Versions Compared

Old Version 9

changes.mady.by.user Colin Wallis

Saved on

compared with

New Version Current

changes.mady.by.user Colin Wallis

Saved on

Key

  • This line was added.
  • This line was removed.
  • Formatting was changed.

...

Introduction

This document (Report: Code of Conduct might include Sections for ...A) Data Protection, B) Admin and Marketing,  plus other aspects to make it comprehensive..

It assumes (1) a set of agreed definitions and (2) a legal contract to make all obligations clear for interpretation.

Colin: July 2015: Trying to find a template for this work. Here is something informed by GEANT's Data Protection one.. via Clarin..

https://www.clarin.eu/content/how-can-i-comply-data-protection-code-conduct

and you can see the various Codes here..Data Protection, etc, non normative informational docs..very good they are too!

http://www.geant.net/uri/dataprotection-code-of-conduct/V1/Pages/default.aspx

 

Data Protection Code of Conduct For Service Providers ... with clauses that might apply to an overall contract removed for clarity./.
The RP/Service Provider agrees and warrants:
a) [Legal compliance] to only process the Attributes in accordance with the relevant provisions of the XXXX law applicable to the RP/Service Provider;
b) Purpose limitation] to only process Attributes of the End User that are necessary for enabling access to the service provided by the Service Provider;
c) [Data minimisation] to minimise the Attributes requested from a Home Organisation to those that are adequate, relevant and not excessive for enabling access to the service and, where a number of
Attributes could be used to provide access to the service, to use the least intrusive Attributes possible;
d) [Deviating purposes] not to process the Attributes for any other purpose (e.g. selling the Attributes or selling the personalisation such as search history, commercial communications, profiling) than enabling
access, unless prior consent has been given to the Service Provider by the End User;
e)[Data retention] to delete or anonymise all Attributes as soon as they are no longer necessary for the purposes of providing the service;
f) [Third parties] not to transfer Attributes to any third party (such as a collaboration partner) except a. if mandated by the Service Provider for enabling access to its service on its behalf, or b. if the third party is committed to the Code of Conduct or has undertaken similar duties
considered sufficient under the data protection law applicable to the Service Provider or c. if prior consent has been given by the End User;
g) [Security measures] to take appropriate technical and organisational measures to safeguard Attributes against accidental or unlawful destruction or accidental loss, alteration, unauthorized
disclosure or access. These measures shall ensure a level of security appropriate to the risks represented by the processing and the nature of the data to be protected, having regard to the state of the art and the cost of their implementation.
h) [Information duty towards End User] to provide to the End User, at least at first contact, in an easily, directly and permanently accessible way a Privacy Policy, containing at least the following information:
a. the name, address and jurisdiction of the Service Provider;
b. the purpose or purposes of the processing of the Attributes;
c. a description of the Attributes being processed;
d. the third party recipients or categories of third party recipient to whom the Attributes might be disclosed, and proposed transfers of Attributes to countries outside of the XXX location/federation
e. the existence of the rights to access, rectify and delete the Attributes held about the End User;
f. the retention period of the Attributes;
g. a reference to this Code of Conduct;
i)
Information duty towards XX(IDP/AP)XX to provide to the or its Agent at least the following information:. a machine-readable link to the Privacy Policy;b. indication of commitment to this Code of Conduct;c. any updates or changes in the local data protection legislation, which are less strict than the principles set out in this Code of Conduct;
j) [Security Breaches] to, without undue delay, report all suspected privacy or security breaches(including unauthorized disclosure or compromise, actual or possible loss of data, documents or any device, etc.) concerning the Attributes to the Home Organisation or its Agent;
k)
l) [Transfer to third countries] when Attributes are being transferred outside the XX Federations/legal area and countries with adequate data protection pursuant to XXXX law.. to ensure an adequate level of protection of the Personal Data by taking appropriate measures pursuant
to the law of the country in which the XX IdP/AP XX is established, such as requesting End User consent or entering into agreements with the XXIdP/AP;XX
m)
n)
o)
p)
q)

 

 

 

placeholder

From the Jan 2015 minutes:

Ken: Some have clearly defined requirements:

1)Governments as relying parties – Are there a common set of requirements that governments have of authoritative parties (Token, Attribute or Identity Providers)?  Do authoritative parties (Token, Attribute or Identity Providers) have expectations of governments that consume their assertions?

2) Governments as authoritative parties (Token, Attribute or Identity Providers) – are there concerns / restrictions on governments acting as an authoritative party? To internal government services, other jurisdictions or the private sector.

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

Incommon, Safe Biopharma

UK has come up with some

USA has come up with some

6-10 clearly identified

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

Keith: As discussed on the call, this page is a wiki comparing the various research and education federations.

https://refeds.terena.org/index.php/Federations

I feel a resource like this for eGov would be a great project for us to undertake and put on the Kantara wiki. It makes comparison of different technologies, models and policies very convenient.

This would take the excellent work done by the BCTF and add more information to the model, with a focus on eGov only.

http://kantarainitiative.org/confluence/display/bctf/Global+Trust+Framework+Survey

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

And of course we have the SAC (Service Assessment Criteria) that the Kantara Identity Assurance Framework uses for IdPs, that the IAWG is custodian of, that you see here (IAF 1400)
https://kantarainitiative.org/confluence/display/LC/Identity+Assurance+Framework
Look at the lists in section 4 and 5 of this
Section 4: COMMON ORGANIZATIONAL SERVICE ASSESSMENT CRITERIA
Enterprise and Service Maturity ..................................................................
Notices and User Information/Agreements ..................................................
Information Security Management ...............................................................
Security-relevant Event (Audit) Records......................................................
Operational infrastructure ............................................................................
External Services and Components ..............................................................
Secure Communications
Section 5: OPERATIONAL SERVICE ASSESSMENT CRITERIA.......................................
Credential Operating Environment ..............................................
Credential Issuing..........................................................................
Credential Renewal and Re-issuing...............................................
Credential Revocation...................................................................
Credential Status Management....................................................
Credential Verification/Authentication
We also have the discussion/list in the IETF about the Vectors of Trust which we should refer to
The trust vectors so far are (flip-sided as risk vectors thanks to Scott Shorter!):
Identity proofing/Identity theft
Credential Strength//Credential compromise
Assertion strength/Assertion subversion
Operational management/?
And we have some basic security requirements from the likes of ISO 27001/27002
..............................................................................................................................................
Boilerplate from NZ.. cut-down

1.1             Client Responsibilities

The Client will:

(a)       pay the Charges in accordance with clause 6;

(b)       co-operate with IdP personnel t in connection with its operation and safe-guarding of the Service/s;

(c)       comply with any standards or specifications issued by the IdP and any reporting obligations required by the IdP from time to time in accordance with any relevant legislation;

(d)       provide appropriate assistance, where reasonably requested by IdP, in carrying out any audit of the Client’s use of the Services or related systems or suppliers;

(e)       participate in progress reporting as specified in the Service Schedule;

(f)        advise IdP promptly of any Service anomalies, suspicious or unusual usage, or complaints relating to the Services and provide reasonable assistance to IdP in the investigation of such anomalies, usage or complaints;

(g)       ensure that the Client’s website terms and conditions explain the inter-relationship of the Services and the Client’s systems in terms agreed with IdP;

(h)       comply with all applicable laws including, without limitation, the Privacy Act 1993;

(i)         subject to clause XXX, use its best endeavours to promote the Services to its customer base to encourage service uptake and use;

(j)         maintain the Service Interface including the security between the Client’s systems and the Service System;

(k)       maintain certification as defined in the Service Integration Guide;

(l)         notify IdP of any network changes or certification renewals that may impact on any part of the Service;

(m)      ensure that the security and privacy of Service are protected to the greatest extent practicable; and

(n)       notify Service Users of the requirements and process published by IdP for Service Users to obtain a Login and verify their Identity.

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

Excerpt for InCommon FOPs

6        Registration, Identification and Authentication of Participant's Trusted Officers

InCommon verifies the identity of all individuals who fill the Participant's trusted roles of Executive and Administrator (see the InCommon website for definitions). By constructing an independently verifiable, out-of-band communication path with these officers, the Registration Authority establishes a sufficiently strong level of assurance that the person is who he or she declares. Details on the registry process are available on the InCommon website.

7        Registration and Management of Participant Policies, Systems, and Technical Components

The Participant's trusted Administrator will be given credentials to manage Federation Participant data and requests in a secure manner.

7.1       Types of Registered Systems: Identity Providers and Service Providers

Within the Federation, participants may offer services as an Identity Provider for their respective user community, as a Service Provider to any participant organization's user community, or both. For instance, a Higher Education Institution serving primarily as an Identity Provider might also make online information or services available to other InCommon participants. Similarly, a Sponsored Partner that is primarily a provider of online services might also act as an Identity Provider.

Participants register identity management systems and/or service provider systems using the InCommon participant administrative interface. Higher Education Institutions and Sponsored Partners receive an initial quota for each system type and can purchase more as needed, subject to certain restrictions, as outlined in the Participation Agreement and Fee Schedule available on the InCommon website.

7.2       Relationship of Systems to Participant

Any identity management system or service provider system registered by a Participant must be under the management hierarchy of the Participant organization. The Participant is responsible for the actions of any system registered with the Federation. Participants may only register third party systems that operate services under contract to Participant and for which Participant will be responsible, in accordance with the provisions of the Participation Agreement. Such third party systems might, for example, include outsourced identity management services.

7.3       Required Information Components

7.3.1      Participant Operating Practices

A fundamental expectation of Federation Participants is that they provide authoritative and accurate attribute assertions to other participants and that participants receiving an attribute assertion protect it and respect any privacy constraints placed on it by the Federation or the source of that information.

To support this goal, each Participant must describe its relevant operations in a Participant Operating Practices (POP) statement and share this POP with Federation Participants. The template POP is available on the InCommon website. In some cases, multiple systems can be described in one POP. A current version of the POP must always be available to the Federation and Participant Administrators. InCommon does not review such Participant Operating Practices against any criteria of performance. The POP is a self-asserted declaration by each Participant of its current practices. More information about POP requirements is available on the InCommon website.

7.3.2      Metadata

A Participant Administrator registers its Identity Provider and Service Provider systems through the participant administrative interface by describing components of its systems. The data are collected and digitally signed by InCommon. Secure, up-to-date, trusted information about all Participants and their systems is a core service of the Federation. InCommon will make reasonable efforts to verify submitted data, and will act in accordance with the practices outlined in the InCommon Operations reference, available on the InCommon website.

Metadata may be removed or modified by Participant Administrators through the participant administrative interface. Changes to metadata are updated within one Internet2 business day following the submission. Under special circumstances, Participant Executives or Administrators may make removal requests via e-mail or telephone as listed on the InCommon website. InCommon will verify these requests using trusted communication channels before processing any removal requests.

Transmission of Federation metadata to Participants is not initiated by InCommon. Instead, Participants are expected to retrieve Federation metadata on a regular basis.

7.3.2.1   

7.3.2.2     Declaration of Participant Assurance Program Certification

InCommon adds a declaration of certification status to the metadata of each Participant's certified identity providers. Only InCommon can supply or modify Assurance metadata declarations. InCommon will remove any declaration when necessary to effect suspension of a certification or termination of a Participant from the program.

8        8.1       Disputes Among Participants

8.2       Disputes Between Participant(s) and the Federation

9        Operations

9.1       Operational Assurance Level

9.1.1      Central Operations .... so the RP Code of Conduct should include a clause agreeing to follow these..

Complete procedures were developed detailing InCommon's central operations. Information security industry standards and practices[1] were used to establish the necessary level of assurance. These operations and procedures were approved by a technical advisory group of Internet2 Middleware Architects. A public listing of these procedures can be found on the InCommon website.

9.1.2      Operations Staff Credentials and Authorization

Operations staff who perform actions critical to security or trustworthiness of Federation operations or services are issued strong identity credentials, commensurate with the risk incurred by unauthorized access to such actions.

9.2       Communications and Support

9.3       Federation Technical Infrastructure

9.3.1      Discovery Service (DS)

9.3.2      Metadata Distribution ..... so the PR is obliged to consume it?

InCommon digitally signs and makes available to Participants metadata submitted by all Participants for interoperation of Identity Provider and Service Provider systems. The metadata is maintained on redundant servers.

9.3.3      Participant Administrative Interface

Federation Participant Administrators use the Participant Administrative Interface to securely manage the data relevant to their organization's participation in the Federation. The particular tasks include submitting certificate signing requests, Participant Operating Practices, and submitting or modifying Participant metadata.

9.3.4      Suspension of Federation Services

 

9.4   Disaster Recovery

10    Participation Status: Renewal, Withdrawal, Termination, and Suspension

for Relying Parties) provides supporting guidance to the controlling documents of the Kantara Initiative Identity Assurance Framework (IAF) so that, in the fullness of time, the IAF and its controlling document suite could be extended to include the role of Relying Parties (RPs).

The intended audience for this document are Trust Framework operators that may require requirements for RPs be specified.

A complete Code of Conduct for Relying Parties, that spans the full extent of a RP's policies, processes and procedures, might include Sections such as the following:

  1. Data Protection,
  2. Admin, Record Keeping and Process,
  3. Audit and Compliance,
  4. Exit and Off Boarding and
  5. Marketing.

It should be noted that other aspects, applicable to a given context or domain, might be required to make it comprehensive.

At this time the document is not intended to be a complete set of requirements for good behaviour of a RP. Rather, it is intended to give pointers to the range of topics that should typically be addressed in describing this set of requirements. A few exemplars have been provided for some of the topics.

On conceptualizing a typical Table of Contents for a code of Conduct for Relying Parties

This document offers an insight into what a typical Code of Conduct for Replying Parties might contain by presenting a draft Table of Contents.  Further, it assumes that the Code of Conduct for Relying Parties would form just one component of a larger document suite (e.g., the IAF) covering other aspects of federated identity activities.  

It assumes that the following artefacts and conditions exist in that broader framework document set for the federation:  

  1. a set of agreed definitions/terminology,
  2. Scope and specification of the Replying Party activities,
  3. a legal contract in force to make all obligations clear for interpretation,
  4. that a federated trust framework is operating, and
  5. that a quality ISMS is operating in the RP/AP environments..

With the above conditions met, a Table of Contents for the Code of Conduct for Relying Parties aspect of the document set might include:

  • Introduction and Purpose
  • Executive Summary
  • Assumptions
  • Definitions/Terminology
  • References and bibliography
  • Activities in scope for the Relying Party
  • Data Protection*  
  • Administration, Record Keeping and processes/procedures* 
  • Audit and Compliance
  • Exit and Off boarding*
  • Marketing

* (note: example text for this topic has been drafted below)

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

Exemplar draft text for the Table of Contents headings above selected and marked as *  

Note: the test in square brackets [..] indicate a principle or objective that the statement seeks to address.

Data Protection 


The RP/Service Provider agrees and warrants:
  1. [Legal compliance] to only process the Attributes in accordance with the relevant provisions of the law applicable to the RP/Service Provider/Federation;
  2. [Purpose limitation] to only process Attributes of the End User that are necessary for enabling access to the service provided by the Service Provider;
  3. [Data minimisation] to minimise the Attributes requested from a party to the Federation to those that are adequate, relevant and not excessive for enabling access to the service and, where a number of Attributes could be used to provide access to the service, to use the least intrusive Attributes possible;
  4. [Deviating purposes] not to process the Attributes for any other purpose (e.g. selling the Attributes or selling the personalisation such as search history, commercial communications, profiling) than enabling access, unless prior consent has been given to the Service Provider by the End User;
  5. [Data retention] to delete or anonymise all Attributes as soon as they are no longer necessary for the purposes of providing the service;
  6. [Third parties] not to transfer Attributes to any third party (such as a collaboration partner) except 1. if mandated by the Service Provider for enabling access to its service on its behalf, or 2. if the third party is committed to the Code of Conduct or has undertaken similar duties considered sufficient under the data protection law applicable to the Service Provider or 3. if prior consent has been given by the End User;
  7. [Security measures] to take appropriate technical and organisational measures to safeguard Attributes against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. These measures shall ensure a level of security appropriate to the risks represented by the processing and the nature of the data to be protected, having regard to the state of the art and the cost of their implementation.
  8. [Information duty towards End User] to provide to the End User, at least at first contact, in an easily, directly and permanently accessible way a Privacy Policy, containing at least the following information:
    1. the name, address and jurisdiction of the Service Provider;
    2. the purpose or purposes of the processing of the Attributes;
    3. a description of the Attributes being processed
    4. the third party recipients or categories of third party recipient to whom the Attributes might be disclosed, and proposed transfers of Attributes to countries outside of the jurisdiction/federation
    5. the existence of the rights to access, rectify and delete the Attributes held about the End User;
    6. the retention period of the Attributes;
    7. a reference to this Code of Conduct;
  9. [Information duty towards  the Federation party/IDP] to provide to it or its Agent at least the following information:
    1. machine-readable link to the Privacy Policy;
    2. indication of commitment to this Code of Conduct;c. any updates or changes in the local data protection legislation, which are less strict than the principles set out in this Code of Conduct;
  10. [Security Breaches] to, without undue delay, report all suspected privacy or security breaches(including unauthorized disclosure or compromise, actual or possible loss of data, documents or any device, etc.) concerning the Attributes, to the Federation Party/IdP or its Agent;
  11. [Transfer to third countries] when Attributes are being transferred outside the jurisdiction and to countries with adequate data protection pursuant to adequacy law/rules etc.. to ensure an adequate level of protection of the Personal Data by taking appropriate measures pursuant to the law of the country in which the RP/Service Provider is established, such as requesting End User consent or entering into agreements with the RP/Service Provider.

Admin, Record Keeping and Processes/procedures
  1. [Payment] pay the Charges in accordance with XXXX clause in the Federation Agreement;
  2. [Co-operation] co-operate with Federation/IdP personnel in connection with its background checking/identity proofing of RP/SP responsible officers, registering authorisation policy for and provide access to records and resources, operation and safe-guarding of the Service/s; and advise IdP promptly of any Service anomalies, suspicious or unusual usage, or complaints relating to the Services and provide reasonable assistance to Federation/IdP in the investigation of such anomalies, usage or complaints; 
  3. [Standards Compliance] comply with any standards or specifications issued by the Federation/IdP and any reporting obligations required by the IdP/AP from time to time in accordance with any relevant legislation (including those of a contracted third party to the RP/SP)
  4. [Audit]   provide appropriate assistance, where reasonably requested by IdP/AP, in carrying out any audit of the Client’s use of the Services or related systems or suppliers; comply with all certification and accreditation requirements
  5. [Federation Reporting] participate in progress reporting as specified in the Service Schedule;
  6. [ transparent relationship  ] ensure that the agency Service Provider/RP's website terms and conditions explain the inter-relationship of the Services and the Client’s systems in terms agreed with Federation/IdP; that the RP/Service Provider maintains an accurate and up to date register of its roles and activities 
  7. [ Promotion  ]   use its best endeavours to promote the Services and instructions for use, to its customer base to encourage service uptake and use;
  8. [Maintenance and notification  ]  use and maintain the Service Interface including the security between the Client’s systems and the Service System;  register/modify/remove/retrieve meta-data,  maintain PKI certificates as defined in the XX Federation Documentation XX; notify IdP of any network changes or certification renewals that may impact on any part of the Service, use the Admin interface to register and update details relating to the Service and the officers charged with administering the service
  9. [Technical Consistency] Requirements for mandatory conformance testing before being connected to the production environment; Requirements for session management and logout (e.g. requirements for session timeout periods and single logout behaviour across the federation); Requirements for logging certain events (e.g. SAML Request/Responses) and to establish correlation identifiers in logs; Requirements for UI (to ensure a consistent user experience across the federation - e.g. layout and placement of 'logout' buttons etc.); Requirements for certificates used to secure communication between SP and IdP.

Exit and Off boarding

  1. [Exit and off boarding]: RP must have an explicit written policy to address and mitigate impacts to existing users (e.g portability of accounts if feasible, re-enrollment, credential switching) in the event that the RP terminates or is terminated from its role.
  2. [Exit and off boarding]: RP must have predetermined processes to put into action to update Helpdesk on status, call handling procedures and documentation, website information, test scripts and system flows to reflect the terminated state of the RP  

References

GEANT: http://www.geant.net/uri/dataprotection-code-of-conduct/V1/Pages/default.aspx (accessed from https://www.clarin.eu/content/how-can-i-comply-data-protection-code-conduct)  

Federal Government of Canada: 'Adding and removing Credential Service Providers under the Credential Broker Service' TBS Canada, CIO Branch, Feb 2015, Version 4.0

Kantara Initiative: Identity Assurance Framework

InCommon:  https://www.incommon.org/docs/policies/InCommonFOPP.pdf 

IETF: Vectors of Trust: https://datatracker.ietf.org/doc/draft-richer-vectors-of-trust/?include_text=1  for the latest version, taken from https://www.ietf.org/mailman/listinfo/vot

NZ RealMe: https://www.realme.govt.nz/ though the MOU from which some text for the Admin, Record-Keeping and Processes/Procedures section is not published

TERENA: https://refeds.terena.org/index.php/Federations

NemLog-in Denmark: http://www.digst.dk/~/media/Files/NemLogin/Tilslutnings-doks/Guide-til-foederationstilslutning-V1-1.pdf 

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