Categories: risk-management • procedure • enforce • create

Federated Privacy Impact Assessment

Contents

Summary

The impact of personal information in a federation is more than the impact in the federated

Context

Identity Management scenarios (that is, when the roles of the Identity Provider and the Service Provider are separated).

Problem

Identity Management solutions were introduced to decouple the functions related to authentication, authorization, and management of user attributes, on the one hand, and service provision on the other hand. Federated Identity Management allows storing a data subject's identity across different systems. All together, these form a Federation that involves complex data flows.

Federated Management solutions can be used to improve privacy (e.g. by allowing service providers to offer their services without knowing the identity of their users). However, the complexity of data flows and the possibility of collusion between different parties entail new risks and threats regarding personal data.

Solution

A Privacy Impact Assessment is conducted by all the members of the federation, both individually and in conjunction, so as to define shared privacy policies, prove they are met, and demonstrate the suitability of the architecture, in the benefit of all the members.

Deal with privacy risks associated from the federation of different parties in an Identity Management solution.

Consequences

The consequences depend on the results of the privacy-impact analysis.

Examples

An Identity Provider issues pseudonyms to authenticate users at third-party Service Providers, which can in turn check the authenticity of these pseudonyms at the Identity Provider, without getting to know the real user identity. However, the Identity Provider knows all the services requested by the users, which discloses personal information to the Identity Provider and allows it to profile the users.

[Known Uses]

The New Federated Privacy Impact Assessment (F-PIA). Building Privacy and Trust-enabled Federation. Information and Privacy Commissioner of Ontario & Liberty Alliance Project, January 2009