements; in that case, the
EXCLUDE
element MUST be ignored by user agents.
Note that the set of URIs specified with
INCLUDE
and
EXCLUDE
does not include cookies that might be set or replayed
when requesting one of such URIs: in order to associate policies with cookies,
the
COOKIE-INCLUDE
and
COOKIE-EXCLUDE
elements are needed.
[12]
include
"" relativeURI ""
[13]
exclude
"" relativeURI ""
Here,
relativeURI
is defined as per
RFC 2396
URI
], with the addition that the '
character is to be treated as a wildcard, as defined in
section 2.3.2.1.2
2.3.2.6 The
HINT
element
Policy reference hints are a performance optimization that can be used
under certain conditions. A site may declare a policy reference for itself
using the well-known location, the P3P response header, or the HTML/XHTML
link
tag. It MAY further provide a hint to additional policy
references, such as those declared by other sites.
For example, an HTML page might hint at policy references for its
hyperlinks, embedded content, and action URIs. User agents MAY use the hint
mechanism to discover policy reference files before requesting the affected
URIs when the policy references are not available from the well-known
location.
User agents which use hints to retrieve policies MUST NOT apply them to any
site other than the one which contains the hinted policy reference file.
Any policy reference file MAY contain zero or more policy reference hints.
Each hint is contained in a
HINT
element with two attributes,
scope
and
path
The
scope
attribute is used to specify a URI scheme and
authority to which the hinted policy reference can be applied. If the
authority component (cf. [
URI
]) is a server component
(e.g., a hostname or IP address) the host part of the authority MAY begin with
wildcard
, as defined in Section 2.3.2.1.2.
The
scope
attribute MUST NOT contain a wildcard in any other
position, MUST be encoded according to the conventions in Section 2.3.2.1.2,
and MUST NOT contain a path, query or fragment URI component. Additionally,
if the authority is a server, it SHOULD NOT contain a userinfo part.
For example, legal values for
scope
include:
ftp://ftp.example.org
The following are illegal values for the
scope
attribute:
; the wildcard can only be at the
start
; the trailing slash is not
allowed
www.example.com
; the scheme must be stated
*://www.example.com
; the scheme cannot contain a
wildcard
; the port cannot contain a
wildcard
The
path
attribute is used to locate the policy reference file
on the hinted site. It is a relative URI whose base is the URI scheme and
authority matched in the
scope
attribute. The
path
attribute MUST NOT be an absolute URI, so that the policy reference file is
always retrieved from the same site that it is applied to.
Example 2.3:



[14]
hint
`"), the domain will match only cookies that omit the
domain
attribute (and thus have domain equivalent to the request
host as per
RFC 2965
([
STATE
]).
Cookies that omit the path attribute have the default path of the request
URI that generated the set-cookie response as per
RFC 2965
STATE
]. The
path
attribute of a
COOKIE-INCLUDE
should be matched against this default value if a
cookie omits the
path
attribute.
All four attributes are optional. If an attribute is absent, the
COOKIE-INCLUDE
(resp.
COOKIE-EXCLUDE
) will match
cookies that have that attribute set to any value.
When
COOKIE-INCLUDE
(and optionally,
COOKIE-EXCLUDE
) elements are present in a
POLICY-REF
element, the policy specified in the
about
attribute of the
POLICY-REF
element applies to every cookie that is matched by
any
COOKIE-INCLUDE
's, and not matched by a
COOKIE-EXCLUDE
element.
User agents MUST interpret
COOKIE-INCLUDE
and
COOKIE-EXCLUDE
elements in a policy reference file to determine
the policy that applies to cookies set by or replayed to the host to which the
policy reference file applies. While the domain attribute of a
COOKIE-INCLUDE
may match more broadly (for example, if the domain
attribute is omitted it defaults to matching any domain value), user agents
MUST limit their application of the policy to domains that could be legally
used in a cookie set by the host to which the policy reference file applies.
For example, if abc.xyz.example.com declares a policyref with

, this would be
matched to cookies with domains such as .abc.xyz.example.com and
.xyz.example.com, but not .example.com or .xyz.sample.com.
A P3P policy can be associated with a cookie by the host that set that
cookie as well as by any or all of the hosts to which it might be replayed. A
user agent MAY fetch a cookie policy at the time a cookie is set and apply it
later when the cookie is replayed, perhaps to other hosts in the domain. A
user agent MAY request a policy reference file from a host before replaying a
cookie to that host, and if the policy reference file contains an appropriate
COOKIE-INCLUDE
, a policy will be applied to that cookie even if
the cookie was not set by that host. Any host to which the cookie may be
replayed MUST be able to honor all the policies associated with the cookie,
regardless of whether that host declares a policy for that cookie. Thus sites
that set cookies that may be replayed to multiple hosts within a domain need
to coordinate to make sure all the hosts can follow the declared policy. In
addition, sites should be cautious with their use of wildcards to make sure
that they do not inadvertently apply a policy to cookies to which it should
not be applied (including previously set cookies that are still in use and
cookies set by other hosts in the domain).
The policy that applies to a cookie applies until the policy expires, even
if the associated policy reference file expires prior to policy expiry (but
after the cookie was set). If the policy associated with a cookie has expired,
then the user agent SHOULD reevaluate the cookie policy before sending the
cookie. In addition, user agents MUST use only non-expired policies and policy
reference files when evaluating new set-cookie events.
Example 2.4 states that
/P3P/Policies.xml#first
applies to all
cookies.
Example 2.4:







Example 2.5 states that
/P3P/Policies.xml#first
applies to all
cookies, except cookies with the cookie name value of
obnoxious-cookie
", a domain value of
.example.com
", and a path value of "
", and that
/P3P/Policies.xml#second
applies to all cookies with the cookie
name of "
obnoxious-cookie
", a domain value of
.example.com
", and a path value of "
".
Example 2.5:











[15]
cookie-include
"[` name="` token `"`] ; matches the cookie's NAME
[` value="` token `"`] ; matches the cookie's VALUE
[` domain="` token `"`] ; matches the cookie's Domain
[` path="` token `"`] ; matches the cookie's Path
"/>"
[16]
cookie-exclude
"[` name="` token `"`] ; matches the cookie's NAME
[` value="` token `"`] ; matches the cookie's VALUE
[` domain="` token `"`] ; matches the cookie's Domain
[` path="` token `"`] ; matches the cookie's Path
"/>"
Here,
token
NAME
VALUE
Domain
and
Path
are
defined as per
RFC
2965
STATE
], with the addition that the
' character is to be treated as a wildcard, as defined
in
section 2.3.2.1.2
Note that [
STATE
] states default values for the
domain and path attributes of cookies: these should be used in the comparison
if those attributes are not found in a specific cookie. Also, conforming to
STATE
], if an explicitly specified
Domain
value does not start with a full stop ("
"),
the user agent MUST prepend a full stop for it; and, note that every
Path
begins with the "
" character.
2.3.2.8 The
METHOD
element
By default, a policy reference applies to the stated URIs regardless of the
method used to access the resource. However, a Web site may wish to define
different P3P policies depending on the method to be applied to a resource.
For example, a site may wish to collect more data from users when they are
performing
PUT
or
DELETE
methods than when
performing
GET
methods.
The
METHOD
element in a policy reference file is used to state
that the enclosing policy reference only applies when the specified methods
are used to access the referenced resources. The
METHOD
element
may be repeated to indicate multiple applicable methods. If the
METHOD
element is not present in a
POLICY-REF
element, then that
POLICY-REF
element covers the resources
indicated regardless of the method used to access them.
So, to state that
/P3P/Policies.xml#first
applies to all
resources whose paths begin with
/docs/
for
GET
and
HEAD
methods, while
/P3P/Policies.xml#second
applies
for
PUT
and
DELETE
methods, the following policy
reference would be written:
Example 2.6:



/docs/*
GET
HEAD


/docs/*
PUT
DELETE



Note that HTTP requires the same behavior for
GET
and
HEAD
requests, thus it is inappropriate to specify different P3P
policies for these methods. The syntax for the
METHOD
element
is:
[17]
method-element
`` Method ``
Here,
Method
is defined in the section
5.1.1 of [
HTTP1.1
].
Finally, note that the
METHOD
element is designed to be used
in conjunction with
INCLUDE
or
COOKIE-INCLUDE
elements. A
METHOD
element by itself will never apply a
POLICY-REF
to a URI.
2.3.3 Applying a Policy to a URI
A policy reference file specifies the policy which applies to a given URI.
In other words, the indicated policy describes all effects of dereferencing
the given URI (in some cases, with the appropriately specified
METHOD
).
There is a general rule which describes what it means for a P3P policy to
cover a URI:
the referenced policy MUST cover actions that the user's
client software is expected to perform as a result of requesting that URI
Obviously, the policy must describe all data collection performed by site as a
result of processing the request for the URI. Thus, if a given URI is covered
for terms of
GET
requests, then the policy given by the policy
reference file MUST describe all data collection performed by the site when
that URI is dereferenced. Likewise, if a URI is covered for
POST
requests, then any data collection that occurs as a result of POSTing a form
or other content to that URI MUST be described by the policy.
The concept of "actions that the client software is expected to perform"
includes the setting of client-side cookies or other state-management
mechanisms invoked by the response. If executable code is returned when a URI
is requested, then the P3P policy covering that URI MUST cover certain actions
which will occur when that code is executed. The covered actions are any
actions which could take place without the user explicitly invoking them. If
explicit user action causes data to be collected, then the P3P policy covering
the URI for that action would disclose that data collection.
Some specific examples:
Fetching a URI returns an HTML page which contains a form, and the form
contents are sent to a second URI when the user clicks a "Submit" button.
The P3P policy covering the second URI MUST disclose all data collected by
the form. The P3P policy covering the first URI (the URI the form was
loaded from) MAY or MAY NOT disclose any of the data that will be
collected on the form.
An HTML page includes JavaScript code which tracks how long the page is
displayed and whether the user moved the mouse over a certain object on
the page; when the page is unloaded, the JavaScript code sends that
information to the server where the HTML page originated. The activity of
the JavaScript code MUST be covered by the P3P policy of the HTML page.
The reasoning is that this activity takes place without the user's
knowledge or consent, and it occurs automatically as a result of loading
the page.
A resource returns an executable for an electronic mail program. In
order to use the email program, the user must run an installation program,
start the email program, and use its facilities. The P3P policy covering
URI from where the email program was downloaded is not required to make a
statement about the data which could be collected by using the email
program. Installing and running the email program is clearly outside the
Web browsing experience, so it is not covered by this specification. A
separate protocol could be designed to allow downloaded applications to
present a P3P policy, but this is outside the scope of this
specification.
An HTML page containing a form includes a reference to an executable
which provides a custom client-side control. The data in the control is
submitted to a site when the form is submitted. In this case, the URI for
the HTML page and the URI for the custom control is not required to make a
statement about the data the custom control represents. However, the URI
to which the form contents are posted MUST cover the data from the custom
control, just as it would cover any other data collected by processing the
form. This behavior is similar to the way HTML forms are handled when they
use only standard HTML controls: the control itself collects no data, and
the data is collected when the form is posted. Note that this example
assumes that the form is only posted when the user actively presses a
"submit" or similar button. If the form were posted automatically (for
example, by some JavaScript code in the page), then this example would be
similar to example #2, and the data collected by the form MUST be
described in the P3P policy which covers the HTML form.
Requests to a URI are redirected to a third party. If the first party
embeds previously collected personal data in the query string or other
part of the redirect URI, the privacy policy for the first party's URI
MUST describe the types of data transmitted and include the third party as
a recipient.
2.3.4
Forms and Related Mechanisms
Forms deserve special consideration, as they often link to CGI scripts or
other server-side applications in their action URIs (the
action URI
is the URI given in the action attribute of the HTML


element, as defined in section 17.3 of [
HTML
]). It is often the case that those action URIs are
covered by a different policy than the form itself.
If a user agent is unable to find a matching include-rule for a given
action URI in the policy reference file that was referenced from the page, it
SHOULD assume that
no
policy is in effect. Under these circumstances,
user agents SHOULD check the
well-known
location
on the host of the action URI to attempt to find a policy
reference file that covers the action URI. If this does not provide a P3P
policy to cover the action URI, then a user agent MAY try to retrieve the
policy reference file by using the
HINT
mechanism
on the action URI, and/or by issuing a
HEAD
request
to the action URI before actually submitting any data in order to find the
policy in effect. Services SHOULD ensure that server-side applications can
properly respond to such
HEAD
requests and return the
corresponding policy reference link in the headers. In case the underlying
application does not understand the
HEAD
request and
no
policy has been predeclared for the action URI in question, user agents MUST
assume that
no
policy is in effect and SHOULD inform the user about
this or take the corresponding actions according to the user's
preferences.
Note that services might want to make use of the

element in order to declare policies for
server-side applications that only cover a subset of supported methods, e.g.,
POST
or
GET
. Under such circumstances, it is
acceptable that the application in question only supports the methods given in
the policy reference file (e.g.,
PUT
requests need not be
supported). User agents SHOULD NOT attempt to issue a
HEAD
request to an action URI if the relevant methods specified in the form's
method
attribute have been properly predeclared in the page's
policy reference file.
In some cases,
different
data is collected at the
same
action URI depending on some selection in the form. For example, a search
service might offer to both search for people (by name and/or email) and
(arbitrary) images. Using a set of radio buttons on the form, a single
server-side application located at one and the same action URI handles both
cases and collects the required information necessary for the search. If a
service wants to predeclare the data collection practices of the server-side
application it MAY declare
all
of the data collection practices in a
single
policy file (using a

declaration
matching the action URI). In this case, user agents MUST assume that all data
elements are collected under every circumstance. This solution offers the
convenience of a single policy but might not properly reflect the fact that
only parts of the listed data elements are collected at a time. Services
SHOULD make sure that a simple
HEAD
request to the action URI
(i.e., without any arguments, especially without the value of the selected
radio button) will return a policy that covers all cases.
Note that if a form is handled through use of the
GET
method,
then the action URI reflects the choice of form elements selected by the user.
In some cases, it will be possible to make use of the wildcard syntax allowed
in policy reference files to specify different policies for different uses of
the same form action-handler URI. Therefore, user agents MUST include the
query-string portion of URIs when making comparisons with
INCLUDE
and
EXCLUDE
elements in policy reference files.
2.4 Additional Requirements
2.4.1 Non-ambiguity
User agents need to be able to determine unambiguously what policy applies
to a given URI. Therefore, sites SHOULD avoid declaring more than one
non-expired policy for a given URI. In some rare case sites MAY declare more
than one non-expired policy for a given URI, for example, during a transition
period when the site is changing its policy. In those cases, the site will
probably not be able to determine reliably which policy any given user has
seen, and thus it MUST honor all policies (this is also the case for compact
policies, cf.
Section 4.1
and
Section 4.6
). Sites MUST be cautious in their
practices when they declare multiple policies for a given URI, and ensure that
they can actually honor all policies simultaneously.
If a policy reference file at the
well-known
location
declares a non-expired policy for a given URI, this policy
applies, regardless of any conflicting policy reference files referenced
through HTTP headers or HTML/XHTML link tags.
If an HTTP response header includes references to more than one policy
reference file, P3P user agents MUST ignore all references after the first
one.
If an HTML (resp. XHTML) file includes HTML (resp. XHTML)
link
tag references to more than one policy reference file, P3P user agents MUST
ignore all references after the first one.
If a user agent discovers more than one non-expired P3P policy for a given
URI (for example because a page has both a P3P header and a
link
tag that reference different policy reference files, or because P3P headers
for two pages on the site reference different policy reference files that
declare different policies for the same URI), the user agent MAY assume any
(or all) of these policies apply as the site MUST honor all of them.
2.4.2 Multiple Languages
Multiple language versions (translations) of the same policy can be offered
by the server using the HTTP "
Content-Language
" header to
properly indicate that a particular language has been used for the policy.
This is useful so that human-readable fields such as entity and consequence
can be presented in multiple languages. The same mechanism can also be used to
offer multiple language versions for data schemas. Servers SHOULD return a
localized policy in response to an HTTP request with an HTTP
Accept-Language
" header when a policy matching the given
language preferences is available.
Whenever
Content-Language
is used to distinguish policies at
the same URI that are offered in multiple languages, the policies MUST have
the same meaning in each language. Two policies (or two data schemas) are
taken to be identical if
All formal (not natural language) protocol elements are semantically
identical (e.g., attribute order does not matter, the presence or absence
of a default value does not matter, but attribute values matter)
All natural language protocol elements correspond one-to-one, and for
each correspondence, one is a careful translation of the other.
Due to the use of the
Accept-Language
mechanism, implementers
should take note that user agents may see different language versions of a
policy or policy reference file despite sending the same
Accept-Language
request header if a new language version of a
policy or data schema has been added.
Finally, language declarations can be also included directly within P3P XML
files: the
POLICY
POLICIES
META
, and
DATASCHEMA
elements MAY take an
xml:lang
attribute
to indicate the language of any human-readable fields they contain
xml:lang
is normatively defined in section 2.12 of [
XML
]).
[18]
xml-lang
` xml:lang="` language `"`
Here,
language
is a language identifier as
defined in [
LANG
].
2.4.3 The "Safe Zone"
P3P defines a special set of "safe zone" practices, which SHOULD be used by
all P3P-enabled user agents and services for the communications which take
place as part of fetching a P3P policy or policy reference file. In
particular, requests to the
well-known
location
for policy reference files SHOULD be covered by these "safe zone"
practices. Communications covered by the safe zone practices SHOULD have only
minimal data collection, and any data that is collected is used only in
non-identifiable ways.
To support this safe zone, P3P user agents SHOULD suppress the transmission
of data unnecessary for the purpose of finding a site's policy until the
policy has been fetched. Therefore safe-zone practices for user agents include
the following requirements:
User agents SHOULD NOT send the HTTP
Referer
header in the
safe zone
User agents SHOULD NOT accept cookies from safe-zone requests
User agents MAY also wish to refrain from sending user agent information
or cookies accepted in a previous session on safe zone requests
User agent implementers need to be aware that there is a privacy
trade-off with using the
Accept-Language
HTTP header in the
safe zone. Sending the correct
Accept-Language
header will
allow fetching a P3P policy in the user's preferred natural language (if
available), but does expose a certain amount of information about the
identity of the user. User agents MAY wish to allow users to decide when
these headers should be sent.
Safe-zone practices for servers include the following requirements:
Servers SHOULD NOT require the receipt of an HTTP
Referer
header, cookies, user agent information, or other information unnecessary
for responding to requests in the safe zone
If the user agent suppresses the
Accept-Language
HTTP
header as part of safe-zone operation, the server is free to choose any of
the available translations
If the communications is taking place over a secure connection (such as
SSL), then the server SHOULD NOT require an identity certificate from the
user agent for safe zone requests
In addition, servers SHOULD NOT use in an identifiable way any
information collected while serving a safe zone request
Note that the safe zone requirements do not say that sites cannot keep
identifiable information -- only that they SHOULD NOT use in an identifiable
way any information collected while serving a policy file or policy reference
file. Tracking down the source of a denial of service attack, for example,
would be a legitimate reason to use this information.
2.4.4 Policy and Policy Reference File Processing by
User Agents
P3P user agents MUST only render or act upon P3P policies and policy
reference files that are well-formed XML.
P3P user agents SHOULD only render or act upon P3P policies and policy
reference files that conform to the XML schema given in
Appendix 4
, and user agents SHOULD NOT rely upon
any part of a policy or policy reference file that does not conform to this
XML schema.
User agents MUST NOT locally modify a P3P policy or policy reference file
in order to make it conform to the XML schema.
2.4.5 Security of Policy Transport
P3P policies and references to P3P policies SHOULD NOT contain any
sensitive information. This means that there are no additional security
requirements for transporting a reference to a P3P policy beyond the
requirements of the document it is associated with; so, if an HTML document
would normally be served over a non-encrypted session, then P3P does
not
require nor recommend that the document be served over an
encrypted session when a reference to a P3P policy is included with that
document.
2.4.6 Policy Updates
Note that when a Web site changes its P3P policy, the old policy applies to
data collected when it was in effect. It is the responsibility of the site to
keep records of past P3P policies and policy reference files along with the
dates when they were in effect, and to apply these policies appropriately.
If a site wishes to apply a new P3P policy to previously collected data, it
MUST provide appropriate notice and opportunities for users to accept the new
policy that are consistent with applicable laws, industry guidelines, or other
privacy-related agreements the site has made.
2.4.7 Absence of Policy Reference File
If no policy reference file is available for a given site, user agents MUST
assume (an empty) policy reference file exists at the well-known location with
a 24 hour expiry, and therefore if the user returns to the site after 24
hours, the user agent MUST attempt to fetch a policy reference file from the
well-known location again. User agents MAY check the well-known location more
frequently, or upon a certain event such as the user clicking a browser
refresh button. Sites MAY place a policy reference file at the well-known
location that indicates that no policy is available, but set the expiry such
that user agents know they need not check every 24 hours.
2.4.8 Asynchronous Evaluation
User agents MAY asynchronously fetch and evaluate P3P policies. That is,
P3P policies need not necessarily be fetched and evaluated prior to other HTTP
transactions.This behavior may be dependent on the the user's preferences and
the type of request being made. Until a policy is evaluated, the user agent
SHOULD treat the site as if it has no privacy policy. Once the policy has been
evaluated, the user agent SHOULD apply the user's preferences. To promote
deterministic behavior, the user agent SHOULD defer application of a policy
until a consistent point in time. For example, a Web browser might apply a
user's preferences just after the user agent completes a navigation, or when
confirming a form submission.
2.5 Example Scenarios
As an aid to sites deploying P3P, several example scenarios are presented,
along with descriptions of how P3P is used on those sites.
Scenario 1
: Web site basic.example.com uses a variety of
images, all of which it hosts. It also includes some forms, which are all
submitted directly to the site. This site can declare a single P3P policy for
the entire site (or if different privacy policies apply to different parts of
the site, it can declare multiple P3P policies). As long as all of the images
and form action URIs are in directories covered by the site's P3P policy, user
agents will automatically recognize the images and forms as covered by the
site's policy.
Scenario 2
: Web site busy.example.com uses a content
distribution network called cdn.example.com to host its images so as to reduce
the load on its servers. Thus, all of the images on the site have URIs at
cdn.example.com. CDN acts as an agent to Busy in this situation, and collects
no data other than log data. This log data is used only for Web site and
system administration in support of providing the services that Busy
contracted for. Busy's privacy policy applies to the images hosted by CDN, so
Busy uses the
HINT
element in its policy reference file to point
to a suitable policy reference file at CDN, indicating that such images are
covered by example.com P3P policy.
Scenario 3
: Web site busy.example.com also has a contract
with an advertising company called clickads.example.com to provide banner ads
on its site. The contract allows Clickads to set cookies so as to make sure
each user does not see a given ad more than three times. Clickads collects
statistics on how many users view each ad and reports them to the companies
whose products are being advertised. But these reports do not reveal
information about any individual users. As was the case in Scenario 2, Busy's
privacy policies applies to these ads hosted by Clickads, so Busy uses the
HINT
element in its policy reference file to point to a suitable
policy reference file at Clickads, indicating that Busy P3P policy applies to
such embedded content served by clickads.example.com. The companies whose
products are being advertised need not be mentioned in the Busy privacy policy
because the only data they are receiving is aggregate data.
Scenario 4
: Web site busy.example.com also has a contract
with funchat.example.com to host a chat room for its users. When users enter
the chat room they are actually leaving the Busy site. However, the chat room
has the Busy logo and is actually covered by the Busy privacy policy. In this
instance Funchat is acting as an agent for Busy, but -- unlike the previous
examples -- their content is not embedded in the Busy site. Busy can use the
HINT
element in its policy reference file to point to a suitable
Funchat policy reference file, that indicates that Funchat chat room is
covered by Busy privacy policy, therefore facilitating a smoother transition
to the chat room.
Scenario 5
: Web site bigsearch.example.com has a form that
allows users to type in a search query and have it performed on their choice
of search engines located on other sites. When a user clicks the "submit"
button, the search query is actually submitted directly to these search
engines -- the action URI is not on bigsearch.example.com but rather on the
search engine selected by the user. Bigsearch can declare the privacy policies
for these search engines by using the
HINT
element to point to
their corresponding policy reference files. So when a user clicks the "submit"
button, their user agent can check its privacy policy before posting any data.
In order to make this search choice mechanism work, Bigsearch might actually
have a form with an action URI on its own site, which redirects to the
appropriate search engine. In this case, the user agent should check the
search engine privacy policy upon receiving the redirect response.
Scenario 6
: Web site bigsearch.example.com also has a form
that allows users to type in a search query and have it simultaneously
performed on ten different search engines. Bigsearch submits the queries, gets
back the results from each search engine, removes the duplicates, and presents
the results to the user. In this case, the user interacts only with Bigsearch.
Thus, the only P3P policy involved is the one that covers the Bigsearch Web
site. However, Bigsearch must disclose that it shares the users' search
queries with third parties (the search Web sites), unless Bigsearch has a
contract with these search engines and they act as agents to Bigsearch.
Scenario 7
: Web site bigsearch.example.com also has banner
advertisements provided by a company called adnetwork.example.com. Adnetwork
uses cookies to develop profiles of users across many different Web sites so
that it can provide them with ads better suited to their interests. Because
the data about the sites that users are visiting is being used for purposes
other than just serving ads on the Bigsearch Web site, Adnetwork cannot be
considered an agent in this context. Adnetwork must create its own P3P policy
and use its own policy reference file to indicate what content it applies to.
In addition, Bigsearch may optionally use the
HINT
element in its
policy reference file to indicate that the Adnetwork P3P policy reference file
applies to these advertisements. Bigsearch should only do this if Adnetwork
has told it what P3P policy applies to these advertisements and has agreed to
notify Bigsearch if the policy reference needs to be changed.
Scenario 8:
Web site busy.example.com uses cookies
throughout its Web site. It discloses a cookie policy, separate from its
regular P3P policy to cover these cookies. It uses the
COOKIE-INCLUDE
element in its policy reference file to declare
the appropriate policy for these cookies. As a performance optimization, it
also makes available a compact policy by sending a P3P header that includes
this compact policy whenever it sets a cookie.
Scenario 9:
Web site config.example.com provides a service
in which they optimize various kinds of Web content based on each user's
computer and Internet configuration. Users go to the Config Web site and
answer questions about their computer, monitor, and Internet connection.
Config encodes the responses and stores them in a cookie. Later, when the user
is visiting Busy -- a Web site that has contracted with Config -- whenever
the browser requests content that can be optimized (certain images, audio
files, etc.), Busy will redirect the user to Config, which will read the
user's cookie, and deliver the appropriate content. In this case, Config
should declare a privacy policy that describes the kinds of data collected and
stored in its cookies, and how that data is used. It should use a
COOKIE-INCLUDE
element in its policy reference file to declare
the policy for the cookies. It will probably reference Busy's P3P policy for
the actual images or audio files delivered, as it is acting much like CDN acts
in scenario 2. Busy will probably also use
HINT
elements in its
policy reference file to reference the policy for the Config-delivered
content.
3. Policy Syntax and Semantics
P3P policies are encoded in XML with namespaces (see [
XML
] and [
XML-Name
]). A possible
encoding using the RDF data model ([
RDF
]) is provided in
P3P-RDF
].
Section 3.1 begins with an example of an English language privacy policy
and a corresponding P3P policy. P3P policies include general assertions that
apply to the entire policy as well as specific assertions -- called
statements
-- that apply only to the handling of particular types of
data referred to by
data references
. Section 3.2 describes the
POLICY
element and policy-level assertions. Section 3.3 describes
statements and data references.
3.1 Example policies
3.1.1 English language policies
The following are two examples of English-language privacy policy to be
encoded as a P3P policy. Both policies are for one example company,
CatalogExample, which has different policies for those browsing their site and
those actually purchasing products. Example 3.1. is provided in both English
and as a more formal description using P3P element and attribute names.
Example 3.1: CatalogExample's Privacy Policy for
Browsers
At CatalogExample, we care about your privacy. When you come to our
site to look for an item, we will only use this information to improve
our site and will not store it with information we could use to identify
you.
CatalogExample, Inc. is a licensee of the PrivacySealExample Program.
The PrivacySealExample Program ensures your privacy by holding Web site
licensees to high privacy standards and confirming with independent
auditors that these information practices are being followed.
Questions regarding this statement should be directed to:
CatalogExample
4000 Lincoln Ave.
Birmingham, MI 48009 USA
email: catalog@example.com
Telephone 248-EXAMPLE (248-392-6753)
If we have not responded to your inquiry or your inquiry has not been
satisfactorily addressed, you can contact PrivacySealExample at
errors or wrongful actions arising in connection with the privacy
policy.
What We Collect and Why:
When you browse through our site we collect:
the basic information about your computer and connection to make
sure that we can get you the proper information and for security
purposes.
aggregate information on what pages consumers access or visit to
improve our site.
Data retention:
We purge every two weeks the browsing information that we collect.
Here is Example 3.1 in a more formal description, using the P3P element and
attribute names [with the section of the spec that was used cited in brackets
for easy reference]:
Disclosure URI:
3.2.2 Policy
Entity: CatalogExample
4000 Lincoln Ave.
Birmingham, MI 48009
USA
catalog@example.com
+1 (248) 392-6753
3.2.4 Entity
Access to Identifiable Information: None
3.2.5 Access
Disputes:
resolution type: independent
service: http://www.privacyseal.example.org
description: PrivacySealExample
3.2.6 Disputes
Remedies: we'll correct any harm done wrong
3.2.7 Remedies
We collect:
dynamic.clickstream
dynamic.http
4.5 Base data schema
For purpose: Web site and system administration, research and
development
3.3.4 Purpose
Recipients: Only ourselves and our agents
3.3.5 Recipients
Retention: As long as appropriate for the stated purposes
3.3.6 Retention
(Note also that the site's human-readable privacy policy MUST mention that
data is purged every two weeks, or provide a link to this
information.)
Example 3.2: CatalogExample's Privacy Policy for
Shoppers
At CatalogExample, we care about your privacy. We will never share
your credit card number or any other financial information with any
third party. With your permission only, we will share information with
carefully selected marketing partners that meet either the preferences
that you've specifically provided or your past purchasing habits. The
more we and know about your likes and dislikes, the better we can tailor
offerings to your needs.
CatalogExample is a licensee of the PrivacySealExample Program. The
PrivacySealExample Program ensures your privacy by holding Web site
licensees to high privacy standards and confirming with independent
auditors that these information practices are being followed.
Questions regarding this statement should be directed to:
CatalogExample
4000 Lincoln Ave.
Birmingham, MI 48009 USA
email: catalog@example.com
Telephone +1 248-EXAMPLE (+1 248-392-6753)
If we have not responded to your inquiry or your inquiry has not been
satisfactorily addressed, you can contact PrivacySealExample -
all errors or wrongful actions arising in connection with the privacy
policy.
When you browse through our site we collect:
the basic information about your computer and connection to make
sure that we can get you the proper information and for security
purposes; and
aggregate information on what pages consumers access or visit to
improve our site
If you choose to purchase an item we will ask you for more information
including:
your name and address so that we can have your purchase delivered
to you and so we can contact you in the future;
your email address and telephone number so we can contact
you;
a login and password to use to update your information at any time
in the future; and
financial information to complete your purchase (you may choose to
store this for future use)
optionally, you can enter other demographic information so that we
can tailor services to you in the future.
Also on this page we will give you the option to choose if you would
like to receive email, telephone calls or written service from
CatalogExample or from our carefully selected marketing partners who
maintain similar privacy practices. If you would like to receive these
solicitations simply check the appropriate boxes. You can choose to stop
participating at any time simply by changing your preferences.
Changing and Updating personal information
Consumers can change all of their personal account information by going
to the preferences section of CatalogExample at
address, telephone number, email address, password as well as your
privacy settings.
CatalogExample uses cookies only to see if you have been an
CatalogExample customer in the past and, if so, customize services based
on your past browsing habits and purchases. We do not store any personal
data in the cookie nor do we share or sell the any of the information
with other parties or affiliates.
Data retention
We will keep the information about you and your purchases for as long as
you remain our customer. If you do not place an order from us for one
year we will remove your information from our databases.
3.1.2
XML
encoding of policies
The following pieces of [
XML
] capture the information as
expressed in the above two examples. P3P policies are statements that are
properly expressed as well-formed
XML
. The policy syntax
will be explained in more detail in the sections that follow.
XML Encoding of Example 3.1

discuri="http://www.catalog.example.com/PrivacyPracticeBrowsing.html"
xml:lang="en">


CatalogExample
4000 Lincoln Ave.
Birmingham
MI
48009
USA
catalog@example.com
1
248
3926753




service="http://www.PrivacySeal.example.org"
short-description="PrivacySeal.example.org">
PrivacySeal's logo














XML Encoding of Example 3.2:

discuri="http://www.catalog.example.com/Privacy/PrivacyPracticeShopping.html"
opturi="http://catalog.example.com/preferences.html"
xml:lang="en">


CatalogExample
4000 Lincoln Ave.
Birmingham
MI
48009
USA
catalog@example.com
1
248
3926753




service="http://www.PrivacySeal.example.org"
short-description="PrivacySeal.example.org">
PrivacySeal's logo





We record some information in order to serve your request
and to secure and improve our Web site.











We use this information when you make a purchase.




















At your request, we will send you carefully selected marketing
solicitations that we think you will be interested in.



















We allow you to set a password so that you
can access your own information.













At your request, we will tailor our site and
highlight products related to your interests.














We tailor our site based on your past visits.















3.2 Policies
This section defines the syntax and semantics of P3P policies. All policies
MUST be encoded using [
UTF-8
].
In cases where the P3P vocabulary is not precise enough to describe a Web
site's practices, sites should use the vocabulary terms that most closely
match their practices and provide further explanation in the
CONSEQUENCE
field and/or their human-readable policy. However,
policies MUST NOT make false or misleading statements.
Policies have to be placed inside a
POLICIES
element.
3.2.1
The
POLICIES
element
The
POLICIES
element gathers one or more P3P policies together
in a single file. This is provided as a performance optimization: many
policies can be collected with a single request, improving network traffic and
caching.
POLICIES
element is the root element of policy files.
Further, the
POLICIES
element can be put within the policy
reference file, inside the
META
element:: in this case, user
agents need only fetch a single file, containing both the policy reference
file and the policies.
The
POLICIES
element can optionally contain an
xml:lang
attribute (see
section 2.4.2
),
an
EXPIRY
element, indicating
the expiration of the included policies, and an embedded data schema using the
DATASCHEMA
element (see
Section 5
).
Since policies are included in a
POLICIES
element, each MUST
have a
name
attribute which is unique in the file. This allows
policy references (in
POLICY-REF
elements) to link to that
policy.
Example 3.3:
The file in
could
have the following content:

....
....
....

The files in
could then be
associated to the second policy ("
policy2
") using the following
policy reference file in



/Shops/CDs/*



[19]
policies
``
[expiry]
[dataschema]
*policy
"
"
3.2.2 The
POLICY
element
The
POLICY
element contains a complete P3P policy. Each P3P
policy MUST contain exactly one
POLICY
element. The policy
element MUST contain an
ENTITY
element that identifies the legal
entity making the representation of the privacy practices contained in the
policy. In addition, the policy element MUST contain an
ACCESS
element, one or more
STATEMENT
elements, a
DISPUTES-GROUP
element, a
P3P data
schema
, and one or more extensions.

includes one or more statements. Each statement includes a set of
disclosures as applied to a set of data elements.
name
mandatory
attribute
name of the policy, used as a fragment identifier to be able to
reference the policy.
discuri
mandatory
attribute
URI of the natural language privacy statement.
opturi
URI of instructions that users can follow to request or decline to
have their data used for a particular purpose (opt-in or opt-out). This
attribute is
mandatory
for policies that
contain a
purpose
with required
attribute set to
opt-in
or
opt-out
. Note that
the opt-in or opt-out procedures are determined by each site and may not
necessarily include a central mechanism for the entire site or an
automated online mechanism.
xml:lang
Language in which the policy is expressed (see
section 2.4.2
).
[20]
policy
`` discuri=` quoted-URI
[` opturi=` quoted-URI]
[xml-lang] `>`
*extension
[test]
entity
access
[disputes-group]
1*statement-block
*extension
`
`
[21]
quoted-URI
`"` URI `"`
Here, URI is defined as per
RFC 2396
URI
].
3.2.3 The
TEST
element
The TEST element is used for testing purposes: the presence of
TEST
in a policy indicates that the policy is just an example,
and as such, it MUST be ignored, and not be considered as a valid P3P
policy.
[22]
test
""
3.2.4 The
ENTITY
element
The
ENTITY
element gives a precise description of the legal
entity making the representation of the privacy practices.

identifies the legal entity making the representation of the privacy
practices contained in the policy
The
ENTITY
element contains a description of the legal entity
consisting of
DATA elements
referencing (all or some of)
the fields of the
business dataset
: it MUST
contain both the legal entity's name and one or more contact information
fields among postal address, telephone number, email address, URI. Note that
some laws and codes of conduct require entities to include a postal address or
other specific information in their contact information.
[23]
entity
""
*extension
entitydescription
*extension
"
"
[24]
entitydescription
""
`` PCDATA ""
*(`` PCDATA "")
"
"
Here,
string
is defined as a
sequence of characters (with " and & escaped) among the values
that are allowed by the
business dataset
PCDATA
is defined as in [
XML
].
3.2.5 The
ACCESS
element
The
ACCESS
element indicates whether the site provides access
to various kinds of information.

the ability of the individual to view identified data and address
questions or concerns to the service provider. Service providers MUST
disclose one value for the access attribute. The method of access is not
specified. Any disclosure (other than

) is not
meant to imply that access to all data is possible, but that some of the
data may be accessible and that the user should communicate further with
the service provider to determine what capabilities they have.
Note that service providers may also wish to provide capabilities to
access information collected through means other than the Web at the
discuri
However, the scope of
P3P statements are limited to data collected through HTTP or other Web
transport protocols. Also, if access is provided through the Web, use of
strong authentication and security mechanisms for such access is
recommended; however, security issues are outside the scope of this
document.
The
ACCESS
element must contain one of the following
elements:

Web site does not collect identified data.

All Identified Data: access is given to all identified data.

Identified Contact Information and Other Identified Data: access is
given to identified online and physical contact information as well as
to certain other identified data.

Identifiable Contact Information: access is given to identified online
and physical contact information (e.g., users can access things such as
a postal address).

Other Identified Data: access is given to certain other identified
data (e.g., users can access things such as their online account
charges).

None: no access to identified data is given.
[25]
access
""
*extension
access_disclosure
*extension
"
"
[26]
access_disclosure
"" | ; Identified Data is Not Used
"" | ; All Identifiable Information
"" | ; Identified Contact Information and
Other Identified Data
"" | ; Identifiable Contact Information
"" | ; Other Identified Data
"" ; None
3.2.6 The
DISPUTES
element
A policy SHOULD contain a
DISPUTES-GROUP
element, which
contains one or more
DISPUTES
elements. These elements describe
dispute resolution procedures that may be followed for disputes about a
services' privacy practices. Each
DISPUTES
element can optionally
contain a
LONG-DESCRIPTION
element, an
IMG
element,
and a
REMEDIES
element. Service providers with multiple dispute
resolution procedures should use a separate
DISPUTES
element for
each. Since different dispute procedures have separate remedy processes, each
DISPUTES
element would need a separate
LONG-DESCRIPTION
IMG
tag and
REMEDIES
element, if they are being used.

Describes dispute resolution procedures that may be followed for
disputes about a services' privacy practices, or in case of protocol
violation.
resolution-type
mandatory
attribute
takes one of the following four values:
Customer Service
[service]
Individual may complain to the Web site's customer service
representative for resolution of disputes regarding the use of
collected data. The description MUST include information about how
to contact customer service.
Independent Organization
[independent]
Individual may complain to an independent organization for
resolution of disputes regarding the use of collected data. The
description MUST include information about how to contact the
third party organization.
Court
[court]
Individual may file a legal complaint against the Web site.
Applicable Law
[law]
Disputes arising in connection with the privacy statement will
be resolved in accordance with the law referenced in the
description.
service
mandatory
attribute
URI of the customer service Web page or independent organization, or
URI for information about the relevant court or applicable law
verification
URI or certificate that can be used for verification purposes. It is
anticipated that seal providers will provide a mechanism for verifying a
site's claim that they have a seal.
short-description
A short human readable description of the name of the appropriate
legal forum, applicable law, or third party organization; or contact
information for customer service if not already provided at the service
URI. No more than 255
characters
The
DISPUTES
element can contain a
LONG-DESCRIPTION
element, where a human readable description is
present: this should contain the name of the appropriate legal forum,
applicable law, or third party organization; or contact information for
customer service if not already provided at the service URI.

This element contains a (possibly long) human readable
description.

An image logo (for example, of the independent organization or
relevant court)
src
mandatory
attribute
URI of the image logo
width
width in pixels of the image logo
height
height in pixels of the image logo
alt
mandatory attribute
very short textual alternative for the image logo
[27]
disputes-group
""
*extension
1*dispute
*extension
"
"
[28]
dispute
"" resolution-type=" '"'("service"|"independent"|"court"|"law")'"'
" service=" quoted-URI
[" verification=" quotedstring]
[" short-description=" quotedstring]
">"
*extension
[longdescription]
[image]
[remedies]
*extension
"
"
[29]
longdescription
PCDATA
[30]
image
"[" height=" `"` number `"`]
" alt=" quotedstring
"/>"
[31]
quotedstring
`"` string `"`
Here,
string
is defined as a
sequence of characters (with " and & escaped), and
PCDATA
is defined as in [
XML
].
Note that there can be multiple assurance services, specified via multiple
occurrences of
DISPUTES
within the
DISPUTES-GROUP
element. These fields are expected to be used in a number of ways, including
representing that one's privacy practices are self assured, audited by a third
party, or under the jurisdiction of a regulatory authority.
3.2.7 The
REMEDIES
element
Each
DISPUTES
element SHOULD contain a
REMEDIES
element that specifies the possible remedies in case a policy breach
occurs.

Remedies in case a policy breach occurs.
The
REMEDIES
element must contain one or more of the
following:

Errors or wrongful actions arising in connection with the privacy
policy will be remedied by the service.

If the service provider violates its privacy policy it will pay the
individual an amount specified in the human readable privacy policy or
the amount of damages.

Remedies for breaches of the policy statement will be determined based
on the law referenced in the human readable description.
[32]
remedies
""
*extension
1*remedy
*extension
"
"
[33]
remedy
"" |
"" |
""
3.3 Statements
Statements describe data practices that are applied to particular types of
data.
3.3.1
The
STATEMENT
element
The
STATEMENT
element is a container that groups together a
PURPOSE
element, a
RECIPIENT
element, a
RETENTION
element, a
DATA-GROUP
element, and
optionally a
CONSEQUENCE
element and one or more extensions. All
of the data referenced by the
DATA-GROUP
is handled according to
the disclosures made in the other elements contained by the statement. Thus,
sites may group elements that are handled the same way and create a statement
for each group. Sites that would prefer to disclose separate purposes and
other information for each kind of data they collect can do so by creating a
separate statement for each data element.

data practices as applied to data elements.
[34]
statement-block
""
*extension
[consequence]
((purpose recipient retention 1*data-group) |
(non-identifiable [purpose] [recipient] [retention] *data-group))
*extension
"
"
To simplify practice declaration, service providers may aggregate any of
the disclosures (purposes, recipients, and retention) within a statement over
data elements. Service providers MUST make such aggregations as an additive
operation. For instance, a site that distributes your age to
ours
(ourselves and our agents), but distributes your postal code to
unrelated
(unrelated third parties), MAY say they distribute your
name and postal code to
ours
and
unrelated
. Such a
statement appears to distribute more data than actually happens. It is up to
the service provider to determine if their disclosure deserves specificity or
brevity. Note that when aggregating disclosures across statements that include
the
NON-IDENTIFIABLE
element, this element may be included in the
aggregated statement only if it would otherwise appear in every statement if
the statements were written separately.
Also, one must always disclose all options that apply. Consider a site with
the sole purpose of collecting information for the purposes of
contact
(Contacting Visitors for Marketing of Services or
Products). Even though this is considered to be for the
current
(Completion and Support of Activity For Which Data Was Provided) purpose, the
site must state both
contact
and
current
purposes.
Consider a site which distributes information to
ours
in order to
redistribute it to
public
: the site must state both
ours
and
public
recipients.
Service providers often aggregate data they collect. Sometimes this
aggregate data may be used for different purposes than the original data,
shared more widely than the original data, or retained longer than the
original data. For example many sites publish or disclose to their advertisers
statistics such as number of visitors to their Web site, percentage of
visitors who fit into various demographic groups, etc. When aggregate
statistics are used or shared such that it would not be possible to derive
data for individual people or households based on these statistics, no
disclosures about these statistics are necessary in a P3P policy. However,
services MUST disclose the fact that the original data is collected and
declare any use that is made of the data before it is aggregated.
3.3.2
The
CONSEQUENCE
element
STATEMENT
elements may optionally contain a
CONSEQUENCE
element that can be shown to a human user to provide
further explanation about a site's practices.

Consequences that can be shown to a human user to explain why the
suggested practice may be valuable in a particular instance even if the
user would not normally allow the practice.
[35]
consequence
""
PCDATA
"
"
3.3.3 The
NON-IDENTIFIABLE
element
STATEMENT
element may optionally contain the
NON-IDENTIFIABLE
element, signifying either that there is no data
collected under this
STATEMENT
, or that all of the data
referenced by that
STATEMENT
will be anonymized upon
collection.

This element signifies that either no data is collected (including Web
logs), or that the organization collecting the data will anonymize the
data referenced in the enclosing
STATEMENT
. In order to
consider the data "anonymized", there must be no reasonable way for the
entity or a third party to attach the collected data to the identity of
a natural person. Some types of data are inherently anonymous, such as
randomly-generated session IDs. Data which might identify natural people
in some circumstances, such as IP addresses, names, or addresses, must
have a non-reversible transformation applied in order be considered
"anonymized".
An example of a non-reversible transformation is removing the last seven
bits of an IP address and replacing them with zeros. This transformation
must be applied to all copies of the data, including those that might be
stored on backup media. An algorithm that replaces identified data with
unique corresponding values from a table is not considered
non-reversible. In addition, a one-way cryptographic hash would not be
considered non-reversible if the set of possible data values is small
enough that all possible hashed values can be generated and compared
with the value that someone is attempting to reverse.
If the
NON-IDENTIFIABLE
element is present in any
STATEMENT
elements in a policy, then a human readable explanation
of how the data is anonymized MUST be included or linked to at the
discuri
Also, if the
NON-IDENTIFIABLE
element is present in a
STATEMENT
then the other elements in that
STATEMENT
are optional.
[36]
non-identifiable
""
3.3.4
The
PURPOSE
element
Each
STATEMENT
element that does not include a
NON-IDENTIFIABLE
element MUST contain a
PURPOSE
element that contains one or more purposes of data collection or uses of data.
Sites MUST classify their data practices into one or more of the purposes
specified below.

purposes for data processing relevant to the Web.
The
PURPOSE
element MUST contain one or more of the
following:

Completion and Support of Activity For Which Data Was
Provided:
Information may be used by the service provider to
complete the activity for which it was provided, whether a one-time
activity such as returning the results from a Web search, forwarding an
email message, or placing an order; or a recurring activity such as
providing a subscription service, or allowing access to an online
address book or electronic wallet.

Web Site and System Administration:
Information may
be used for the technical support of the Web site and its computer
system. This would include processing computer account information,
information used in the course of securing and maintaining the site, and
verification of Web site activity by the site or its agents.

Research and Development
: Information may be used to
enhance, evaluate, or otherwise review the site, service, product, or
market. This does not include personal information used to tailor or
modify the content to the specific individual nor information used to
evaluate, target, profile or contact the individual.

One-time Tailoring
: Information may be used to tailor
or modify content or design of the site where the information is used
only for a single visit to the site and not used for any kind of future
customization. For example, an online store might suggest other items a
visitor may wish to purchase based on the items he has already placed in
his shopping basket.

Pseudonymous Analysis
: Information may be used to
create or build a record of a particular individual or computer that is
tied to a pseudonymous identifier, without tying identified data (such
as name, address, phone number, or email address) to the record. This
profile will be used to determine the habits, interests, or other
characteristics of individuals
for purpose of research, analysis and
reporting
, but it will not be used to attempt to identify specific
individuals. For example, a marketer may wish to understand the
interests of visitors to different portions of a Web site.

Pseudonymous Decision
: Information may be used to
create or build a record of a particular individual or computer that is
tied to a pseudonymous identifier, without tying identified data (such
as name, address, phone number, or email address) to the record. This
profile will be used to determine the habits, interests, or other
characteristics of individuals
to make a decision that directly
affects that individual
, but it will not be used to attempt to
identify specific individuals. For example, a marketer may tailor or
modify content displayed to the browser based on pages viewed during
previous visits.

Individual Analysis
: Information may be used to
determine the habits, interests, or other characteristics of individuals
and combine it with identified data
for the purpose of research,
analysis and reporting
. For example, an online Web site for a
physical store may wish to analyze how online shoppers make offline
purchases.

Individual Decision
: Information may be used to
determine the habits, interests, or other characteristics of individuals
and combine it with identified data
to make a decision that directly
affects that individual
. For example, an online store suggests
items a visitor may wish to purchase based on items he has purchased
during previous visits to the Web site.

Contacting Visitors for Marketing of Services or
Products
: Information may be used to contact the individual,
through a communications channel other than voice telephone, for the
promotion of a product or service. This includes notifying visitors
about updates to the Web site. This does not include a direct reply to a
question or comment or customer service for a single transaction -- in
those cases,

would be
used. In addition, this does not include marketing via customized Web
content or banner advertisements embedded in sites the user is visiting
-- these cases would be covered by the


and

, or

and

purposes.

Historical Preservation
: Information may be archived
or stored for the purpose of preserving social history as governed by an
existing law or policy. This law or policy MUST be referenced in the

element and MUST include a specific
definition of the type of qualified researcher who can access the
information, where this information will be stored and specifically how
this collection advances the preservation of history.

Contacting Visitors for Marketing of Services or Products Via
Telephone
: Information may be used to contact the individual
via a voice telephone call for promotion of a product or service. This
does not include a direct reply to a question or comment or customer
service for a single transaction -- in those cases,

would be used.

string

Other Uses
: Information may be used in other ways not
captured by the above definitions. (A human readable explanation MUST be
provided in these instances).
Each type of purpose (with the exception of
current
) can have
the following optional attribute:
required
Whether the purpose is a required practice for the site. The attribute
can take the following values:
always
: The purpose is always
required; users cannot opt-in or opt-out of this use of their data.
This is the default when no
required
attribute is
present.
opt-in
: Data may be used for this
purpose only when the user affirmatively requests this use -- for
example, when a user asks to be added to a mailing list. An
affirmative request requires users to take some action specifically
to make the request. For example, when users fill out a survey,
checking an additional box to request to be added to a mailing list
would be considered an affirmative request. However, submitting a
survey form that contains a pre-checked mailing list request box
would not be considered an affirmative request. In addition, for any
purpose that users may affirmatively request, there must also be a
way for them to change their minds later and decline -- this MUST be
specified at the
opturi
opt-out
: Data may be used for this
purpose unless the user requests that it not be used in this way.
When this value is selected, the service MUST provide clear
instructions to users on how to opt-out of this purpose at the
opturi
. Services SHOULD also
provide these instructions or a pointer to these instructions at the
point of data collection.
[37]
purpose
""
*extension
1*purposevalue
*extension
"
"
[38]
purposevalue
"" | ; Completion and Support of Activity For Which Data Was Provided
"" | ; Web Site and System Administration
"" | ; Research and Development
"" | ; One-time Tailoring
"" | ; Pseudonymous Analysis
"" | ; Pseudonymous Decision
"" | ; Individual Analysis
"" | ; Individual Decision
"" | ; Contacting Visitors for Marketing of Services or Products
"" | ; Historical Preservation
"" | ; Telephone Marketing
"" PCDATA ""; Other Uses
[39]
required
" required=" `"` ("always"|"opt-in"|"opt-out") `"`
Service providers MUST use the above elements to explain the purpose of
data collection. Service providers MUST disclose
all that apply
. If a
service provider does not disclose that a data element will be used for a
given purpose, that is a representation that data will not be used for that
purpose. Service providers that disclose that they use data for
other
" purposes MUST provide human readable explanations of
those purposes.
3.3.5
The
RECIPIENT
element
Each
STATEMENT
element that does not include a
NON-IDENTIFIABLE
element MUST contain a
RECIPIENT
element that contains one or more recipients of the collected data. Sites MUST
classify their recipients into one or more of the six recipients
specified.

the legal entity, or domain, beyond the service provider and its
agents where data may be distributed.
The
RECIPIENT
element MUST contain one or more of the
following:

Ourselves and/or entities acting as our agents or entities for
whom we are acting as an agent
: An agent in this instance is
defined as a third party that processes data only on behalf of the
service provider for the completion of the stated purposes. (e.g., the
service provider and its printing bureau which prints address labels and
does nothing further with the information.)

Delivery services possibly following different
practices
: Legal entities
performing delivery services
that may use data for purposes other than completion of the stated
purpose. This should also be used for delivery services whose data
practices are unknown.

Legal entities following our practices
: Legal
entities who use the data on their own behalf under equable practices.
(e.g., consider a service provider that grants the user access to
collected personal information, and also provides it to a partner who
uses it once but discards it. Since the recipient, who has otherwise
similar practices, cannot grant the user access to information that it
discarded, they are considered to have equable practices.)

Legal entities following different practices
: Legal
entities that are constrained by and accountable to the original service
provider, but may use the data in a way not specified in the service
provider's practices (e.g., the service provider collects data that is
shared with a partner who may use it for other purposes. However, it is
in the service provider's interest to ensure that the data is not used
in a way that would be considered abusive to the users' and its own
interests.)

Unrelated third parties
: Legal entities whose data
usage practices are not known by the original service provider.

Public fora
: Public fora such as bulletin boards,
public directories, or commercial CD-ROM directories.
Each of the above tags can optionally contain:
one or more
recipient-description
tags, containing a
description of the recipient;
with the exception of

, a
required
attribute: this attribute is defined
exactly as the analogous attribute in the
PURPOSE
tag,
indicating whether opt-in/opt-out of sharing is available (and, its
default value is
always
).
[40]
recipient
""
*extension
1*recipientvalue
*extension
"
"
[41]
recipientvalue
"" *recdescr
"
| ; only ourselves and our agents
"" *recdescr
"
" | ; legal entities following our practices
"" *recdescr
"" | ; legal entities following different practices
"" *recdescr
"
" | ; delivery services following different practices
"" *recdescr
"" | ; public fora
"" *recdescr
"" ; unrelated third parties
[42]
recdescr
""
PCDATA ; description of the recipient
"
"
Service providers MUST disclose
all the recipients that apply
. P3P
makes no distinctions about how that data is released to the recipient; it
simply requires that if data is released, then that sharing must be disclosed
in the P3P policy. Examples of disclosing data which MUST be covered by a P3P
statement include:
Transmitting customer data as part of an order-fulfillment or billing
process
Leasing or selling mailing lists
Placing personal information in URIs when redirecting requests to a
third party
Placing personal information in URIs which link to a third party
Note that in some cases the above set of recipients may not completely
describe all the recipients of data. For example, the issue of transaction
facilitators, such as shipping or payment processors, who are necessary for
the completion and support of the activity but may follow different practices
was problematic. Currently, only delivery services can be explicitly
represented in a policy. Other such transaction facilitators should be
represented in whichever category most accurately reflects their practices
with respect to the original service provider.
A special element for delivery services is included, but not one for
payment processors (such as banks or credit card companies) for the following
reasons: Financial institutions will typically have separate agreements with
their customers regarding the use of their financial data, while delivery
recipients typically do not have an opportunity to review a delivery service's
privacy policy.
Note that the

element SHOULD NOT be used for
delivery services that agree to use data only on behalf of the service
provider for completion of the delivery.
3.3.6
The
RETENTION
element
Each
STATEMENT
element that does not include a
NON-IDENTIFIABLE
element MUST contain a
RETENTION
element that indicates the kind of retention policy that applies to the data
referenced in that statement.

the type of retention policy in effect
The
RETENTION
element MUST contain one of the following:

Information is not retained for more than a brief period of time
necessary to make use of it during the course of a single online
interaction. Information MUST be destroyed following this interaction
and MUST NOT be logged, archived, or otherwise stored. This type of
retention policy would apply, for example, to services that keep no Web
server logs, set cookies only for use during a single session, or
collect information to perform a search but do not keep logs of searches
performed.

For the stated purpose: Information is retained to meet the stated
purpose. This requires information to be discarded at the earliest time
possible. Sites MUST have a retention policy that establishes a
destruction time table. The retention policy MUST be included in or
linked from the site's human-readable privacy policy.

As required by law or liability under applicable law: Information is
retained to meet a stated purpose, but the retention period is longer
because of a legal requirement or liability. For example, a law may
allow consumers to dispute transactions for a certain time period;
therefore a business may for liability reasons decide to maintain
records of transactions, or a law may affirmatively require a certain
business to maintain records for auditing or other soundness purposes.
Sites MUST have a retention policy that establishes a destruction time
table. The retention policy MUST be included in or linked from the
site's human-readable privacy policy.

Determined by service provider's business practice: Information is
retained under a service provider's stated business practices. Sites
MUST have a retention policy that establishes a destruction time table.
The retention policy MUST be included in or linked from the site's
human-readable privacy policy.

Indefinitely: Information is retained for an indeterminate period of
time. The absence of a retention policy would be reflected under this
option. Where the recipient is a public fora, this is the appropriate
retention policy.
[43]
retention
""
*extension
retentionvalue
*extension
"
"
[44]
retentionvalue
"" | ; not retained
"" | ; for the stated purpose
"" | ; stated purpose by law
"" | ; indeterminate period of time
"" ; by business practices
3.3.7 The
DATA-GROUP
and
DATA
elements
Each
STATEMENT
element that does not include a
NON-IDENTIFIABLE
element MUST contain at least one
DATA-GROUP
element that contains one or more
DATA
elements.
DATA
elements are used to describe the type of data
that a site collects.

describes the data to be transferred or inferred
base
base URI
([
URI
]) for URI references
present in
ref
attributes. When this attribute is omitted,
the default value is the URI of the P3P base data schema (
).
When the attribute appears as an empty string (""), the base is the
local document.

describes the data to be transferred or inferred
ref
mandatory attribute)
URI reference
([
URI
]), where the fragment
identifier part denotes the
name of a data element/set
, and the
URI part denotes the corresponding
data schema
. In case the URI
part is not present, if the
DATA
element is contained
within a
DATA-GROUP
element, then the default base URI is
assumed to be the URI of the
base
attribute. In the other
cases, as usual, the default base URI is a same-document reference ([
URI
]).
Remember that
names of data elements and sets are
case-sensitive
(so, for example,
user.gender
is different from
USER.GENDER
or
User.Gender
).
optional
indicates whether or not the site requires visitors to submit this
data element to access a resource or complete a transaction; "no"
indicates that the data element is not optional (it is required), while
"yes" indicates that the data element is optional.
The default is
"no."
The
optional
attribute is used only in policies
(not in data schema definitions).
Note that user agents should be cautious about using the
optional
attribute in automated decision-making. If the
optional
attribute is associated with a data element directly
controlled by the user agent (such as the HTTP
Referer
header or
cookies), the user agent should make sure that this data is not transmitted to
Web sites at which a data element is optional if the site's policy would not
match a user's preferences if the data element was required. Likewise, for
data elements that users typically type into forms, user agents should alert
users when a site's practices about optional data do not match their
preferences.
DATA
elements can contain the actual data (as already sen in
the case of the
ENTITY
element), and can contain related
category
information.
[45]
data-group
"[" base=" quoted-URI]
">"
*extension
1*dataref
*extension
"
"
[46]
dataref
`[" optional=" `"` ("yes"|"no") `"`] ">"
[categories] ; the
categories
of the data element.
[PCDATA] ; the eventual value of the data element
""
Here,
URI-reference
is defined
as in [
URI
].
For example, to reference the user's home address city, all the elements of
the data set
user.business-info
and (optionally) all the elements
of the data set
user.home-info.telecom
, the service would send
the following references inside a P3P policy:





When the actual value of the data is known, it can be expressed inside the
DATA
element. For example, as seen in the
example policies


CatalogExample
4000 Lincoln Ave.
...
3.4 Categories and the
CATEGORIES
element
Categories are elements inside data elements that provide hints to users
and user agents as to the intended uses of the data. Categories are vital to
making P3P user agents easier to implement and use. Note that
categories
are not data elements
: they just allow users to express more generalized
preferences and rules over the exchange of their data. Categories SHOULD NOT
be used within the
DATA
elements of an
ENTITY
element.
The following elements are used to denote data categories:
[47]
categories
"" 1*category ""
[48]
category
"" | ; Physical Contact Information
"" | ; Online Contact Information
"" | ; Unique Identifiers
"" | ; Purchase Information
"" | ; Financial Information
"" | ; Computer Information
"" | ; Navigation and Click-stream Data
"" | ; Interactive Data
"" | ; Demographic and Socioeconomic Data
"" | ; Content
"" | ; State Management Mechanisms
"" | ; Political Information
"" | ; Health Information
"" | ; Preference Data
"" | ; Location Data
" | ; Government-issued Identifiers
"" PCDATA "" ; Other

Physical Contact Information
: Information that allows
an individual to be contacted or located in the physical world -- such
as telephone number or address.

Online Contact Information
: Information that allows
an individual to be contacted or located on the Internet -- such as
email. Often, this information is independent of the specific computer
used to access the network. (See the category "Computer
Information")

Unique Identifiers
: Non-financial identifiers,
excluding government-issued identifiers, issued for purposes of
consistently identifying or recognizing the individual. These include
identifiers issued by a Web site or service.

Purchase Information
: Information actively generated
by the purchase of a product or service, including information about the
method of payment.

Financial Information
: Information about an
individual's finances including account status and activity information
such as account balance, payment or overdraft history, and information
about an individual's purchase or use of financial instruments including
credit or debit card information. Information about a discrete purchase
by an individual, as described in "Purchase Information," alone does not
come under the definition of "Financial Information."

Computer Information
: Information about the computer
system that the individual is using to access the network -- such as the
IP number, domain name, browser type or operating system.

Navigation and Click-stream Data
: Data
passively
generated by
browsing
the Web site -- such
as which pages are visited, and how long users stay on each page.

Interactive Data
: Data
actively
generated
from or reflecting
explicit interactions
with a service
provider through its site -- such as queries to a search engine, or logs
of account activity.

Demographic and Socioeconomic Data
: Data about an
individual's characteristics -- such as gender, age, and income.

Content
: The words and expressions contained in the
body of a communication -- such as the text of email, bulletin board
postings, or chat room communications.

State Management Mechanisms
: Mechanisms for
maintaining a stateful session with a user or automatically recognizing
users who have visited a particular site or accessed particular content
previously -- such as HTTP cookies.

Political Information
: Membership in or affiliation
with groups such as religious organizations, trade unions, professional
associations, political parties, etc.

Health Information
: information about an individual's
physical or mental health, sexual orientation, use or inquiry into
health care services or products, and purchase of health care services
or products.

Preference Data
: Data about an individual's likes and
dislikes -- such as favorite color or musical tastes.

Location Data
: Information that can be used to
identify an individual's current physical location and track them as
their location changes -- such as GPS position data.

Government-issued Identifiers
: Identifiers issued by
a government for purposes of consistently identifying the
individual.

string

Other
: Other types of data not captured by the above
definitions. (A human readable explanation should be provided in these
instances, between the

and the

tags.)
The
Computer
Interactive
and
Content
categories can be
distinguished as follows. The Computer category includes information about the
user's computer including IP address and software configuration. Navigation
data describes actual user behavior related to browsing. When an IP address is
stored in a log file with information related to browsing activity, both the
Computer category and the Navigation category should be used. Interactive Data
is data actively solicited to provide some useful service at a site beyond
browsing. Content is information exchanged on a site for the purposes of
communication.
The
Other
category should be used only when data is
requested that does not fit into any other category.
P3P uses categories to give users and user agents additional hints as to
what type of information is requested from a service. While most data in the
base data schema is in a known category (or a set of known categories), some
data elements can be in a number of different categories, depending on the
situation. The former are called
fixed-category data elements
(or
"fixed data elements" for short), the latter
variable-category data
elements
("variable data elements"). Both types of elements are described
in
Section 5.7
3.5 Extension Mechanism: the
EXTENSION
element
P3P provides a flexible and powerful mechanism to extend its syntax and
semantics using one element:
EXTENSION
. This element is used to
indicate portions of the policy/policy reference file/data schema which belong
to an extension. The meaning of the data within the
EXTENSION
element is defined by the extension itself.

describes an extension to the syntax
optional
This attribute determines if the extension is
mandatory
or
optional
. A
mandatory
extension is indicated by giving
the
optional
attribute a value of
no
. A
mandatory
extension to the P3P syntax means that applications
that do not understand this extension cannot understand the meaning of
the whole policy (or policy reference file, or data schema) containing
it. An
optional
extension, indicated by giving the optional
attribute a value of
yes
, means that applications that do
not understand this extension can safely ignore the contents of the
EXTENSION
element, and proceed to process the whole policy
(or policy reference file, or data schema) as usual. The
optional
attribute is not required; its default value is
yes
[49]
extension
"" PCDATA "
"
For example, if www.catalog.example.com would like to add to P3P a feature
to indicate that a certain set of data elements were only to be collected from
users living in the United States, Canada, or Mexico, it could add a mandatory
extension like this:

...






On the other hand, if www.catalog.example.com would like to add an
extension stating what country the server is in, an optional extension might
be more appropriate, such as the following:




...

The
xmlns
attribute is significant since it specifies the
namespace for interpreting the names of elements and attributes used in the
extension. Note that, as specified in [
XML-Name
], the
namespace URI is just intended to be a unique identifier for the XML entities
used by the extension. Nevertheless, service providers MAY provide a page with
a description of the extension at the corresponding URI.
The
EXTENSION
element can appear in various places within P3P
syntax: such positions are normatively specified by the XML Schema present in
Appendix 4
(and, informally specified by the
ABNF syntax, and by the DTD present in
Appendix 5
)..
3.6 User Preferences
User agents MUST document a method by which preferences can be imported and
processed, and SHOULD document a method by which preferences can be
exported.
P3P user agents MUST act according to the preference settings selected by
the user. This requires that they be able to process policy and policy
reference files as appropriate to evaluate each policy with respect to a
user's preferences or other criteria specified by the settings. Depending on
these settings, this may require, for example, that the user agent verify that
required parts of the P3P policy are present, or check that the syntax of the
entire policy is valid.
4. Compact Policies
Compact policies are summarized P3P policies that provide hints to user
agents to enable the user agent to make quick, synchronous decisions about
applying policy. Compact policies are a performance optimization that is
OPTIONAL
for either user agents or servers. User agents that
are unable to obtain enough information from a compact policy to make a
decision according to a user's preferences SHOULD fetch the full policy.
In P3P, compact policies contain policy information related to cookies (cf.
] and [
STATE
])
only. The Web server is responsible for building a P3P compact policy to
represent the cookies referenced in a full policy. The policy specified in a
P3P compact policy applies to data stored within all cookies set in the same
HTTP response as the compact policy, all cookies set by scripts associated
with that HTTP response, and also to data linked to the cookies.
4.1 Referencing compact
policies
Any HTTP resource MAY include a P3P compact policy through the P3P response
header (cf.
Section 2.2.2
). If a site is using P3P
headers, it SHOULD include this on responses for all appropriate request
methods, including
HEAD
and
OPTION
requests.
The P3P compact policy header has a quoted string that may contain one or
more delimited tokens (the "compact policy"). Tokens can appear in any order,
and the space character (" ") is the only valid delimiter. The syntax for this
header is as follows:
[50]
compact-policy-field
`CP="` compact-policy `"`
[51]
compact-policy
compact-token *(" " compact-token)
[52]
compact-token
compact-access |
compact-disputes |
compact-remedies |
compact-non-identifiable |
compact-purpose |
compact-recipient |
compact-retention |
compact-categories |
compact-test
As for all HTTP headers, the name of the P3P header field is
case-insensitive. The field-value (i.e., the content of the header) is instead
case sensitive.
If an HTTP response includes more than one compact policy, P3P user agents
MUST ignore all compact policies after the first one.
4.2 Compact Policy Vocabulary
P3P compact policies use tokens representing the following elements from
the P3P vocabulary:
ACCESS
CATEGORIES
DISPUTES
NON-INDENTIFIABLE
PURPOSE
RECIPIENT
REMEDIES
RETENTION
TEST
If a token appears more than once in a single compact policy, the compact
policy has
the same semantics
as if that token appeared only once. If
an unrecognized token appears in a compact policy, the compact policy has
the same semantics
as if that token was not present.
The P3P compact policy vocabulary is expressed using a developer-readable
language to reduce the number of bytes transferred over the wire within a HTTP
response header. The syntax of the tokens follows:
4.2.1 Compact
ACCESS
Information in the
ACCESS
element is represented in compact
policies using tokens composed by a three letter code:
[53]
compact-access
"NOI" | ; for
"ALL" | ; for
"CAO" | ; for
"IDC" | ; for
"OTI" | ; for
"NON" ; for
4.2.2 Compact
DISPUTES
If a full P3P policy contains a
DISPUTES-GROUP
element that
contains one or more
DISPUTES
elements, then the server should
signal the user agent by providing a
single
DSP
" token in the P3P-compact policy field:
[54]
compact-disputes
"DSP" ; there are some DISPUTES
4.2.3 Compact
REMEDIES
Information in the
REMEDIES
element is represented in compact
policies as follows:
[55]
compact-remedies
"COR" | ; for
"MON" | ; for
"LAW" ; for
4.2.4 Compact
NON-IDENTIFIABLE
The presence of the
NON-IDENTIFIABLE
element in every
statement of the policy is signaled by the
NID
token (note that
the
NID
token MUST NOT be used unless the
NON-IDENTIFIABLE
element is present in every statement within the
policy):
[56]
compact-non-identifiable
"NID" ; for
4.2.5 Compact
PURPOSE
Purposes are expressed in P3P compact policy format using tokens composed
by a three letter code plus an optional one letter attribute. Such an optional
attribute encodes the value of the "
required
" attribute in full
P3P policies: its value can be "
", "
" and
", which mean that the "
required
" attribute in the
corresponding P3P policy must be set to "
always
",
opt-in
" and "
opt-out
" respectively.
If a P3P compact policy needs to specify one or more other-purposes in its
full P3P policy, a single
OTP
flag is used to signal the user
agent that other-purposes exist in the full P3P policy.
The corresponding associations among P3P purposes and compact policy codes
follow:
[57]
compact-purpose
"CUR" | ; for
"ADM" [creq] | ; for
"DEV" [creq] | ; for
"TAI" [creq] | ; for
"PSA" [creq] | ; for
"PSD" [creq] | ; for
"IVA" [creq] | ; for
"IVD" [creq] | ; for
"CON" [creq] | ; for
"HIS" [creq] | ; for
"TEL" [creq] | ; for
"OTP" [creq] ; for
[58]
creq
"a"| ;"always"
"i"| ;"opt-in"
"o" ;"opt-out"
4.2.6 Compact
RECIPIENT
Recipients are expressed in P3P compact policy format using a three letter
code plus an optional one letter attribute. Such an optional attribute encodes
the value of the "
required
" attribute in full P3P policies: its
value can be "
", "
" and "
", which
mean that the "
required
" attribute in the corresponding P3P
policy must be set to "
always
", "
opt-in
" and
opt-out
" respectively.
The corresponding associations among P3P recipients and compact policy
codes follow:
[59]
compact-recipient
"OUR" | ; for
"DEL" [creq] | ; for
"SAM" [creq] | ; for
"UNR" [creq] | ; for
"PUB" [creq] | ; for
"OTR" [creq] ; for
4.2.7 Compact
RETENTION
Information in the
RETENTION
element is represented in compact
policies as follows:
[60]
compact-retention
"NOR" | ; for
"STP" | ; for
"LEG" | ; for
"BUS" | ; for
"IND" ; for
4.2.8 Compact
CATEGORIES
Categories are represented in compact policies as follows:
[61]
compact-categories
"PHY" | ; for
"ONL" | ; for
"UNI" | ; for
"PUR" | ; for
"FIN" | ; for
"COM" | ; for
"NAV" | ; for
"INT" | ; for
"DEM" | ; for
"CNT" | ; for
"STA" | ; for
"POL" | ; for
"HEA" | ; for
"PRE" | ; for
"LOC" | ; for
"GOV" | ; for
"OTC" ; for
Note that if a P3P policy specifies one or more
other-category
in its full P3P policy, a
single
OTC
token is
used to signal the user agent that
other-category
's exist in the
full P3P policy.
4.2.9 Compact
TEST
The presence of the
TEST
element is signaled by the
TST
token:
[62]
compact-test
"TST" ; for
4.3 Compact Policy Scope
When a P3P compact policy is included in a HTTP response header, it applies
to cookies set by the current response. This includes cookies set through the
use of a HTTP
SET-COOKIE
header or cookies set by script.
4.4 Compact Policy Lifetime
To use compact policies, the validity of the full P3P policy must span the
lifetime of the cookie. There is no method to indicate that policy is valid
beyond the life of the cookie because the value of user agent caching is
marginal, since sites would not know when to optimize by not sending the
compact policy. When a server sends a compact policy, it is asserting that the
compact policy and corresponding full P3P policy will be in effect for at
least the lifetime of the cookie to which it applies.
4.5 Transforming a P3P Policy to a Compact
Policy
When using P3P compact policies, the Web site is responsible for building a
compact policy by summarizing the policy referenced by the
COOKIE-INCLUDE
elements of a P3P policy reference file. If a
site's policy reference file uses
COOKIE-EXCLUDE
elements then
the site will need to manage sending the correct P3P compact policies to the
user agent given the cookies set in a specific response.
The transformation of a P3P policy to a P3P compact policy may result in a
loss of descriptive policy information -- the compact policy may not contain
all of the policy information specified in the full P3P policy. The
information from the full policy that is discarded when building a compact
policy includes expiry, data group/data-schema elements, entity elements,
consequences elements, and disputes elements are reduced.
Full policies that include mandatory extensions MUST NOT be represented as
compact policies.
All of the purposes, recipients, and categories that appear in multiple
statements in a full policy MUST be aggregated in a compact policy, as
described in section 3.3.1. When performing the aggregation, a Web site MUST
disclose all relevant tokens (for instance, observe Example 4.1, where
multiple retention policies are specified.)
In addition, for each fixed category data element appearing in a statement
the associated category as defined in the associated schema MUST be included
in the compact policy.
Example 4.1:
Consider the following P3P policy:
discuri="http://www.example.com/cookiepolicy.html"
opturi="http://www.example.com/opt.html">


Example, Corp.
privacy@example.com




service="http://www.example.com/privacy.html"
short-description="Please contact our customer service desk with
privacy concerns by emailing privacy@example.com"/>























The corresponding compact policy is:
"NON DSP ADM DEV PSD IVDo OUR IND STP PHY PRE NAV UNI"
4.6 Transforming a Compact Policy to a P3P
Policy
Some user agents may attempt to generate a full P3P policy from a compact
policy, for use in evaluating user preferences. They will not be able to
provide values for the
ENTITY
and
DISPUTES
elements
as well as a number of the attributes. However:
In case there
are not
multiple different values of compact
retention,
they should be able to generate a policy with an appropriate
ACCESS
element, and: a single
STATEMENT
element that contains the appropriate
RECIPIENT
RETENTION
, and
PURPOSE
elements, as well as a
dynamic.miscdata
element with
the appropriate
CATEGORIES
In case there
are
multiple different values of compact
retention,
they should be able to generate a policy with an appropriate
ACCESS
element, and: multiple
STATEMENT
elements (as many as the different values of the compact retention) that
contain a different corresponding value for the
RETENTION
element, the appropriate
RECIPIENT
, and
PURPOSE
elements, as well as a
dynamic.miscdata
element with the
appropriate
CATEGORIES
Note that, in agreement with the non ambiguity requirements stated in
Section 2.4.1
, a site MUST honor a compact policy
for a given URI in any case (even when the full policy referenced in the
policy reference file for that URI does not correspond, as per
Section 4.5
, to the compact policy itself).
5. Data Schemas
data schema
is a description of a set of data. P3P includes a way
to describe data schemas so that services can communicate to user agents about
the data they collect. A data schema is built from a number of
data
elements
, which are specific items of data a service might collect.
Data elements in a data schema can have the following properties:
Data element name. The name of the data element is used when a P3P
policy includes this data element in a

element.
This is required on all data elements.
Descriptive name or short name. A data element's short name provides a
short, human-understandable name for the data element. The short name is
not required, but it is strongly recommended.
Long description. The long description of a data element provides a more
detailed, human-understandable definition of the data element. Like the
short name, the long description is not required, but it is strongly
recommended.
Category or categories. Most data elements have categories assigned to
them when they are defined in a data schema. See
Categories
for more information on categories.
Data elements are organized into a hierarchy. A data element automatically
includes all of the data elements below it in the hierarchy. For example, the
data element representing "the user's name" includes the data elements
representing "the user's given name", "the user's family name", and so on. The
hierarchy is based on the data element name. Thus the data elements
user.name.given, user.name.family,
and
user.name.nickname
are all children of the data element
user.name
, which is in turn a child of the data element
user
P3P has defined a data schema called the
P3P
base data schema
that includes a large number of data elements
commonly used by services.
Services may declare new data elements by creating and publishing their own
data schemas, which are created using the

element. Data schemas can either be published in standalone XML files (whose
root element is then
DATASCHEMA
), or they can be embedded in a
policy file (even the same policy file with policies referencing the data
schema itself).
The

element is defined as follows:
[63]
dataschema
""
*(datadef|datastruct|extension)
"
"
A standalone data schema has the

element as
the root element in the XML file. It must have the appropriate namespace
defined in the
xmlns
attribute to identify it as a P3P data
schema, as follows:


...


Optionally,
DATASCHEMA
can contain an
xml:lang
attribute (see
section 2.4.2
),
When a data schema is declared inside a policy file, then the

element is still used (as described in
Section 3.2.1
, "The

element").
5.1 Natural Language Support for Data
Schemas
Data schemas contain a number of fields in natural language. Services
publishing a data schema MAY wish to translate these fields into multiple
languages. The data element short and long names MAY be translated, but the
data element name MUST NOT be translated - this field needs to stay constant
across translations of a data schema.
If a service is going to provide a data schema in multiple natural
languages, then it SHOULD examine the
Accept-Language
HTTP
request-header on requests for that data schema to pick the best available
alternative.
5.2 Data Structures
Data schemas often need to reuse a common group of data elements. P3P data
schemas support this through data structures. A data structure is a named,
abstract definition of a group of data elements. When a data element is
defined, it can be defined as being of an unstructured type, in which case it
has no child elements. The data element can also be defined as being of a
specific structured type, in which case the data element will be automatically
expanded to include as sub-elements all of the elements defined in the data
structure. For example, the following structure is used to represent a date
and time:

short-description="Year"/>

short-description="Month"/>

short-description="Day"/>

short-description="Hour"/>

short-description="Minute"/>

short-description="Second"/>
Now we shall define a "meeting" data element, which has a time and place
for the meeting:
short-description="Meeting time"
structref="#date"/>
short-description="Meeting place/>
Since
meeting.place
does not reference a structure, it is of
an unstructured type, and has no child elements. The
meeting.time
element uses the
date
structure. By declaring this, the following
sub-elements are created:
meeting.time.ymd.year
meeting.time.ymd.month
meeting.time.ymd.day
meeting.time.hms.hour
meeting.time.hms.minute
meeting.time.hms.second
A P3P policy can now declare that it collects the
meeting
data
element, which implies that it collects all of the sub-elements of
meeting
, or it can use data elements lower down the hierarchy -
meeting.time
, for example, or
meeting.time.ymd.day
5.3 The
DATA-DEF
and
DATA-STRUCT
elements

and

Define a data element or a data structure, respectively. Data
structures are reusable structured type definitions that can be used to
build data elements. Data elements are declared within a

in a P3P policy to describe data covered
by that statement.
The following attributes are common to these two elements:
name
mandatory attribute)
Indicates the name of the data element or data structure. Remember
that names of data element and data structures are
case-sensitive
, so, for example,
user.gender
is different from
USER.GENDER
or
User.Gender
. Furthermore, in names of data elements and
structures no number character can appear immediately following a
dot.
structref
URI reference
([
URI
]), where the fragment
identifier part denotes the
structure
, and the URI part denotes
the corresponding
data schema
where it is defined. The default
base URI is a same-document reference ([
URI
]). Data elements or data
structures without a
structref
attribute (and, so, without
an associated structure) are called
unstructured
short-description
a string denoting the short display name of the data element or
structure, no more than 255
characters
The
DATA-DEF
and
DATA-STRUCT
elements can also
contain a long description of the data element or structure, using the
LONG-DESCRIPTION
element.
[64]
datadef
"[" short-description=" quotedstring]
">"
[categories] ; the
categories
of the data element.
[longdescription] ; the long description of the data element
"
"
[65]
datastruct
"[" short-description=" quotedstring]
">"
[categories] ; the
categories
of the Data Structure.
[longdescription] ; the long description of the Data Structure
"
"
Here,
URI-reference
is defined
as in [
URI
].
Data elements can be structured, much like in common programming languages:
structures are hierarchical (tree-like) descriptions of data elements: this
hierarchical description is performed in the
name
attribute using
a dot ("
") character as separator.
P3P provides the
P3P base data
schema
, which has built-in definitions of a number of widely
used structures and data elements. All P3P implementations are required to
understand the P3P base data schema, so the structures and elements it defines
are always available to P3P implementers.
A data schema may include multiple
DATA-STRUCT
elements that
together describe a structure. For example, there is no single
DATA-STRUCT
for the
uri
data structure (cf.
section 5.5.7.1
) in the P3P base data schema.
Instead
uri.authority
uri.stem
, and
uri.querystring
are interpreted together to define this
structure.
5.3.1 Categories in P3P Data
Schemas
Categories can be assigned to data structures or data elements. The
following rules define how those category definitions are meant to be
used:

elements MAY include category
definitions. If a structure definition includes categories, then all uses
of those structures in data definitions and data structures pick up those
categories. If a structure contains no categories, then the categories for
that structure MAY be defined when it is used in another structure or data
element. Otherwise, a data element using this structure is a
variable-category element. Any uses of a variable-category data element in
a policy require that its categories be listed in the policy.

with an unstructured type is a
variable-category data element if no categories are defined in the

, and has exactly those categories listed in
the

if any categories are included.

or

with
a structured type which has no categories defined on that structure
produces a variable-category data element/structure if no categories are
defined in the

or

. If the

or

does have categories listed, then those
categories are applied to that data element, and all of its sub-elements.
In other words, categories are pushed down into sub-elements when defining
a data element to be of a structured type, and the structured type does
not define any categories.

using a structured type which has
categories defined on that structure picks up all the categories listed on
the structure. In addition, categories may be listed in the

, and these are added to the categories
defined in the structure. These categories are defined only at the level
of that data element, and are not "pushed down" to any sub-elements.

that has no categories assigned to
it, and which is using a structured subtype which has categories defined
on the subtype picks up all the categories listed on the subtype.

that has categories assigned to it,
and which is using a structured subtype replaces all of the categories
listed on the subtype.
There is a "bubble-up" rule for categories when referencing data
elements: data elements, must at a minimum, include all categories defined
by any of its children. This rule applies recursively, so for example, all
categories defined by data elements
foo.a.w
foo.a.y
, and
foo.b.z
MUST be considered to apply
to data element
foo

cannot be defined with some
variable-category elements and some fixed-category elements. Either all of
the sub-elements of a structure must be in the variable category, or else
all of them must have one or more assigned categories.

with some variable-category elements and
some fixed-category elements MUST NOT be referenced. Note, this means that
the
dynamic
structure (cf. section 5.6.4 "
Dynamic Data
"), existing in the basedata schema,
cannot be referenced in a policy (each of its sub-elements
dynamic.clickstream
dynamic.http
, etc. can be
referenced individually).
5.3.2 P3P Data Schema Example
Consider the case where the company HyperSpeedExample wishes to describe
the features of a vehicle, using a structure called
vehicle
. This
structure includes:
The vehicle's model type (
vehicle.model
),
The vehicle's color (
vehicle.color
),
The vehicle's year of manufacture (
vehicle.built.year
),
and
The vehicle's price (
vehicle.price
).
If HyperSpeedExample also wants to include in the definition of a vehicle
the location of manufacture, it could add other fields to the structure with
all the relevant data like country, street address, postal code, and so on.
But, each part of a structure can use other structures as well:
structures
can be composed
. In this case, the
P3P base data
schema
already provides a structure
postal
describing all the postal information of a location. So, the final definition
of the structure vehicle is
vehicle.model
(unstructured)
vehicle.color
(unstructured)
vehicle.price
(unstructured)
vehicle.built.year
(unstructured)
vehicle.built.where
(with structure
postal
from the base data schema)
The structure
postal
has fields
postal.street
postal.city
, and so on. Since we have applied the structure
postal
to
vehicle.built.where
, it means that we can
access the street and city of a vehicle using the descriptions
vehicle.built.where.street
and
vehicle.built.where.city
respectively. So, by applying a
structure (in this case,
postal
) we can build very complex
descriptions in a modular way.
HyperSpeedExample wants to declare that all of the vehicle information will
be in the

category. The
vehicle.model,
vehicle.color, vehicle.price,
and
vehicle.built.year
fields are all unstructured types, so assigning them to the

category accomplishes this for those fields.
Since vehicle is a structure definition, assigning the

category to
vehicle.built.where
will override (replace) the categories defined on all of the sub-elements of
vehicle.built.where
, placing all of them in the

category, even though the
postal
structure was originally defined as being in other categories.
As said, structures do not contain data elements; they are just abstract
data types. We can use them to rapidly build structured collections of data
elements. Going on with the example, HyperSpeedExample needs this abstract
description of the features of a vehicle because it wants to actually exchange
data about cars and motorcycles. So, it could define two data elements called
car
and
motorcycle
, both with the above structure
vehicle
This description of the data elements and data structures is encoded in XML
using a data schema. In the HyperSpeedExample case, it would be something
like:

short-description="Model">


short-description="Color">


short-description="Construction Year">


structref="http://www.w3.org/TR/P3P/base#postal"
short-description="Construction Place">





Continuing with the example, in order to reference a car model and
construction year, HyperSpeedExample
or any other service
could send
the following references inside a P3P policy:





Using the
base
attribute, the
above references can be written in an even more compact way:




Alternatively, the data schema could be
embedded
directly into a
policy file. In this case, the policy file could look like:



short-description="Model">


short-description="Color">


short-description="Construction Year"">


structref="http://www.w3.org/TR/P3P/base#postal"
short-description="Construction Place">







...




...

....
....

Note that in any case there MUST NOT be more than one data schema per
file.
5.3.3 Use of data element names
Note that the data element names specified in the base data schema or in
extension data schemas may be used for purposes other than P3P policies. For
example, Web sites may use these names to label HTML form fields. By referring
to data the same way in P3P policies and forms, automated form-filling tools
can be better integrated with P3P user agents.
5.4 Persistence of data
schemas
An essential requirement on data schemas is the
persistence of
data schemas
: data schemas that can be fetched at a certain URI
can only be changed by extending the data schema in a
backward-compatible
way (that is to say, changing the data schema
does not change the meaning of any policy using that schema). This way, the
URI of a policy acts in a sense like a unique identifier for the data elements
and structures contained therein: any data schema that is not
backward-compatible
must therefore use a new different URI
Note that a useful application of the persistence of data schema is given
for example in the case of multi-lingual sites: multiple language versions
(translations) of the same data schema can be offered by the server, using the
HTTP "
Content-Language
" response header field to properly
indicate that a particular language has been used for the data schema.
5.5
Basic Data Structures
The Basic Data Structures are structures used by the P3P base data schema
(and possibly, due to their basic nature, they should be reused as much as
possible by other different data schemas). All P3P-compliant user agent
implementations MUST be aware of the Basic Data Structures. Each table below
specifies the elements of a basic data structure, the categories associated,
their structures, and the display names shown to users. More than one category
may be associated with a fixed data element. However, each base data element
is assigned to only one category whenever possible. Data schema designers are
recommended to do the same.
5.5.1
Dates
The
date
structure specifies a date. Since date
information can be used in different ways, depending on the context, all
date
information is tagged as being of "variable" category
(see
Section 5.7.2
). For example, schema definitions
can explicitly set the corresponding category in the element referencing this
data structure, where soliciting the birthday of a user might be "Demographic
and Socioeconomic Data", while the expiration date of a credit card might
belong to the "Purchase Information" category.
date
Category
Structure
Short display name
ymd.year
variable-category
unstructured
Year
ymd.month
variable-category
unstructured
Month
ymd.day
variable-category
unstructured
Day
hms.hour
variable-category
unstructured
Hour
hms.minute
variable-category
unstructured
Minute
hms.second
variable-category
unstructured
Second
fractionsecond
variable-category
unstructured
Fraction of Second
timezone
variable-category
unstructured
Time Zone
The "time zone" information is for example described in the time standard
ISO8601
]. Note that "date.ymd" and "date.hms" can be
used to fast reference the year/month/day and hour/minute/second blocks
respectively.
5.5.2
Names
The
personname
structure specifies information about the
naming of a person.
personname
Category
Structure
Short display name
prefix
Demographic and Socioeconomic Data
unstructured
Name Prefix
given
Physical Contact Information
unstructured
Given Name (First Name)
family
Physical Contact Information
unstructured
Family Name (Last Name)
middle
Physical Contact Information
unstructured
Middle Name
suffix
Demographic and Socioeconomic Data
unstructured
Name Suffix
nickname
Demographic and Socioeconomic Data
unstructured
Nickname
5.5.3
Logins
The
structure specify information (IDs and
passwords) for computer systems and Web sites which require authentication.
Note that this data element should not be used for computer systems or Web
sites which use digital certificates for authentication: in those cases, the
certificate
structure should be used.
Category
Structure
Short display name
id
Unique Identifiers
unstructured
Login ID
password
Unique Identifiers
unstructured
Login Password
The "id" field represents the ID portion of the login information for a
computer system. Often, user IDs are made public, while passwords are kept
secret. IDs do not include any type of biometric authentication
mechanisms.
The "password" field represents the password portion of the login
information for a computer system. This is a secret data value, usually a
character string, that is used in authenticating a user. Passwords are
typically kept secret, and are generally considered to be sensitive
information
5.5.4
Certificates
The
certificate
structure is used to specify identity
certificates (like, for example, X.509).
certificate
Category
Structure
Short display name
key
Unique Identifiers
unstructured
Certificate Key
format
Unique Identifiers
unstructured
Certificate Format
The "format" field is used to represent the information of an IANA
registered public key or authentication certificate format, while the "key"
field is used to represent the corresponding certificate key.
5.5.5
Telephones
The
telephonenum
structure specifies the characteristics
of a telephone number.
telephonenum
Category
Structure
Short display name
intcode
Physical Contact Information
unstructured
International Telephone Code
loccode
Physical Contact Information
unstructured
Local Telephone Area Code
number
Physical Contact Information
unstructured
Telephone Number
ext
Physical Contact Information
unstructured
Telephone Extension
comment
Physical Contact Information
unstructured
Telephone Optional Comments
5.5.6
Contact Information
The
contact
structure is used to specify contact
information. Services can specify precisely which set of data they need,
postal, telecommunication, or online address information.
contact
Category
Structure
Short display name
postal
Physical Contact Information, Demographic and
Socioeconomic Data
postal
Postal Address Information
telecom
Physical Contact Information
telecom
Telecommunications Information
online
Online Contact Information
online
Online Address Information
5.5.6.1
Postal
The
postal
structure specifies a postal mailing
address.
postal
Category
Structure
Short display name
name
Physical Contact Information, Demographic and
Socioeconomic Data
personname
Name
street
Physical Contact Information
unstructured
Street Address
city
Demographic and Socioeconomic Data
unstructured
City
stateprov
Demographic and Socioeconomic Data
unstructured
State or Province
postalcode
Demographic and Socioeconomic Data
unstructured
Postal Code
country
Demographic and Socioeconomic Data
unstructured
Country Name
organization
Demographic and Socioeconomic Data
unstructured
Organization Name
The "country" field represents the information of the name of the country
(for example, one among the countries listed in [
ISO3166
]).
5.5.6.2
Telecommunication
The
telecom
structure specifies telecommunication
information about a person.
telecom
Category
Structure
Short display name
telephone
Physical Contact Information
telephonenum
Telephone Number
fax
Physical Contact Information
telephonenum
Fax Number
mobile
Physical Contact Information
telephonenum
Mobile Telephone Number
pager
Physical Contact Information
telephonenum
Pager Number
5.5.6.3
Online
The
online
structure specifies online information about a
person or legal entity.
online
Category
Structure
Short display name
email
Online Contact Information
unstructured
Email Address
uri
Online Contact Information
unstructured
Home Page Address
5.5.7
Access Logs and Internet
Addresses
Two structures used for representing forms of Internet addresses are
provided. The
uri
structure covers Universal Resource Identifiers
(URI), which are defined in [
URI
]. The
ipaddr
structure represents IP addresses and Domain Name System (DNS) hostnames.
5.5.7.1
URI
uri
Category
Structure
Short display name
authority
variable-category
unstructured
URI Authority
stem
variable-category
unstructured
URI Stem
querystring
variable-category
unstructured
Query-string Portion of URI
The authority of a URI is defined as the
authority
component
in [
URI
]. The stem of a URI is defined as the information
contained in the portion of the URI after the authority and up to (and
including) the first '?' character in the URI, and the querystring is the
information contained in the portion of the URI after the first '?' character.
For URIs which do not contain a '?' character, the stem is the entire URI, and
the querystring is empty.
Since URI information can be used in different ways, depending on the
context, all the fields in the
uri
structure are tagged as being
of "variable" category. Schema definitions MUST explicitly set the
corresponding category in the element referencing this data structure.
5.5.7.2
ipaddr
The
ipaddr
structure represents the hostname and IP address of
a system.
ipaddr
Category
Structure
Short display name
hostname
Computer Information
unstructured
Complete Host and Domain Name
partialhostname
Demographic
unstructured
Partial Hostname
fullip
Computer Information
unstructured
Full IP Address
partialip
Demographic
unstructured
Partial IP Address
The
hostname
element is used to represent collection of either
the simple hostname of a system, or the full hostname including domain name.
The
partialhostname
element represents the information of a
fully-qualified hostname which has had
at least
the host portion
removed from the hostname. In other words, everything up to the first '.' in
the fully-qualified hostname MUST be removed for an address to quality as a
"partial hostname".
The
fullip
element represents the information of a full IP
version 4 or IP version 6 address. The
partialip
element
represents an IP version 4 address (only - not a version 6 address) which has
had
at least
the last 7 bits of information removed. This removal
MUST be done by replacing those bits with a fixed pattern for all visitors
(for example, all 0's or all 1's).
Certain Web sites are known to make use not of the visitor's entire IP
address or hostname, but rather make use of a reduced form of that
information. By collecting only a subset of the address information, the site
visitor is given some measure of anonymity. It is certainly not the intent of
this specification to claim that these "stripped" IP addresses or hostnames
are impossible to associate with an individual user, but rather that it is
significantly more difficult to do so. Sites which perform this data reduction
MAY wish to declare this practice in order to more-accurately reflect their
practices.
5.5.7.3 Access Log Information
The
loginfo
structure is used to represent information
typically stored in Web-server access logs.
loginfo
Category
Structure
Short display name
uri
Navigation and click-stream data
uri
URI of Requested Resource
timestamp
Navigation and click-stream data
date
Request Timestamp
clientip
Computer Information, Demographic and Socioeconomic
Data
ipaddr
Client's IP Address or Hostname
other.httpmethod
Navigation and click-stream data
unstructured
HTTP Request Method
other.bytes
Navigation and click-stream data
unstructured
Data Bytes in Response
other.statuscode
Navigation and click-stream data
unstructured
Response Status Code
The resource in the HTTP request is captured by the
uri
field.
The time at which the server processes the request is represented by the
timestamp
field. Server implementations are free to define this
field as the time the request was received, the time that the server began
sending the response, the time that sending the response was complete, or some
other convenient representation of the time the request was processed. The IP
address of the client system making the request is given by the
clientip
field.
The
other
data fields represent other information commonly
stored in Web server access logs.
other.httpmethod
is the HTTP
method (such as
GET
POST
, etc) in the client's
request.
other.bytes
indicates the number of bytes in the
response-body sent by the server.
other.statuscode
is the HTTP
status code on the request, such as 200, 302, or 404 (see section 6.1.1 of [
HTTP1.1
] for details).
5.5.7.4
Other HTTP Protocol Information
The
httpinfo
structure represents information carried by the
HTTP protocol which is not covered by the
loginfo
structure.
httpinfo
Category
Structure
Short display name
referer
Navigation and click-stream data
uri
Last URI Requested by the User
useragent
Computer Information
unstructured
User Agent Information
The
useragent
field represents the information in the HTTP
User-Agent
header (which gives information about the type and
version of the user's Web browser), and/or the HTTP
accept
headers.
The
referer
field represents the information in the HTTP
Referer
header, which gives information about the previous page
visited by the user. Note that this field is misspelled in exactly the same
way as the corresponding HTTP header.
5.6
The base data schema
All P3P-compliant user agent implementations MUST be aware of the data
elements in the P3P base data schema. The P3P base data schema includes the
definition of the basic data structures, and four data element sets:
user
thirdparty
business
and
dynamic
. The
user
thirdparty
and
business
sets include elements that
users and/or businesses might provide values for, while the
dynamic
set includes elements that are dynamically generated in
the course of a user's browsing session. User agents may support a variety of
mechanisms that allow users to provide values for the elements in the
user
set and store them in a data repository, including
mechanisms that support multiple personae. Users may choose not to provide
values for these data elements.
The formal XML definition of the P3P base data schema is given in
Appendix 3
. In the following sections, the base data
elements and sets are explained one by one. In the future there will be in all
likelihood
demand for the creation of other data sets and elements.
Obvious applications include catalogue, payment, and agent/system attribute
schemas (an extensive set of system elements is provided for example in
.)
Each table below specifies a
set
, the elements within the
set, the category associated with the element, its structure, and the display
name shown to users. More than one category may be associated with a fixed
data element. However, each base data element is assigned to only one category
whenever possible. It is recommended that data schema designers do the
same.
5.6.1
User Data
The
user
data set includes general
information about the user.
user
Category
Structure
Short display name
name
Physical Contact Information, Demographic and
Socioeconomic Data
personname
User's Name
bdate
Demographic and Socioeconomic Data
date
User's Birth Date
Unique Identifiers
User's Login Information
cert
Unique Identifiers
certificate
User's Identity Certificate
gender
Demographic and Socioeconomic Data
unstructured
User's Gender (Male or Female)
employer
Demographic and Socioeconomic Data
unstructured
User's Employer
department
Demographic and Socioeconomic Data
unstructured
Department or Division of Organization where User is
Employed
jobtitle
Demographic and Socioeconomic Data
unstructured
User's Job Title
home-info
Physical Contact Information, Online Contact
Information, Demographic and Socioeconomic Data
contact
User's Home Contact Information
business-info
Physical Contact Information, Online Contact
Information, Demographic and Socioeconomic Data
contact
User's Business Contact Information
Note, that this data set includes elements that are actually sets of data
themselves. These sets are defined in the
Data
Structures
subsection of this document. The short display name for an
individual element contained within a data set is defined as the concatenation
of the short display names that have been defined for the set and the element,
separated by a separator appropriate for the language/script in question, e.g.
a comma for English. For example, the short display name for
user.home-info.postal.postalcode
could be "User's Home Contact
Information, Postal Address Information, Postal code". User agent
implementations may prefer to develop their own short display names rather
than using the concatenated names when displaying information for the
user.
5.6.2
Third Party Data
The
thirdparty
data set allows users and
businesses to provide values for a related third party. This can be useful
whenever third party information needs to be exchanged, for example when
ordering a present online that should be sent to another person, or when
providing information about one's spouse or business partner. Such information
could be stored in a user repository alongside the
user
data set.
User agents may offer to store multiple such
thirdparty
data sets
and allow users to select the appropriate values from a list when
necessary.
The
thirdparty
data set is identical with the
user
data set. See section
5.6.1 User
Data
for details.
5.6.3
Business Data
The
business
data set features a subset of
user
data relevant for describing legal entities. In P3P1.0, this
data set is primarily used for declaring the policy entity, although it should
also be applicable to business-to-business interactions.
business
Category
Structure
Short display name
name
Demographic and Socioeconomic Data
unstructured
Organization Name
department
Demographic and Socioeconomic Data
unstructured
Department or Division of Organization
cert
Unique Identifiers
certificate
Organization Identity Certificate
contact-info
Physical Contact Information, Online Contact
Information, Demographic and Socioeconomic Data
contact
Contact Information for the Organization
5.6.4
Dynamic Data
In some cases, there is a need to specify data elements that do not have
fixed values that a user might type in or store in a repository. In the P3P
base data schema, all such elements are grouped under the
dynamic
data set. Sites may refer to the types of data they collect using the dynamic
data set only, rather than enumerating all of the specific data elements.
dynamic
Category
Structure
Short display name
clickstream
Navigation and Click-stream Data, Computer
Information
loginfo
Click-stream Information
http
Navigation and Click-stream Data, Computer
Information
httpinfo
HTTP Protocol Information
clientevents
Navigation and Click-stream Data
unstructured
User's Interaction with a Resource
variable-category
unstructured
Use of HTTP Cookies
miscdata
variable-category
unstructured
Miscellaneous Non-base Data Schema Information
searchtext
Interactive Data
unstructured
Search Terms
interactionrecord
Interactive Data
unstructured
Server Stores the Transaction History
These elements are often implicit in navigation or Web interactions. They
should be used with categories to describe the type of information collected
through these methods. A brief description of each element follows.
clickstream
The
clickstream
element is expected to apply to
practically all Web sites. It represents the combination of information
typically found in Web server access logs: the IP address or hostname of
the user's computer, the URI of the resource requested, the time the
request was made, the HTTP method used in the request, the size of the
response, and the HTTP status code in the response. Web sites that
collect standard server access logs as well as sites which do URI path
analysis can use this data element to describe how that data will be
used. Web sites that collect only some of the data elements listed for
the
clickstream
element MAY choose to list those specific
elements rather than the entire
dynamic.clickstream
element. This allows sites with more limited data-collection practices
to accurately present those practices to their visitors.
http
The
http
element contains additional information
contained in the HTTP protocol. See the definition of the
httpinfo
structure for descriptions of specific elements.
Sites MAY use the
dynamic.http
field as a shorthand to
cover all the elements in the
httpinfo
structure if they
wish, or they MAY reference the specific elements in the
httpinfo
structure.
clientevents
The
clientevents
element represents data about how the
user interacts with their Web browser while interacting with a resource.
For example, an application may wish to collect information about
whether the user moved their mouse over a certain image on a page, or
whether the user ever brought up the help window in a Java applet. This
kind of information is represented by the dynamic.clientevents data
element. Much of this interaction record is represented by the events
and data defined by the Document Object Model (DOM) Level 2 Events [
DOM2-Events
]. The
clientevents
data element also covers any other data regarding the user's interaction
with their browser while the browser is displaying a resource. The
exception is events which are covered by other elements in the base data
schema. For example, requesting a page by clicking on a link is part of
the user's interaction with their browser while viewing a page, but
merely collecting the URL the user has clicked on does not require
declaring this data element;
clickstream
covers that event.
However, the DOM event
DOMFocusIn
(representing the user
moving their mouse over an object on a page) is not covered by any other
existing element, so if a site is collecting the occurrence of this
event, then it needs to state that it collects the dynamic.clientevents
element. Items covered by this data element are typically collected by
client-side scripting languages, such as JavaScript, or by client-side
applets, such as ActiveX or Java applets. Note that while the previous
discussion has been in terms of a user viewing a resource, this data
element also applies to Web applications which do not display resources
visually - for example, audio-based Web browsers.
The
element should be used whenever HTTP cookies
are set or retrieved by a site. Please note that
is
variable data element
and requires the explicit declaration
of usage categories in a policy.
miscdata
The
miscdata
element references information collected by
the service that the service does not reference using a specific data
element. Categories have to be used to better describe these data: sites
MUST reference a separate
miscdata
element in their
policies for each category of miscellaneous data they collect.
searchtext
The
searchtext
element references a specific type of
solicitation used for searching and indexing sites. For example, if the
only fields on a search engine page are search fields, the site only
needs to disclose that data element.
interactionrecord
The
interactionrecord
element should be used if the
server is keeping track of the interaction it has with the user (i.e.
information other than clickstream data, for example account
transactions, etc).
5.7 Categories and Data
Elements/Structures
5.7.1
Fixed-Category Data Elements/Structures
Most of the elements in the base data schema are so called
"fixed"
data elements: they belong to one or at most two category classes. By
assigning a category invariably to elements or structures in the base data
schema, services and users are able to refer to entire groups of elements
simply by referencing the corresponding category. For example, using [
APPEL
], the privacy preferences exchange language, users can
write rules that warn them when they visit a site that collects any data
element in a certain category.
When creating data schemas for fixed data elements, schema creators have to
explicitly enumerate the categories that these element belong to. For
example:
short-description="Street Address">


If an element or structure belongs to multiple categories, multiple
elements referencing the appropriate categories can be used. For example, the
following piece of XML can be used to declare that the data elements in
user.name have both category "physical" and "demographic":
short-description="User's Name">


Please note that the category classes of fixed data elements/structures can
not
be overridden, for example by writing rules or policies
that assign a different category to a known fixed base data element. User
agents MUST ignore such categories and instead use the original category (or
set of categories) listed in the schema definition. User agents MAY preferably
alert the user that a fixed data element is used together with a non-standard
category class.
5.7.2
Variable-Category Data
Elements/Structures
Not all data elements/structures in the base data schema belong to a
pre-determined category class. Some can contain information from a range of
categories, depending on a particular situation. Such elements/structures are
called
variable-category data elements/structures
(or "variable data
element/structure" for short). Although most variable data elements in the P3P
base data schema are combined in the
dynamic
element set,
they can appear in any data set, even mixed with
fixed-category data
elements
When creating a schema definition for such elements and/or structures,
schema authors MUST NOT list an explicit category attribute, otherwise the
element/structure becomes
fixed
. For example when specifying the
"Year"
Data Structure
, which can take various categories depending on
the situation (e.g. when used for a credit card expiration date vs. for a
birth date), the following schema definition can be used:
short-description="Year"/>
This allows new schema extensions that reference such variable-category
Data Structures
to assign a specific category to derived elements,
depending on their usage in that extension. For example, an e-commerce schema
extension could thus define a credit card expiration date as follows:
short-description="Card Expiration Date">


Under these conditions, the variable Data Structure
date
is assigned a fixed category
"Purchase Information
when being used for specifying a credit card expiration date.
Note that while user preferences can list such variable data elements
without any additional category information (effectively expressing
preferences over
any
usage of this element), services MUST always
explicitly specify the categories that apply to the usage of a variable data
element in their particular policy. This information has to appear as a
category element in the corresponding
DATA
element listed in the
policy, for example as in:

...

...

where a service declares that cookies are used to recognize the user at
this site (i.e. category
Unique Identifiers
).
If a service wants to declare a data element that is in multiple
categories, it simply declares the corresponding categories (as shown in the
above section
):

...

...

With the above declaration a service announces that it uses cookies both to
recognize the user at this site
and
for storing user preference data.
Note that for the purpose of P3P there is no difference whether this
information is stored in two separate cookies or in a single one.
Finally, note that categories can be inherited as well:
Categories
inherit downward when a field is structured, but only into fields which have
no predefined category.
Therefore, we suggest to schema authors that they
do their best to insure that all applicable categories are applied to new data
elements they create.
5.6
Using Data Elements
P3P offers Web sites a great deal of flexibility in how they describe the
types of data they collect.
Sites may describe data generally using the
dynamic.miscdata
element and the appropriate
categories.
Sites may describe data specifically using the data elements defined in
the base data schema.
Sites may describe data specifically using data elements defined in new
data schemas.
Any of these three methods may be combined within a single policy.
By using the
dynamic.miscdata
element, sites
can specify the types of data they collect without having to enumerate every
individual data element. This may be convenient for sites that collect a lot
of data or sites belonging to large organizations that want to offer a single
P3P policy covering the entire organization. However, the disadvantage of this
approach is that user agents will have to assume that the site might collect
any data element belonging to the categories referenced by the site. So, for
example, if a site's policy states that it collects
dynamic.miscdata
of the physical contact
information category, but the only physical contact information it collects is
business address, user agents will nonetheless assume that the site might also
collect telephone numbers. If the site wishes to be clear that it does not
collect telephone numbers or any other physical contact information other than
business address, than it should disclose that it collects
user.business-info.contact.postal
. Furthermore,
as user agents are developed with automatic form-filling capabilities, it is
likely that sites that enumerate the data they collect will be able to better
integrate with these tools.
By defining new data schemas, sites can precisely specify the data they
collect beyond the base data set. However, if user agents are unfamiliar with
the elements defined in these schemas, they will be able to provide only
minimal information to the user about these new elements. The information they
provide will be based on the category and display names specified for each
element.
Regardless of whether a site wishes to make general or specific data
disclosures, there are additional advantages to disclosing specific elements
from the
dynamic
data set. For example, by
disclosing
dynamic.cookies
a site can indicate
that it uses cookies and explain the purpose of this use. User agent
implementations that offer users cookie control interfaces based on this
information are encouraged. Likewise, user agents that by default do not send
the HTTP_REFERER header, might look for the
dynamic.http.referer
element in P3P policies and
send the header if it will be used for a purpose the user finds
acceptable.
6.
Appendices
Appendix 1:
References
(Normative)
ABNF
D. Crocker, P. Overel. "
Augmented BNF for Syntax
Specifications: ABNF
," RFC2234, IETF, November 1997.
Available at
CHARMODEL
M. Dürst,
et al.
(Eds.), "
Character Model for the World Wide
Web
,"
World Wide Web Consortium
Working Draft. 20 February 2002.
Latest version available at
DOM2-Events
T. Pixley (Ed.), "
Document Object Model
(DOM) Level 2 Events Specification
,"
World Wide Web Consortium
, Recommendation.
13 November 2000.
Available at
HTTP1.0
T. Berners-Lee, R. Fielding, H. Frystyk, "
Hypertext Transfer Protocol
-- HTTP/1.0
," RFC1945, IETF, May 1996.
Available at
HTTP1.1
R. Fielding, J. Gettys, J. Mogul, H. Frystyk, L. Masinter, P. Leach,
T. Berners-Lee, "
Hypertext
Transfer Protocol -- HTTP/1.1
," RFC2616, IETF, June 1999. [Updates
RFC2068
Available at
HTML
D. Raggett, A. Le Hors, and I. Jacobs (Eds.). "
HTML 4.01 Specification
World Wide Web Consortium
, Recommendation.
24 Dicember 1999.
Available at
KEY
S. Bradner. "
Key words
for use in RFCs to Indicate Requirement Levels
." RFC2119, IETF,
March 1997.
Available at
LANG
H. Alvestrand, "
Tags for
the Identification of Languages.
" RFC1766, IETF, 1995.
Available at
STATE
D. Kristol, L. Montulli, "
HTTP State Management
Mechanism
." RFC2695, IETF, October, 2000 [Obsoletes
RFC2109
Available at
URI
T. Berners-Lee, R. Fielding, and L. Masinter. "
Uniform Resource Identifiers
(URI): Generic Syntax and Semantics
." RFC2396, IETF, August 1998.
[Updates
RFC1738
Available at
UTF-8
F. Yergeau. "
UTF-8, a
transformation format of ISO 10646
." RFC2279, IETF, January
1998.
Available at
XHTML-MOD
M. Altheim,
et al.
(Eds.). "
Modularization of
XHTML
".
World Wide Web Consortium
Recommendation. 10 April 2000.
Available at
XML
T. Bray, J. Paoli, C. M. Sperberg-McQueen, E.Maler (Eds.). "
Extensible Markup Language (XML) 1.0
Specification (Second Edition)
."
World
Wide Web Consortium
, Recommendation. 6 October 2000.
Available at
XML-Name
T. Bray, D. Hollander, A. Layman (Eds.). "
Namespaces in XML.
World Wide Web Consortium
, Recommendation.
14 January 1999.
Available at
XML-Schema1
H. Thompson, D. Beech, M. Maloney, and N. Mendelsohn (Eds.). "
XML Schema Part 1:
Structures
World Wide Web
Consortium
Recommendation. 2 May 2001.
Available at
XML-Schema2
P. Biron, A. Malhotra (Eds.). "
XML Schema Part 2:
Datatypes
World Wide Web
Consortium
Recommendation. 2 May 2001.
Available at
Appendix 2:
References
(Non-Normative)
APPEL
M. Langheinrich (Ed.). "
A P3P Preference Exchange
Language (APPEL)
."
World Wide Web
Consortium
Working Draft. 26 February 2001.
Available at
CACHING
I. Cooper, I. Melve, G. Tomlinson. "
Internet Web Replication and
Caching Taxonomy
." RFC3040, IETF, January 2001.
Available at
Persistent
Client State -- HTTP Cookies
," Preliminary Specification, Netscape,
1999.
Available at
ISO3166
"ISO3166: Codes for The Representation of Names of Countries."
International Organization for Standardization.
ISO8601
"ISO8601: Data elements and interchange formats -- Information
interchange -- Representation of dates and times." International
Organization for Standardization.
P3P-HEADER
M. Marchiori, R. Lotenberg (Eds.), "The HTTP header for the Platform
for Privacy Preferences 1.0 (P3P1.0)." IETF Internet Draft, 2002.
Latest version available as text at
Latest version available as HTML at
Latest version available as XML at
P3P-RDF
B. McBride, R.Wenning, L.Cranor. "
An RDF Schema for P3P
."
World Wide Web Consortium
, Note. 25
January 2002.
Latest version available at
RDF
O. Lassila and R. Swick (Eds.). "
Resource Description
Framework (RDF) Model and Syntax Specification.
World Wide Web Consortium
, Recommendation.
22 February 1999.
Available at
UNICODE
Unicode Consortium. "
The Unicode
Standard
Available at
Appendix 3: The P3P base data schema Definition
(Normative)
The data schema corresponding to the P3P base data schema follows for easy
reference. The schema is also present as a separate file at the URI


short-description="Year"/>

short-description="Month"/>

short-description="Day"/>

short-description="Hour"/>

short-description="Minutes"/>

short-description="Second"/>

short-description="Fraction of Second"/>

short-description="Time Zone"/>


short-description="Login ID">

short-description="Login Password">


short-description="Name Prefix">

short-description="Given Name (First Name)">

short-description="Middle Name">

short-description="Family Name (Last Name)">

short-description="Name Suffix">

short-description="Nickname">


short-description="Certificate key">

short-description="Certificate format">


short-description="International Telephone Code">

short-description="Local Telephone Area Code">

short-description="Telephone Number">

short-description="Telephone Extension">

short-description="Telephone Optional Comments">



short-description="Street Address">

short-description="City">

short-description="State or Province">

short-description="Postal Code">

short-description="Organization Name">

short-description="Country Name">


short-description="Telephone Number"
structref="#telephonenum">

short-description="Fax Number"
structref="#telephonenum">

short-description="Mobile Telephone Number"
structref="#telephonenum">

short-description="Pager Number"
structref="#telephonenum">


short-description="Email Address">

short-description="Home Page Address">


short-description="Postal Address Information"
structref="#postal">

short-description="Telecommunications Information"
structref="#telecom">

short-description="Online Address Information"
structref="#online">


short-description="URI Authority"/>

short-description="URI Stem"/>

short-description="Query-string Portion of URI"/>


short-description="Complete Host and Domain Name">

short-description="Partial Hostname">

short-description="Full IP Address">

short-description="Partial IP Address">


short-description="URI of Requested Resource"
structref="#uri">

short-description="Request Timestamp"
structref="#date">

short-description="Client's IP Address or Hostname"
structref="#ipaddr">

short-description="HTTP Request Method">

short-description="Data Bytes in Response">

short-description="Response Status Code">


short-description="Last URI Requested by the User"
structref="#uri">

short-description="User Agent Information">


short-description="Click-stream Information"
structref="#loginfo">

short-description="HTTP Protocol Information"
structref="#httpinfo">

short-description="User's Interaction with a Resource">

short-description="Use of HTTP Cookies"/>

short-description="Search Terms">

short-description="Server Stores the Transaction History">

short-description="Miscellaneous Non-base Data Schema =
information"/>


short-description="User's Name"
structref="#personname">

short-description="User's Birth Date"
structref="#date">

short-description="User's Login Information"
structref="#login">

short-description="User's Identity Certificate"
structref="#certificate">

short-description="User's Gender">

short-description="User's Job Title">

short-description="User's Home Contact Information"
structref="#contact">

short-description="User's Business Contact Information"
structref="#contact">

short-description="Name of User's Employer">

short-description="Department or Division of Organization where User is Employed">


short-description="Third Party's Name"
structref="#personname">

short-description="Third Party's Birth Date"
structref="#date">

short-description="Third Party's Login Information"
structref="#login">

short-description="Third Party's Identity Certificate"
structref="#certificate">

short-description="Third Party's Gender">

short-description="Third Party's Job Title">

short-description="Third Party's Home Contact Information"
structref="#contact">

short-description="Third Party's Business Contact Information"
structref="#contact">

short-description="Name of Third Party's Employer">

short-description="Department or Division of Organization where Third Party is Employed">


short-description="Organization Name">

short-description="Department or Division of Organization">

short-description="Organization Identity certificate"
structref="#certificate">

short-description="Contact Information for the Organization"
structref="#contact">


Appendix 4: XML Schema Definition
(Normative)
This appendix contains the XML schema for P3P policy reference files, for
P3P policy documents, and for P3P data schema documents. P3P policy reference
files, P3P policy documents and P3P data schema documents are XML documents
that MUST conform to this schema. Note that this schema is based on the XML
Schema specification [
XML-Schema1
][
XML-Schema2
]. The schema is also present as a separate
file at the URI

xmlns='http://www.w3.org/2001/XMLSchema'
xmlns:p3p='http://www.w3.org/2002/01/P3Pv1'
targetNamespace='http://www.w3.org/2002/01/P3Pv1'
elementFormDefault='qualified'>


schemaLocation='http://www.w3.org/2001/xml.xsd' />
































minOccurs='0' maxOccurs='unbounded' type='anyURI'/>
minOccurs='0' maxOccurs='unbounded' type='anyURI'/>
minOccurs='0' maxOccurs='unbounded' type='p3p:cookie-element'/>
minOccurs='0' maxOccurs='unbounded' type='p3p:cookie-element'/>
minOccurs='0' maxOccurs='unbounded' type='anyURI'/>









































































































































































































































































use='optional' default='http://www.w3.org/TR/P3P/base'/>



























































Appendix 5: XML DTD Definition (Non-normative)
This appendix contains the DTD for P3P policy reference files, for P3P
policy documents, and for P3P data schema documents. This DTD MAY be used to
verify that P3P files are valid (although, note that there are some valid
files that may be rejected if checked against the DTD). The DTD is also
present as a separate file at the URI







EXCLUDE*,
COOKIE-INCLUDE*,
COOKIE-EXCLUDE*,
METHOD*,
EXTENSION*)>
about %URI; #REQUIRED >



scope CDATA #IMPLIED
path CDATA #IMPLIED >



max-age %NUMBER; #IMPLIED
date CDATA #IMPLIED >


POLICY*)>





name CDATA #IMPLIED
value CDATA #IMPLIED
domain CDATA #IMPLIED
path CDATA #IMPLIED>

name CDATA #IMPLIED
value CDATA #IMPLIED
domain CDATA #IMPLIED
path CDATA #IMPLIED>


TEST?,
ENTITY,
ACCESS,
DISPUTES-GROUP?,
STATEMENT+,
EXTENSION*)>
name ID #REQUIRED
discuri %URI; #REQUIRED
opturi %URI; #IMPLIED
xml:lang NMTOKEN #IMPLIED>




(nonident
| all
| contact-and-other
| ident-contact
| other-ident
| none),
EXTENSION*)>







( (LONG-DESCRIPTION, IMG?, REMEDIES?, EXTENSION*)
| (IMG, REMEDIES?, EXTENSION*)
| (REMEDIES, EXTENSION*) )?)>
resolution-type (service | independent | court | law) #REQUIRED
service %URI; #REQUIRED
verification CDATA #IMPLIED
short-description CDATA #IMPLIED >




src %URI; #REQUIRED
width %NUMBER; #IMPLIED
height %NUMBER; #IMPLIED
alt CDATA #REQUIRED >






CONSEQUENCE?,
((PURPOSE,RECIPIENT,RETENTION,DATA-GROUP+)|
(NON-IDENTIFIABLE,PURPOSE?,RECIPIENT?,RETENTION?,DATA-GROUP*)),
EXTENSION*)>




(current
| admin
| develop
| customization
| tailoring
| pseudo-analysis
| pseudo-decision
| individual-analysis
| individual-decision
| contact
| historical
| telemarketing
| other-purpose)+,
EXTENSION*)>

"required (always | opt-in | opt-out) #IMPLIED">




























(ours
| same
| other-recipient
| delivery
| public
| unrelated)+,
EXTENSION*)>












(no-retention
| stated-purpose
| legal-requirement
| indefinitely
| business-practices),
EXTENSION*)>






base %URI; "http://www.w3.org/TR/P3P/base" >

ref %URI; #REQUIRED
optional (yes | no) "no" >





name ID #REQUIRED
structref %URI; #IMPLIED
short-description CDATA #IMPLIED >


name ID #REQUIRED
structref %URI; #IMPLIED
short-description CDATA #IMPLIED >


| online
| uniqueid
| purchase
| financial
| computer
| navigation
| interactive
| demographic
| content
| state
| political
| health
| preference
| location
| government
| other-category)+>


















optional (yes | no) "yes" >
Appendix 6: ABNF Notation
(Normative)
The formal grammar of P3P is given in this specification using a slight
modification of [
ABNF
]. The following is a simple
description of the ABNF.
name = (elements)
where is the name of the rule, is one or
more rule names or terminals combined through the operands provided
below. Rule names are case-insensitive.
element1 element2)
elements enclosed in parentheses are treated as a single element,
whose contents are strictly ordered.
*element
at least
and at most occurrences of the
element.
(1*4 means one to four elements.)
element
exactly
occurrences of the element.
(4 means exactly 4 elements.)
*element
or more elements
(4* means 4 or more elements.)
*element
0 to elements.
(*5 means 0 to 5 elements.)
*element
0 or more elements.
(* means 0 to infinite elements.)
[element]
optional element, equivalent to *1(element).
([element] means 0 or 1 element.)
"string"
or
'string'
matches the literal string given inside double quotes.
Other notations used in the productions are:
or
/* ... */
comment.
Appendix 7: P3P Guiding Principles
(Non-normative)
This appendix describes the intent of P3P development and recommends
guidelines regarding the responsible use of P3P technology. An earlier version
was published in the W3C Note "
P3P Guiding Principles
).
The Platform for Privacy Preferences Project (P3P) has been designed to be
flexible and support a diverse set of user preferences, public policies,
service provider polices, and applications. This flexibility will provide
opportunities for using P3P in a wide variety of innovative ways that its
designers had not imagined. The P3P Guiding Principles were created in order
to: express the intentions of the members of the P3P Working Groups when
designing this technology and suggest how P3P can be used most effectively in
order to maximize privacy and user confidence and trust on the Web. In keeping
with our goal of flexibility, this document does not place requirements upon
any party. Rather, it makes recommendations about 1) what
should
be
done to be consistent with the intentions of the P3P designers and 2) how to
maximize user confidence in P3P implementations and Web services. P3P was
intended to help protect privacy on the Web. We encourage the organizations,
individuals, policy-makers and companies who use P3P to embrace the guiding
principles in order to reach this goal.
Information Privacy
P3P has been designed to promote privacy and trust on the Web by enabling
service providers to disclose their information practices, and enabling
individuals to make informed decisions about the collection and use of their
personal information. P3P user agents work on behalf of individuals to reach
agreements with service providers about the collection and use of personal
information. Trust is built upon the mutual understanding that each party will
respect the agreement reached.
Service providers should preserve trust and protect privacy by applying
relevant laws and principles of data protection and privacy to their
information practices. The following is a list of privacy principles and
guidelines that helped inform the development of P3P and may be useful to
those who use P3P:
CMA Code
of Ethics & Standards of Practice: Protection of Personal
1981
Council of Europe Convention For the Protection of Individuals with Regard
to Automatic Processing of Personal Data
CSA
--Q830-96 Model Code for the
Protection of Personal Information
Directive
95/46/EC of the European Parliament and of the Council of 24 October 1995
on the protection of individuals with regard to the processing of personal
data and on the free movement of such data
The
DMA's Marketing Online Privacy Principles and Guidance
and
The
DMA Guidelines for Ethical Business Practice
OECD
Guidelines on the Protection of Privacy and Transborder Flows of Personal
Data
Online
Privacy Alliance Guidelines for Online Privacy Policies
In addition, service providers and P3P implementers should recognize and
address the special concerns surrounding children's privacy.
Notice and Communication
Service providers should provide timely and effective notices of their
information practices, and user agents should provide effective tools for
users to access these notices and make decisions based on them.
Service providers should:
Communicate explicitly about data collection and use, expressing the
purpose for which personal information is collected and the extent to
which it may be shared.
Use P3P privacy policies to communicate about all information they
propose to collect through a Web interaction.
Prominently post clear, human-readable privacy policies.
User agents should:
Provide mechanisms for displaying a service's information practices to
users.
Provide users an option that allows them to easily preview and agree to
or reject each transfer of personal information that the user agent
facilitates.
Not be configured by default to transfer personal information to a
service provider without the user's consent.
Inform users about the privacy-related options offered by the user
agent.
Choice and Control
Users should be given the ability to make meaningful choices about the
collection, use, and disclosure of personal information. Users should retain
control over their personal information and decide the conditions under which
they will share it.
Service providers should:
Limit their requests to information necessary for fulfilling the level
of service desired by the user. This will reduce user frustration,
increase trust, and enable relationships with many users, including those
who may wish to have an anonymous, pseudonymous, customized, or
personalized relationship with the service.
Obtain informed consent prior to the collection and use of personal
information.
Provide information about the ability to review and if appropriate
correct personal information.
User agents should:
Include configuration tools that allow users to customize their
preferences.
Allow users to import and customize P3P preferences from trusted
parties.
Present configuration options to users in a way that is neutral or
biased towards privacy.
Be usable without requiring the user to store user personal information
as part of the installation or configuration process.
Fairness and Integrity
Service providers should treat users and their personal information with
fairness and integrity. This is essential for protecting privacy and promoting
trust.
Service providers should:
Accurately represent their information practices in a clear and
unambiguous manner -- never with the intention of misleading users.
Use information only for the stated purpose and retain it only as long
as necessary.
Ensure that information is accurate, complete, and up-to-date.
Disclose accountability and means for recourse.
For as long as information is retained, continue to treat information
according to the policy in effect when the information was collected,
unless users give their informed consent to a new policy.
User agents should:
Act only on behalf of the user according to the preferences specified by
the user.
Accurately represent the practices of the service provider.
Security
While P3P itself does not include security mechanisms, it is intended to be
used in conjunction with security tools. Users' personal information should
always be protected with reasonable security safeguards in keeping with the
sensitivity of the information.
Service providers should:
Provide mechanisms for protecting any personal information they
collect.
Use appropriate trusted protocols for the secure transmission of
data.
User agents should:
Provide mechanisms for protecting the personal information that users
store in any data repositories maintained by the agent.
Use appropriate trusted protocols for the secure transmission of
data.
Warn users when an insecure transport mechanism is being used.
Appendix 8: Working Group Contributors
(Non-normative)
This specification was produced by the P3P Specification Working Group. The
following individuals participated in the P3P Specification Working Group,
chaired by Lorrie Cranor (AT&T): Mark Ackerman (University of California,
Irvine), Margareta Björksten (Nokia), Eric Brunner (Engage), Joe Coco
(Microsoft), Brooks Dobbs (DoubleClick), Rajeev Dujari (Microsoft), Matthias
Enzmann (GMD), Patrick Feng (RPI), Aaron Goldfeder (Microsoft), Dan Jaye
(Engage), Marit Koehntopp (Privacy Commission of Land Schleswig-Holstein,
Germany), Yuichi Koike (NEC/W3C), Yusuke Koizumi (ENC), Daniel LaLiberte
(Crystaliz), Marc Langheinrich (NEC/ETH Zurich), Daniel Lim (PrivacyBank), Ran
Lotenberg (IDcide), Massimo Marchiori (W3C/MIT/UNIVE), Christine McKenna
(Phone.com, Inc.), Mark Nottingham (Akamai), Paul Perry (Microsoft), Jules
Polonetsky (DoubleClick), Martin Presler-Marshall (IBM), Joel Reidenberg
(Fordham Law School), Dave Remy (Geotrust), Ari Schwartz (CDT), Noboru Shimizu
(ENC), Rob Smibert (Jotter Technologies Inc.), Tri Tran (AvenueA), Mark
Uhrmacher (DoubleClick), Danny Weitzner (W3C), Michael Wallent (Microsoft),
Rigo Wenning (W3C), Betty Whitaker (NCR), Allen Wyke (Engage), Kevin Yen
(Netscape), Sam Yen (Citigroup), Alan Zausner (American Express).
The P3P Specification Working Group inherited a large part of the
specification from previous P3P Working Groups. The Working Group would like
to acknowledge the contributions of the members of these previous groups
(affiliations shown are the members' affiliations at the time of their
participation in each Working Group).
The P3P Implementation and Deployment Working Group, chaired by Rolf Nelson
(W3C) and Marc Langheinrich (NEC/ETH Zurich): Mark Ackerman (University of
California, Irvine), Rob Barrett (IBM), Joe Coco (Microsoft), Lorrie Cranor
(AT&T), Massimo Marchiori (W3C/MIT), Gabe Montero (IBM), Stephen Morse
(Netscape), Paul Perry (Microsoft), Ari Schwartz (CDT), Gabriel Speyer
(Citibank), Betty Whitaker (NCR).
The P3P Syntax Working Group, chaired by Steve Lucas (Matchlogic): Lorrie
Cranor (AT&T), Melissa Dunn (Microsoft), Daniel Jaye (Engage
Technologies), Massimo Marchiori (W3C/MIT), Maclen Marvit (Narrowline), Max
Metral (Firefly), Paul Perry (Firefly), Martin Presler-Marshall (IBM),
Drummond Reed (Intermind), Joseph Reagle (W3C).
The P3P Vocabulary Harmonization Working Group, chaired by Joseph Reagle
(W3C): Liz Blumenfeld (America Online), Ann Cavoukian (Information and Privacy
Commission/Ontario), Scott Chalfant (Matchlogic), Lorrie Cranor (AT&T),
Jim Crowe (Direct Marketing Association), Josef Dietl (W3C), David Duncan
(Information and Privacy Commission/Ontario), Melissa Dunn (Microsoft),
Patricica Faley (Direct Marketing Association), Marit Köhntopp (Privacy
Commissioner of Schleswig-Holstein, Germany), Tony Lam (Hong Kong Privacy
Commissioner's Office), Tara Lemmey (Narrowline), Jill Lesser (America
Online), Steve Lucas (Matchlogic), Deirdre Mulligan (Center for Democracy and
Technology), Nick Platten (Data Protection Consultant, formerly of DG XV,
European Commission), Ari Schwartz (Center for Democracy and Technology),
Jonathan Stark (TRUSTe).
The P3P Protocols and Data Transport Working Group, chaired by Yves Leroux
(Digital): Lorrie Cranor (AT&T), Philip DesAutels (Matchlogic), Melissa
Dunn (Microsoft), Peter Heymann (Intermind), Tatsuo Itabashi (Sony), Dan Jaye
(Engage), Steve Lucas (Matchlogic), Jim Miller (W3C), Michael Myers
(VeriSign), Paul Perry (FireFly), Martin Presler-Marshall (IBM), Joseph Reagle
(W3C), Drummond Reed (Intermind), Craig Vodnik (Pencom Web Worlds).
The P3P Vocabulary Working Group, chaired by Lorrie Cranor (AT&T): Mark
Ackerman (W3C), Philip DesAutels (W3C), Melissa Dunn (Microsoft), Joseph
Reagle (W3C), Upendra Shardanand (Firefly).
The P3P Architecture Working Group, chaired by Martin Presler-Marshall
(IBM): Mark Ackerman (W3C), Lorrie Cranor (AT&T), Philip DesAutels (W3C),
Melissa Dunn (Microsoft), Joseph Reagle (W3C).
Finally,
Appendix 7
is drawn from the W3C
Note "
P3P Guiding
Principles
", whose signatories are: Azer Bestavros (Bowne Internet
Solutions), Ann Cavoukian (Information and Privacy Commission Ontario Canada),
Lorrie Faith Cranor (AT&T Labs-Research), Josef Dietl (W3C), Daniel Jaye
(Engage Technologies), Marit Köhntopp (Land Schleswig-Holstein), Tara Lemmey
(Narrowline; TrustE), Steven Lucas (MatchLogic), Massimo Marchiori (W3C/MIT),
Dave Marvit (Fujitsu Labs), Maclen Marvit (Narrowline Inc.), Yossi Matias (Tel
Aviv University), James S. Miller (MIT), Deirdre Mulligan (Center for
Democracy and Technology), Joseph Reagle (W3C), Drummond Reed (Intermind),
Lawrence C. Stewart (Open Market, Inc.).