Authorization from Consent

Version: 0.8.9.3

Document Updated: Nov 22

Status:

The ANCR record objective is to provide operational transparency for people so they are able to have a choice to control personal data and it’s processing to co-regulate digital surveillance technologies.

The Anchored Notice and Consent Receipt (ANCR) as a digitally twinned record provides active state transparency features with the use of a technique called Differential Transparency. A processing model driven with the authority of the individual. The specification is intended to be used for with or in addition to any legal data processing activity. AuthC employs a 3-layer notice record schema to indicate knowledge of processing, and in this context indicate consent and or permissions as appropriate.

Required for a specific data exchange. PII Principals can enhance the single use record schema with a layer 2 schema that incorporates a digital identifier to serve a ‘proof of notice’ record for repeated use in concentric data exchanges.

The 3^rd notice record schema is the private, anchored notice record which contains sensitive information to validate the digital identity relationship. This schema is' a self-sovereign security' schema, which considers security transparency requirements as a mandatory pre-condition for digital consent receipt tokens validation.

Finally, an active technical record of processing activities provides for the PII Principal in context transparency over who is accountable for — and is a pre-condition of — processing Personally Identifiable Information (PII) for human interoperable governance and security.

AuthC contribution are from the Digital Transparency Lab Canada.

NOTES TO READER

This Kantara Initiative work effort began when Liberty Alliance became the Kantara Initiative, and the Consent and Information Sharing Working Group formally began in 2015. That Working Group’s activities carried on through the ANCR Working Group.

In this specification and proposed standard the term “PII Principal” is used interchangeably with Data Subject and “Individual”.

IPR Option:

This ANCR Record Specification is available for use for public benefit licensing @0PN C.I.C and the open schema available @Human Colossus, and is specified under a Reasonable and Non‑Discriminatory (RAND) agreement at the Kantara Initiative for submission to ISO/IEC SC 27 WG 5

Published for use as public infrastructure through code of conduct and practice in industry and trade certification bodies.

Patent & Copyright: Reciprocal Royalty Free with Opt-out to Reasonable and Nondiscriminatory (RAND)

Suggested Citation: (upon WG approval)

ANCR Specification v0.9

NOTICE

This document has been prepared by Participants of Kantara Initiative Inc. Permission is hereby granted to use the document solely for the purpose of implementing the Specification. No rights are granted to prepare derivative works of this Specification. Entities seeking permission to reproduce this document, in whole or in part, for other uses must contact the Kantara Initiative to determine whether an appropriate license for such use is available.

Implementation or use of certain elements of this document may require licenses under third party intellectual property rights, including without limitation, patent rights. The Participants and any other contributors to the Specification are not and shall not be held responsible in any manner for identifying or failing to identify any or all such third-party intellectual property rights. This Specification is provided "AS IS," and no Participant in Kantara Initiative makes any warranty of any kind, expressed or implied, including any implied warranties of merchantability, non-infringement of third-party intellectual property rights, or fitness for a particular purpose. Implementers of this Specification are advised to review Kantara Initiative’s website (http://www.kantarainitiative.org ) for information concerning any Necessary Claims Disclosure Notices that have been received by the Kantara Initiative Board of Directors.

Dear reader

Thank you for downloading this publication prepared by the international community of experts that comprise the Kantara Initiative. Kantara is a global non-profit ‘commons’ dedicated to improving trustworthy use of digital identity and personal data through innovation, standardization and good practice.

Kantara is known around the world for incubating innovative concepts, operating Trust Frameworks to assure digital identity and privacy service providers, and developing community-led best practices and specifications. Its efforts are acknowledged by OECD ITAC, UNCITRAL, ISO SC27, other consortia and governments around the world. 'Nurture, Develop, Operate' captures the rhythm of Kantara in consolidating an inclusive, equitable digital economy offering value and benefit to all.

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Contents

Introduction

ANCR Notice Record Schema Specification

The ANCR notice record is fundamentally a layered record schema, the first record layer is the minimum viable notice record (MVNR) a PII Principal can make to capture the organisation/institution that controls their personal data as well as the accountable person liable for that legal entity. This record collects no additional data, except what the PII Principal is required to see and understand in order to be legally informed of the risks of generating a digital identifier.

The notice record is an electronic notice document and is used to initiate electronic consent dialogue using a common, default engagement point that the PII Principal can expect, and trust, per data processing session.

Trust is predicated on operational transparency and security assurances that are inherent to creation and use of records and receipts.

This schema is cumulative, where each schema layer can be added upon the previous layer.

3 Layers to the ANCR Record Schema

Layer 1 - Notice Record Schema.

The PII Principal's private record of a notice without digital identifiers, also called a ‘minimum viable record notice’. This record is un-anchored and used for contextual purposes when it does not contain an ANCR Record ID, in the ancr record id field.

Layer 2 – Private Notice Record Micro-Data

1. The meta data that can, and must be collected with the notice record to make a digital record of the notice record

2. Is kept private and not directly accessible, exposed or made public.

3. The PII Principal private record collects personal data specific to the use of the notice

Layer 3 - A Proof of Notice (PoN) record is generated

1. A secured Anchored Notice Record generated upon engagement with a notice to demonstrate that the PII Principal is informed. Not an opt-in or opt-out check box – which is linked to a notice. But check-box to confirm a notice clause is read, with a button on the notice dialogue that generates a record and receipt when used by the PII Principal

2. A proof of notice record can then be used by processing stakeholders to generate subsequent (serialized) linked notice, notification and disclosure records pertinent to the context of notice.

   1. Personal identifiers and attributes are encrypted, secured, verified and validated by linking to the private notice record.

Notice Record Schema: PII Controller Identity & Privacy Contact Point Schema

These are the schema elements that are used to generate a static Notice Record and does not contain any PII, or digital identifiers.

Private Notice Record Profile

These fields can be asserted by the PII Principle to extend the functionality beyond the transparency TPI’s specified, on the PII Principal’s behalf.

These private record fields are separated from the Proof of Notice schema, as these are kept and controlled by the PII Principal and are used to provide defaults.

Private Notice Record Schema

This is the data source for consented records of processing that is directed (and securely) verified by the PII Principal, with secure localized data source and device.

Proof of Notice Record

For consented digital identity management, a proof of Notice Record is used as an alternative to terms and conditions, to mitigate high privacy risks associated with digital identifier surveillance and profiling. Terms of use refer to a contract-based policies for the governance of identifiers and credentials.

Much like a two-factor authentication (2FA) used for digital identity security, a two‑factor notice (2FN), presented here, adopts the ISO/IEC 27560 consent record information structure, as summarized in Appendix: ANCR Record Extension 1.

Each 2FN implements a standardized consent notice dialogue for the use of digital identity management technology, which is the technology used to profile and then automate personal data processing in systems.

Each 2FN requires the presentation of information about data processing using the same content controls, format, ontology, vocabulary, and order of presentation:

1. Legal justification,

2. Purpose of profiling

3. Localization/Scope of disclosures & identification of 3^rd Party Controllers

4. Privacy/Security and Surveillance Risks

The 2FN can provides standardized options to engage with the notice, notification, or disclosure. 2FN is typically implemented with a software interface in which, at a minimum, these three options are used by default (and easily extended with a code of practice):³

1. By default, the notice can be ignored.

2. PII Principal provides an informed consent

3. Privacy rights and control options are presented and, depending on the Individual’s age, an accessibility context can be further simplified to the right to be heard and make a complaint, in specific context of processing personal data notified.

An ANCR Notice Record and a Consent Receipt, referred to as a mirrored (or twinned) record of a processing activity, is generated when the PII Principal engages with a notice dialogue and completes a notification sequence by selecting one of the 2FN options; and, by default, when a notice or notification is ignored. When an ‘I consent’ option is selected an electronic notice record and evidence of consent receipt is generated, for the corresponding eConsent.

Note: The ANCR Notice Record ID is used to create and link new receipts, thereby ensuring the providence of the PII Principal’s control of the ANCR Record.

Proof of Notice Record Schema

The Proof of Notice Record builds upon the PII Controller Identity fields and contact fields, with PII Controller Identifiers used to digitally track the state of privacy .

The 2FN produces a network event, presenting information that is needed to produce an evidential record, which a PII Principal can then use independently. A micro-credential used to aggregate operational transparency information, access privacy state and rights information, or to implement personal data controls (that are required for a grant of consent grants to a system to implement controls and permissions in systems for collection, capture, portability and access to private data profiles)

• A notice that is used to generate granular consent receipts using standards that specify purpose in the same way. Those generated with the same schema based can be compared to automate notice for operational transparency over changes to privacy state.

• A 2FN is used to produce a dual record and receipt upon engaging with a standardized notice with access to administrator-level privacy rights from the notice, prior to processing with consent.

• The consent receipts produced from a 2FN can be compared independently to measure the difference in the active state and status of privacy, to automatically produce a notification based on the difference in state.

• Differential Transparency, produced with a tactile signal, or layer1 notice indicator, standardized with machine readable data privacy vocabulary (i.e., concentric and synchronic transparency).

Open

Notice Record Security Architecture

Overview

The ANCR Record represents the online privacy notice control record that is used to assess conformance with privacy expectations using controls and structure for consent from ISO/IEC 29184 Online Privacy Notice and Consent, which sets out the rules used to secure, protect and safeguard personal data:

• The only identifier is the identifier the PII Principal chooses to provide to extend the functionality of the anchored record for receipts.

• Only the PII Principal owns, controls, and delegates technical access to this identifier

• Whenever an identifier is exchanged, it must use the blinding identifier taxonomy, cryptographically hashed with PII Principal public/private key pair in which the private key is in the notice record and the public key is applied according to it’s purpose

• Only attributes from the corresponding records can be verified for a credential

• The record MUST not be generated or managed by any other stakeholder or delegate, apart from the PII Principal in order to be a trustworthy id.

Three (3) layers of the notice record schema is presented in this specification, with each layer building on the first as described in the Introduction.

Security practice: requirements for the privately anchored record

The ANCR record identifier has specific security requirements and considerations since it can be used by the PII Principal as an identifier for and by a PII Controller. The ANCR Notice Record can be extended to additional stakeholders with a public key. Consent records and receipts created by the PII Principal are sensitive, confidential, and secured for PII Principal ownership and control. Evidence of consent is required to access these attributes for producing or using verifiable (micro) credentials the PII Principal can validate.

The protocol requires that the ANCR Record be referenced each time a directed, or altruistic consent is generated, or when decentralized data governance is required. This is done in order to verify the PII Controller Identity and ensure sufficient (any) security for the privacy state that is, and can then be, expected by the PII Principal.

Security Assurance

The transparency performance indicators (TPIs) provide transparency and security assurance to the PII Controller before the Controller processes personal information.

Numerous methods available to provide security and to safeguard personal data, and for securing the control and transparency of data processing using the personal and private notice record, held by the PII Principal.

1. Blinding identifier taxonomy (BiT)

1. Pseudonymous identifier

1. Verified Credential Identifier

1. Differential Transparency

1. Differential Privacy (additive as editorial)

In this table, suggestions for what method can be applied on a per attribute level are provided as an example.

1. Blinded Identity Taxonomy (BiT)

   1. PII field security measure that is used to blind attributes that are identifiable, for example, the attributes presented in ISO/IEC 29100 section 4.4.2

   2. A BiT attribute is encrypted with the PII Principals private key- so as not be usable in any data set without the corresponding authority required to unencrypt the field for a specified purpose and treatment.

   3. In this specification BIT is used by the PII Principle to encrypt and blind the ANCR record ID field. Which is in the private notice record, the pseudonymized identifier generated/provided by the PII Principals (client security protocol)

2. Pseudonymized Identifier

   1. The ANCR record id refers to the PII Controller legal identity captured with a notice record, and once a notice record is collected it can be signed to become added to digital wallet (or pod), it can be signed to become a micro-credential, and used to communicate to the PII Controller, to manage rights and control processing of digital identifiers and associated information.

   2. Conceptually, the ANCR Id is a reverse use cookie, in that it is used by the PII Principle to remember the privacy state and track the PII Controller through different service environments, domains and jurisdictions.

3. Verifiable Private Notice Record signed to be a micro-credential

   1. The PII Principal as the holder of the notice record can use it to a verify the presentation a PII Controller Identity

   2. Holders of a signed notice record (proof of notice) can generate a verifiable presentation of this proof by;

      1. signing a copy of the notice-record

         1. (transforms record into a micro-credential)

      2. exchanging this with the other stakeholder (PII Principle or Controller) as a signed consent receipt in order to tokenize the exchange of attribute level private record data on a per processing session basis.

         1. (W3C Verified Credential Data Model, www.w3.org/TR/vc-data-model/#what-is-a-verifiable-credential)

4. Differential Transparency – operational transparency signaling

   1. Operational transparency – notice record ‘trust’ protocol for active state technical object. Achieved by comparing the expected privacy state (purpose and credential) each technical session to authorize an instance of processing, whereby a notification signal is generated only if there has been a change in the expected, and known active state of privacy.

   2. Differential Transparency (DT) is a contextual transparency enhancing notification protocol that uses record serialization in order to sequence data control points. Used to maintain a shared understanding of privacy and conversely security expectations.

   3. Implemented by comparing than Anchored Notice Record with a newly minted anchored consent notice receipt. To detect if there has been a change in this expected state. Achieved through self-asserted changes, or through monitoring authoritative public data sources.

   4. Differential Transparency is used by the PII Principal to automate the verification of trust, monitoring the active state of the PII Controller Legal identity and technical security performance. Prior to authorizing data processing activities by signing a consent notice receipt.

      1. Utilizing the Transparency Performance Indicator’s in the introduction of this specification to transform a consent receipt into a consent token. (Individual authority and providence default controls to implement rights)

   5.  

Notice Record Extensions (for a Consent Record information structure)

The Anchored Notice record can be extended with the standardized consent record information structure by using three (3) extensions.

Extension 1: Purpose Specification

The concentric notice label is used to identify the default legal justification for processing which is used for the default data processing practices.

ISO/IEC 27560 is used to generate a standard purpose-specification to then provide a two factor notice which can either confirm or update the PII Principal expectations of privacy, according to the context and legal justification for processing. The 2FN, provides pseudonymous access to privacy rights, controls and services, without requiring the PII Principal to identify themselves.

The Transparency Performance indicators can then be used by the PII Principal to validate and negotiate control of personal data processing, with the PII Controller according to the purpose and context of service provisions on or before data processing occurs.

The extension is written for the PII Controller, to enable the anchored record to be used as a verifiable data source for operationalizing a channel (exchange) where PII Principals can advertise a consent grant to the controller. (see Appendix 1 )

Extension 2: Data treatment & RIghts based controls

Extension 2 is focused on data treatment and rights of the purpose specified in Extension1. This extension uses some of the ISO/IEC 27560 schema, as well as the W3C Data Privacy Vocabulary, and some additional elements regarding delegation, cross-border adequacy, definition of data privacy rights data controls.

Extension 3:bundled cod of transparency practices

Extending the security code of conduct, purpose specification (Extension 1) and data treatment sections (Extension2) with a transparency code of practice.

specified by industry, trade associations and civil registries (referred to as code of conduct as it references the legal requirements).

This can be further extended (Internationally) where the filed data, categories, vocabulary, ontology and record formats are specified (to be hosted by a non-national regulatory body) to enable decentralized data exchange governance at a global scale.
[Note: The appendices introduce the new elements found in this specification, as well as a schema map for interoperability with ISO/IEC 27560 for contribution.]

Acknowledgements

• Kantara Community, DIACC, ToiP, W3C DPV and Consent

• The ISO/IEC 27560 committee

• Standards Council of Canada

• PasE; Consent Gateway Team and the NGI – Next Generation Internet Grant contribution

References

[Conv 108+] Council of Europe, Convention 108 +

[GDPR] General Data Protection Regulation, www.eugdpr.org/article-summaries.html

[ISO 29100:2011] Information technology -- Security techniques -- Privacy framework. http://www.iso.org/iso/iso_catalogue/catalogue_tc/catalogue_detail.htm?csnumber=45123

[ISO 639] ISO 639-1:2002, Codes for the representation of names of languages — Part 1: Alpha-2 code http://www.iso.org/standard/22109.html

[Kantara Initiative] Blinding Identity Taxonomy [BiT]

[Kantara Initiative] Consent Receipt v1.1

[OECD] OECD Guidelines on the Protection of Privacy and Transborder Flows of Personal Data. http://www.oecd.org/sti/ieconomy/oecdguidelinesontheprotectionofprivacyandtransborderflowsofpersonaldata.htm

[RFC 2119] Bradner, S., “Key words for use in RFCs to Indicate Requirement Levels”, BCP 14, RFC 2119, DOI 10.17487/RFC2119, March 1997 http://www.rfc-editor.org/info/rfc2119

Click through to no cost license standards.iso.org/ittf/PubliclyAvailableStandards/c045123_ ISO_IEC_29100_2011.zip

Annex (WiP to v8.9.9)

ANNEX A : ANCR OPERATIONAL SCHEMA

ANCR Record Schema

This ANCR Record uses a record data type for MySQL as the example data type for records, unlike consent notice receipt tokens, which use jason-ld web-token data types. (PII ConISO/IEC 28184 Annex B: Consent [Notice] Receipt)

The Notice Record uses data types for a record in a database, this maps to MySQL, unlike the consent receipt which uses JSON token data types.

Terms and Definitions

Attribute Name

data types, for attribute … machine readable element

• Array [attribute type]: a data type that defines a structure that holds several data items or elements of the same data type. When you want to store many pieces of data that are related and have the same data type, it is often better to use an array instead of many separate variables (e.g. array[text], array[numeric], etc.).

• Binary: a data type that defines a binary code signal, a series of electrical pulses representing numbers, characters, and performed operations. Based on a binary number system, each digit position represents a power of two (e.g., 4, 8, 16, etc.). In binary code, a set of four binary digits or bits represents each decimal number (0 to 9). Each digit only has two possible states: off and on (usually symbolised by 0 and 1). Combining basic Boolean algebraic operations on binary numbers makes it possible to represent each of the four fundamental arithmetic operations of addition, subtraction, multiplication, and division.

• Boolean: a data type where the data only has two possible variables: true or false. In computer science, Boolean is an identification classifier for working out logical truth values and algebraic variables.

• DateTime: a data type that defines the number of seconds or clock ticks that have elapsed since the defined epoch for that computer or platform. Common formats (see 'Format Overlay') include dates (e.g., YYYY-MM-DD), times (e.g., hh:mm:ss), dates and times concatenated (e.g., YYYY-MM-DDThh:mm:ss.sss+zz:zz), and durations (e.g., PnYnMnD).

• Document Reference

• Element Reference

• Field Category

• Field Description

• Field Label

• Numeric: a data type that defines anything of, relating to, or containing numbers. The numbering system consists of ten different digits: 0, 1, 2, 3, 4, 5, 6, 7, 8, and 9.

• Reference: a data type that defines a self-addressing identifier (SAID) that references a set of attributes through its associated parent. SAID is an identifier that is deterministically generated from and embedded in the content it identifies, making it and its data mutually tamper-evident.

• Text: a data type that defines a human-readable sequence of characters and the words they form, subsequently encoded into computer-readable formats such as ASCII.