Use Case: Basic Site Registration

Reference #: UC_CR_001

Brief Description

A web user provides information to a web site for the purpose of creating a persistent user identity on that site. The web site collects the information provided by the user and provides the user with a consent receipt to record the information transaction.

Actors

Alice: Alice is the web user seeking to make use of the information or services provided by the web site on which she is registering.

Bob: Bob is the person or organization that is accountable for the operation of the web site.

Stakeholders and Interests

Data Protection Authority (DPA): The competent authority or authorities that have jurisdiction over the operation of the web site in this use case. This is the authority to which Bob will be accountable and to which Alice could raise issues or complaints.

Pre-Conditions

The following conditions must be true before this Use Case can be executed:

1. The connection between Alice and Bob is reasonably secure - that is to say that Bob has provision the security level appropriate for the sensitivity of the data that Alice has been asked to provide.
2. Alice is using a standards compliant web browser
3. Bob has a web privacy notice on a URL accessible to Alice
4. Alice has provided the information necessary for Bob to register her chosen identity on his web site.
5. Alice has consented to the collection, use and disclosure of the information she has provided for the purposes identified in Bob’s web privacy notice.

Post Conditions

Success end condition

• Bob has generated and retained a copy of the information contained in a consent receipt.
• Alice has seen and been presented with the opportunity to save a local copy of the consent receipt
• Bob has logged the presentation of the consent receipt to Alice.

Failure end condition

• Alice does not receive a consent receipt
• Bob retains more information about Alice than is necessary for the purposes of web registration.

Minimal Guarantee    

Alice is registered as a user on Bob’s web site and has been presented with a consent receipt that allows her to understand what information about her has been collected, the purposes for that data collection, how the information will be used, whether or not the information will be disclosed to third parties and for how long the information will be retained.

Trigger

The creation and presentation of a consent receipt is triggered when Alice consents to the collection of her information for site registration.

Event Flows

Conformance Mode 1 (Human Readable)

1. Alice is asked for consent to the collection of her information to register her on the site.
2. Alice consents to the collection of her information.
3. Bob generates or gathers the information necessary for a consent receipt
4. Bob presents Alice with the consent receipt. Options for presentation include
   1. Displayed as a web page or web pop up that Alice can choose to print and/or save locally.
   2. Deliver as a link to a unique persistent web document (i.e. a Google Doc) that Alice can choose to print and/or save locally.
   3. Delivered as a PDF document that Alice can choose to print and/or save locally.
5. Bob confirms that Alice has been presented with the consent receipt and stores a copy for reference.
6. Bob logs the events necessary to demonstrate the creation and presentation of the consent receipt to Alice.

Conformance Mode 2 (Machine Readable)

Mode 2 is the same basic flow as Mode 1, with additions noted below in bold.

1. Alice is asked for consent to the collection of her information to register her on the site.
2. Alice consents to the collection of her information.
3. Bob gathers the information necessary for a consent receipt
4. Bob generates a JSON object containing the specifics of this consent receipt.
5. Bob presents Alice with the consent receipt, including the JSON object. Options for presentation include
   1. Displayed as a web page or web pop up that Alice can choose to print and/or save locally.
   2. Displayed as a link to a unique persistent web document (i.e. a Google Doc) that Alice can choose to print and/or save locally.
   3. Delivered as a PDF document that Alice can choose to print and/or save locally.
   4. If Alice has a browser or a browser add-on, that software may present the consent receipt as above and store the JSON object for Alice to enable consent receipt management
6. Bob confirms that Alice has been presented with the consent receipt and stores the JSON object for reference.
7. Bob logs the events necessary to demonstrate the creation and presentation of the consent receipt to Alice.

UML Use Case Diagram

Assumptions

• Alice has access to Bob’s web privacy notice and may have read it.
• Bob will process the information collected from Alice only for the purposes identified in his web privacy notice.
• Bob will protect the information collected with security consistent with the sensitivity of the information and according to the commitments made in his web privacy notice.
• Alice will be presented a copy of the consent receipt irrespective of whether or not Bob uses conformance mode 1 or mode 2.

Special Requirements or Guidance for Implementers

Other Information

Depending on the regulatory environment in which Bob operates, or because of internal policies, Bob may wish to include information in the consent receipt beyond the information (mode 1) or fields (mode 2) that have been specified. The guidance in this case to implementers is this:

An implementer of consent receipts (Bob) may include additional information in the consent receipt, and still conform to the consent receipt standard, except where such information negates, contradicts or invalidates information required in the consent receipt.

Security

The information security measures used to protect the confidentiality, integrity and availability of consent receipts should not be less than the measures used to protect the information referred to by the consent receipt.

Privacy

Consent receipts should be assumed to be personally identifiable information about the person who has provided the consent.

Issues

Tasks

• Type task here and @mention a user to assign them the task

Appendices

A. Consent Receipt Contents (Mode 1 Conformance)

Link to be provided

B. Consent Receipt JSON Specification (Mode 2 Conformance)

Link to be provided

C. Sample Consent Receipt

Link to be provided or graphic added