P3P Implementation Tips: Observations for approaching Design, Build and Deploy PricewaterhouseCoopers Brendon Lynch

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P3P Implementation Tips Observations for
approachingDesign, Build and Deploy
PricewaterhouseCoopersBrendon Lynch
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Assemble your team

• Your P3P Build and Deploy team needs a
  combination of skill sets
• IT
• Privacy
• Legal
• Marketing
• Content Management
• and perhaps.. Consultants

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Understand Your Website Architecture

• Perform a detailed review of your website to
  determine
• How reliant is your website on cookies?
• What states do users have on your site (e.g.
  visitor (anon), registrant, transactor?)
• Which cookies are associated with these states?
• How will a users experience be affected if
  cookies are blocked or denied?
• Does your website recognize when cookies are
  blocked?
• Are suitable work-around instructions provided

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Detect and instruct - example
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Other 3rd Party Cookies

• Some companies are missing the true impact,
  example (now changed but)www.cnn.com served a
  metric count cookie from www.cnnaudience.com
• This is a 3P cookie in the IE6 logic and is
  blocked at medium (default)
• Solutions a suitable Compact Policy or an
  architecture change to minimal level domain

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Determine 3rd Party Compliance

• Your third party cookie providers should be P3P
  compliant by now
• If not, what effect will this have on your site?
• Consider unique metric counts relied upon by
  analysts
• Engage in dialog with your 3rd Party cookie
  vendors and work with them to implement P3P
  compact policies

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Our Tools for Understanding Your Web Architecture

• WebCPOTM, a complete privacy technology developed
  by Watchfire and PwC that scans and provides an
  automated detailed analysis of your website
  architecture, cookies and IE6 impact.
• WebCPOTM will scan every link on the website,
  identifying 3rd Parties, Cookies, Forms,
  Security, domains, and other important privacy
  criteria.
• More details can be explained post-workshop

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IE 6 Cookie Handling Report
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Know the Spec!

• The specification is long and cumbersome, it
  takes a while to digest
• Simple, one Full P3P (verbose) instance is best,
  but only IF your architecture permits
• Use the P3P Generators but beware they are not
  perfect, you still need to micro-audit, test and
  pilot the outputs
• P.S. Do you have the correct version of the spec?

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Understand Your Existing Narrative Privacy Policy

• Does your narrative privacy policy adequately
  disclose all of the elements in the Spec?
• Are you comfortable that your site conforms to
  the statement?
• Does your policy map to the binary disclosures
  required in Full P3P policy?
• Check some elements, (e.g. Data Retention)
• Indefinitely may sound bad, your company does
  have retention standards, should this be
  articulated in your narrative policy?

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Understand Your Existing Narrative Privacy Policy

• Be Aware - Your current policy may need to be
  revised after a P3P Policy is created.
• Simple items e.g. entity contact information,
  phone number
• Complex items - Access, Retention,
  Multiple-choice

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Edit the Full Policy

• The Policy Building utilities are a good starting
  point, but are not perfect(e.g. may not output
  multiple statements)
• If changes need to be made to the Full Policy, a
  simple XML editor should be used to make the
  changes
• Avoid using a text editor or word processor to
  make changes, they will not always work properly

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Full P3P Matrix

• Recommended
• Map each Data element by user state,
  double/triple check, get a second pair of eyes,
  (then code)
• Discuss the mapping with the whole team, check
  your binary i/o decisions with legal
• Youd be surprised.

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Full Policy Some key areas

• Disputes sometimes legislation can also be
  disclosed, see ATT example
• Statement groups together a purpose element, a
  recipient element, a data group element, and
  optionally a consequence elements and one or more
  extensions
• NOTE create a statement per user state and
  also the cookies associated with that state for
  future proofing, also name your statements using
  the extension syntax so they view in the Privacy
  Report

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User states confusing example
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Validate the Full Policy

• Use the W3C developed Validator to ensure Full
  Policy does not have errors
• http//www.w3.org/P3P/validator/20010928
• WARNING! the validator DOES NOT check all
  logic, (e.g. prior version did not check for
  opturi 3.2.2 mandatory if purpose elements
  have opt-in or opt-out)

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Test View Privacy Report

• REMINDER IE6 uses the Full P3P policy to create
  the View Privacy Report
• Check if the Privacy Report displays accurately,
  (e.g. the seal gifs, did you correctly code name
  extensions on statements, did you have good
  descriptions in the Other Purpose and Other
  Categories?)
• If Policy Reference File contains EXCLUDE
  statements, the Full Policy should not work on
  those areas of the site - double check the coding
  and the accuracy of the elements
• Recommend testing on a local webserver
  environment - NOT in live environment

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Build a Compact Policy

• The Compact policy must associate the elements of
  your Full P3P policy that relate to the actual
  practices of the cookie, it would be normal to
  have multiple CPs
• REMINDER IE6 only evaluates the Compact Policy

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Validate the Compact Policy

• Manual Validation Required
• Reference P3P Specification for details around
  tokens
• Ensure that you have not created unsatisfactory
  conditions by not specifying opt-in or opt-out
  criteria
• See IE6 guidance on msdn
• Be cognizant of Low, Medium and High (e.g. o
  unsatisfactory at High setting)
• Build site logic to recognize blocked cookies and
  prompt users to accept

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Implement Test

• IE6 offers two good methods for testing P3P
• View Privacy Report Option
• Prompt for Cookies
• Tools / Internet Options / Privacy
• Advanced, check override
• Prompt 1P and 3P
• Once prompted, allow, block, more info displays
  the full cookie properties including CP served

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Check All Cookies

• Make sure you have deployed the right CP on the
  matching cookie and every cookie!
• Youd be surprised.
• IT department should validate the purpose of each
  cookie, get sign-off prior to launch
• Again, if possible - deploy on test first

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Ongoing Monitoring

• Periodically review your website
• Preferably use an automated tool, such a
  WebCPOTM, to ensure ongoing P3P compliance
• Ensure that current and future 3P Cookies are P3P
  compliant
• New or changes in use of 1P cookies deployed must
  be revisited
• Implement automatic manual triggers human
  change machine change