Best Practices in Federated identity scenarios Francisco DE QUINTO2 , Manel MEDINA1 TB-Security, Gran Capitán, 2, 08034-Barcelona, Spain Tel: +34-934054232, Fax: +34-034054231, Email: mmedina@tb-security.com 2 pdequinto@tb-security.com 1 Abstract: The present paper describes legal, societal and business requirements that should be fulfilled by heterogeneous Circles of Trust (CoT), according to the specifications issued within the Liberty Alliance Project (LAP) and the recommendations derivate from the work done within the CELTIC, FIDELITY project. This project has set up four CoTs, each of them in a different European country. The 3 viewpoints followed to find out the requirements, provide multiple perspectives; which result in an implementation acceptable by all relevant actors: lawyers, business managers and end users. The proposed guidelines range from service level agreements to be signed between collaborating web service providers and consumers, to disclaimers and legal notices to be shown to end users accessing the services. These guidelines are part of a Code of Practice to be promoted within the Liberty Alliance users, to guarantee compliance of Personal Data Protection, as well as e-Commerce and e-Signature legislations by all involved actors sharing personal and financial data. 1. Introduction and objectives The scenarios of services provided to mobile users, have an enormous potential of deployment, which is directly conditioned by the creation of a service that fulfils the needs of the users, being at the same time: attractive, transparent and secure; including in the security issue the scrupulous fulfilment of the legal requirements in the scopes of: Privacy, e-commerce, telecommunications and e-signature. The Fidelity project has implemented one of these kinds of service provision networks of agents, known as Circle of Trust (CoT), according to the Liberty Alliance specifications (Fig. 1), and has demonstrated its interest and efficiency from both, business earnings and usability viewpoints. The creation of identity management Business Servic agreement e Attribu frameworks and federated identity Provid te er communities is intended, among other Provid Discov er things, to enhance the speed and ery Servic Identit convenience of online interactions and e y Servic Provid Provid transactions, through features such as single Attribue er er te sign-on and sign-off. The LAP defines Provid er specific components to ease the discovery of attribute and web service providers Fig. 1: Circle of Trust components. which are ready to share information about individuals, within federated communities, created around an Identity Provider. Examples of Service providers that may share users’ attributes are: Find near Restaurant, Book a Hotel room, Purchase a Game, Student interchange, etc. Those scenarios have been defined by LAP and implemented by Fidelity. Within this framework, the main Objective of the Fidelity Project (Federated Identity Management based on Liberty) is to implement and promote the evolution of the Liberty Alliance specifications. The Fidelity Project integrates technical, legal and business requirements for the full deployment of a multi-CoT scenario of services. Fidelity has set up four CoT,s that interact one each other, with base of operation in Norway, Finland, France and Spain. The current paper focuses on the description of the requirements that a CoT must follow, from three perspectives: Strictly legal requirements (disclaimer) on personal data privacy and recommendations for users (legal notice) Approximation to the requirements coming from the Society, in an EU environment. Incorporation of the above requirements into diverse business scenarios. The main objective of this paper is the justification and introduction of some guidelines to create a Code of Best Practices of the CoT, which must be structured in a simple, brief and accessible way, and that will work like a Constitution (rights and obligations) of all the parties that interact in the CoT. The law goal is to achieve legality (technology), whilst the Best Practices one is to reach the excellence of the environment and of the agents involved. As a consequence of the juridical system, the most of the social demands have already been reflected in the current laws and must be efficiently published, to guarantee the citizens enough knowledge of them (informative transfer). It is the only way to win confidence within the users’ community. The main demands expressed by the European society regarding the use of the ITC are the following: 1. Privacy, digital identity management and personal data protection. 2. Attention and care of the minors. 3. Protection of the rights of the consumers (quality). 4. Protection of the contents (intellectual property). 5. Trustability of the information (no deceptive or illicit publicity). 6. Spam prohibition and control. 2. Legal requirements In this section we explain the requirements to be followed by the actors involved in service provision that are consequences of the applicable legislation regarding the relevant areas: Personal Data Protection, e-Signature, e-Commerce and Telecommunications. 2.1 -Legal framework The EU Directives are relevant to the CoT operation because they determine the minimum mandatory constrains about service provision as a set of Best Practices that regulate the interaction between the actors, of the information and of the services: European Union Directive on Data Protection of individuals with regard to the processing of personal data and the free movement of such data. European Union Directive concerning the processing of personal data and the protection of privacy in the electronic communications sector. Directive 2006/24/EC of the European Parliament and of the Council of 15 March 2006 on the retention of data generated or processed in connection with the provision of publicly available electronic communications services or of public communications networks and amending Directive 2002/58/EC. Directive 1999/93/EC of the European Parliament and of the Council of 13 December 1999 on a Community framework for electronic signatures. Directive 2000/31/EC of the European Parliament and of the Council of 8 June 2000 on certain legal aspects of information society services, in particular electronic commerce, in the Internal Market (Directive on electronic commerce). 2.2 -Personal data types Each kind of data requires a different level of protection in order to ensure privacy. The aim of the differentiation of the kinds of data is to establish a hierarchy, a bottom-up approach to find technical constraints and security measures, that each of the actors must implement in their data processes and management. Personal data may be of 5 types: Private: The most Highly sensitive data, includes, for example: religion, politic and trade unions preferences, medical records, philosophic convictions Personality: Basically economic and patrimonial, this information is also given special treatment by some national legislation, because it may be used to draw a psychological profile of the person. The most common kinds of financial information are: Company information: Name, address, business identity code. Information related to employee: Occupation, status, title, duration of the employment, personal information. Personal: This level is related to the data defined as 'personal data': it shall mean any information related to an identified or identifiable natural person ('data subject'). National: Public information that may be distributed at National or EU level. The most common kinds of national information are: Information publicly known: nationality, any other published information. Shared: Published information about the citizens, which may be distributed anywhere without restrictions. The most common kinds of Shared information are: agreements between CoTs and technical information shared between CoTs. 2.3 -Security levels Depending on the data type, the EU Directive establishes different security levels. Protection Level Type of data Basic All personal data Medium Data relative to administrative and penal infractions, economic solvency, fiscal information and personality profiles Data relative to religion, ideology, trade unions membership, sexual life, race and health High Security measures Security document, access control, incidences and back-up copies. Security designated responsible person, permanent update of the security document, audit of data protection every two years. Users must be identified and authenticated when accessing the data. When distributing media and transferring documentation, the data must be encrypted so that it can not be manipulated or read. There must be back-up copies of this data in a different location where the data is kept. 2.4 -Legal requirements Principal’s consent: It depends on the kind of the data. Sensitive data requires explicit consent, whilst personal and financial data require unambiguous consent. National and Shared data don’t require any consent from the user (Art. 7 &8 of [12]). Principal’s rights: They must be granted; access, cancellation; opposition and rectification. See Article 12 of [12]. Security measures: In general, Security Policy. Private data must be encrypted, while financial data needs a security policy with a responsible officer. There must be periodic Security Audits. Check Article 17 of [12]. Data transfer: The inter-CoT data transfers must be accompanied by notification to the Central Authority. The transfers within EU States must obey the rules as above, while the transfers to third countries need explicit consent from the principal. Check Articles 18, to 21 of [12]. 2.5 -Disclaimer and legal notice The CoT actors must make public the characteristics of the data they are processing by means of a Legal Notice or a Disclaimer: A Legal Notice is important because it is the element that adds transparency to the user of the Inter-CoT structure, by informing him/her of his/her rights and corresponding obligations of all the providers that integrate the structure. The consequence of this transparency policy is to earn the confidence of the final user. A Disclaimer is important because it limits the legal liability of the providers, integrating the Inter-CoT with respect to the users. Both kinds of texts, in order to reach operative and juridical effectiveness, must be shown to the user constantly, easily, directly and free of charge. Common Legal Notice for all functional components: A- When asking for consent from the user, he/she must be informed (according to Article 7 and 10 of [12]) about the following issues: Purpose and processing of the data for the information, administration, development, and cancellation of the services (Article 6.1 of [12] and Article 4 of [16]). Distribution: strictly subject to the scope of the purpose and processing (Article 7 (f) of [12] and Article 11 of [16]). Protection of the data: Measures of security according to the sensibility level of the data (Article 17 of[12] and Article 9 of [16]). Granting the right of access, modification, objection and cancellation: Always in an easy and free-of-charge way (Articles 12, to 14 of [12] and Articles 13 to 19 of [16]). Conservation of the data: As long as it is necessary for the finality, which the consent was given to. From then on, the data is blocked and must be kept for a period in which it may be derived and liability based on the processing or usage (Article 6 (b) [12]). B- If the data is acquired through another way than the end user (public access source), the origin of the data must be communicated to the user (Article 11 of [12]). Common Disclaimer for all functional components: All the entities that participate in this Circle of Trust (IdP, SP,…) fully adhere with no rejections to the Code of Privacy and Security Best Practices from LAP that regulates the CoT and declines any liability related to usage and behaviour of the users. 3. Business requirements Once seen the “must” requirements emerging from the European and national legislations, this section introduces the requirements imposed by the commercial entities involved in the CoT to the other actors collaborating in building the service for the end user, to guarantee their liability limits and quality of the overall service provided. We start with the description of the types of actors involved in a CoT, from the business viewpoint, and end with the requirements that all of them have to meet. 3.1 -The roles of Inter-CoT functional components Home and Visited Identity provider As defined by Liberty specifications, the identity provider (IdP) is the central component in a CoT which manages identity information on behalf of end-users or systems and provides assertions of end-users or systems authentication to other components. IdPs will most probably have several additional roles: Attribute Provider (AP), Service/Content Provider (SP/CP), Discovery Service Provider (DS), initial registration entity and proxy of identity or personal information provider Service provider The service provider (SP) component is typically a website or a web service which provides end-users or systems services and/or goods. For this purpose, the service provider may have to interact with other components in order to retrieve identity information of end-users or systems. Service/Content providers are typically third party companies: an IdP can also be a SP/CP, SPs/CPs usually have an agreement with IdP and SPs/CPs do not necessarily have agreements with end users or APs. In their relationships with other actors, SP may take also the role of: WSC Web service Consumer and WSP Web service Provider. Attribute provider The attribute provider (AP) stores and provides end-user’s information to other components (mainly SPs) according to rules and agreements defined with end-users. It is worth noting that this definition is slightly different from the one given in the Liberty specifications: “An attribute provider (AP) provides Identity Personal Profile (IDPP) information”. In this document, the term attribute provider may be used for all components which provide any kind of identity information (personal, geolocation, presence …). Attribute providers could be individual companies or IdPs: it has agreements with an IdP(s), it has agreements with end users and it possesses specific information about the user. Discovery service The discovery service component facilitates the registration and the discovery of identity service instances, which maintain information about or on behalf of end-users, or perform actions on behalf of end-users. For example, the discovery service is requested by a service provider to retrieve the attribute provider which stores the required information about the user. Web service consumer A role performed by a system entity when it makes a request to a web service. In Fidelity project, a web service consumer (WSC) is a service provider accessing another functional component. Web service provider A role performed by a system entity when it provides a web service. In Fidelity project, the attribute provider plays the role of a web service provider (WSP). End User / Principal / Data Subject End user is always a natural person. End user could be a private person or an employee in a corporate body. End user could have agreements between different parties in the service chain, but with the IdP at the minimum. According to Article 2 of EU Directive, all the functional components (except user/principal/data subject) can assume one of these two roles: a) Controller The controller is defined in the DPD to mean any person or entity which, alone or jointly with others, determines the purposes and means of processing personal data. It is generally the controller that is required to comply with data protection laws. In a federation, it is quite possible that more than one participant could be the controller in respect of any given transaction; It implies that a controller need not be in possession of the personal data concerned; it merely must exercise control over the processing. It envisages that who is controller may change from one data-processing operation to another, even within one information system. Participants in a CoT could quite possibly be playing different roles in respect of different transactions. b) Processor The processor is a person or entity that processes personal data on behalf of the controller. The processor merely carries out a processing operation on behalf of the controller, but does not determine the purposes or means of processing; control remains with the controller. Understanding the distinction between the roles of controller and processor is essential to understanding the impact of the DPD on the establishment of a CoT. 3.2 -Technical and management constraints to functional components Directives, national legislations and regulations impose some restrictions to the management and processing of data within the different functional components. Herein follows a summary of these restrictions, classified according to the security requirement imposed by the legislation: Integrity/ Accuracy: Accuracy and update of data must be guaranteed. Otherwise it must be erased or rectified. Availability: only the information needed for the accomplishment of the contract can be held. Transfer to third countries: must be done always with the consent from the principal and the authorisation of the Control Authority. Liability with respect to the data: it must be according to the clauses of the contracts, limited by the Disclaimer clause with respect to the user. Cancellation: the data must be cancelled once the contract has been terminated and once the responsibility terms derived from the contract have expired. The IdP must retain the data according to [15] on the retention of data generated or processed in connection with the provision of publicly available electronic communications services or of public communications networks and amending [13]. 4. Societal Requirements To finish, we have seen the requirements made by the end users of the services (the principals), and those imposed by the managers of the applications that allow to provide them, to preserve the users’ rights and expected quality of service, mainly from the privacy viewpoint. 4.1 -Identity Management It focus on the Identity Provider (IdP) as an entity that creates, maintains and manages identity information for principals and provides principal authentication to other service providers within a CoT. The management of the federated identity allows several privacy levels: Anonymity enables service to request certain attributes without needing to know the user’s identity. Pseudonyms (obfuscated identity) are arbitrary names assigned by the IdP to identify a principal to a given relying party so that the name has meaning only in the context of the relationship between the relying parties. Authentication: a set of information that enables the identification of a person. Strong authentication: The electronic data annexed to other electronic data or associated in a logic way with it (authentication token). Non Repudiation: The electronic data annexed to other electronic data and to be used as an authentication mean, in such a way that any alteration of them can be detectable (PKI authentication). 4.2 -Scenarii requirements Herein follows a list of the data exchanged in the different scenarii implemented in the CoTs according to Fidelity model. Data types have been classified according to Liberty Alliance document “Circles of Trust: The Implications of EU Data Protection and Privacy Law for Establishing a Legal Framework for Identity Federation”. Traffic and Geo-location data may be considered Personal attributes, if they can be used to identify a Principal, as a real person or as a particular user of the telecommunication or web services (traceable).: Book a hotel: the classic personal data is processed (name, address), sensitive data like preferences and traffic data like Service Data Record is also handled. The service produces geo-location information (where the hotel is during the stay). The chosen payment means and credit card number are personal data. Download a game: personal data as above is used, as well as preferences (for specific games,…) and traffic data such as terminal and access network features. Again, payment means are personal data. Call a contact: Communications VoIP; SIP addresses. Personal data, basic security level. Search a near restaurant: preferences for the kind of diet (sensitive data). High security level. Express content from the principal needed. Student exchange service: the classic personal data, as above; and sensitive data, such as scholar records, recommendation letters… High security level and express consent from the principal is needed. Register with a mobile: classic personal data. Basic security level and tacit consent. Healthcare: sensitive data, high security level and express consent from the principal. Hire a credit card: financial data, medium security level and tacit consent. Buy a flight: classic personal data, tacit consent and basic security level. 5. Conclusions This paper is a clear exponent of how the convergence, between Law & Technology turns out to be efficient to reach a delicate balance, between society security and the fundamental citizen rights (freedom and privacy). The requirements about personal data protection impose both: technical mechanisms to protect the data by the applications used to manage them (mainly encryption, data access control and logs, security policy), as well as administrative ones (contract agreements). The latter ones are mainly addressed to guarantee the adequate control on the liability of the agents involved in a service provision in an international scenario. This liability guarantee will promote the deployment of advanced e-services, thanks to the confidence of both: telecom operators and other e-service providers, that will trust on their effective limited liability when sharing personal data, and end users, that will not fear providing their personal data to providers that will have a formal compromise to preserve their privacy on the behalf of the citizen, all over the life of the service provision cycle. All requirements on service provision claimed by citizens (societal requirements), are already claimed by Lawyers. Business requirements have the main objective to guarantee the share of benefits and liability in the use of personal data and attributes and in the quality of the service offered. There is a great level of convergence of legislation regarding Personal Data, e-Commerce and e-Signature usage in most of the EU countries. 6. References [1] www.projectliberty.org [2] http://www.celtic-fidelity.org [3] Introduction to the Liberty Alliance Identity Architecture – Liberty Alliance [4] Business Benefits of Federated Identity – Liberty Alliance [5] Liberty Alliance ID-FF 1.2 Specifications [6] Liberty Alliance ID-WSF 1.1 Specifications [7] Liberty Alliance ID-SIS 1.0 Specifications [8] Circles of Trust: the implications of EU Data Protection and Privacy Law for establishing a legal framework for Identity Federation [9] Privacy and Security Best Practices . http://www.projectliberty.org/specs/final_privacy_security_best_practices.pdf [10] Liberty ID-WSF Security and Privacy Overview . https://www.projectliberty.org/specs/liberty-idwsf-security-privacy-overview-v1.0.pdf [12] 95/46/EC Directive on the protection of individuals with regard to the processing of personal data and on the free movement of such data. [13] 2002/58/EC Directive concerning the processing of personal data and the protection of privacy in the electronic communications sector (Directive on privacy and electronic communications) [14] 2000/31/EC Directive on certain legal aspects of information society services, in particular electronic commerce, in the Internal Market (Directive on electronic commerce) [15] 2006/24/EC Directive on the retention of data generated or processed in connection with the provision of publicly available electronic communications services or of public communications networks and amending Directive 2002/58/EC. [16] the Spanish Law 15/1999: Ley Orgánica para la Protección de Datos Personales.