The Platform for Privacy Preferences 1.0 (P3P1.0) Specification

W3C Working Draft 10 May 2000

This Version:: http://www.w3.org/TR/2000/WD-P3P-20000510
Latest Version:: http://www.w3.org/TR/P3P
Previous Version:: http://www.w3.org/TR/2000/WD-P3P-20000424
Editor:: Massimo Marchiori, W3C/MIT, (massimo@w3.org)
Authors:: Lorrie Cranor, AT&T; Marc Langheinrich, ETH Zurich; Massimo Marchiori, W3C/MIT; Martin Presler-Marshall, IBM; Joseph Reagle, W3C/MIT

Abstract

This is the specification of the Platform for Privacy Preferences (P3P). This document, along with its normative references, includes all the specification necessary for the implementation of interoperable P3P applications.

Status of This Document

This section describes the status of this document at the time of its publication. Other documents may supersede this document. The latest status of this document series is maintained at the W3C.

This is a W3C Working Draft for review by W3C members. This document has been produced by the P3P Specification Working Group as part of the P3P Activity, and it is the fourth revision of the last call draft issued the 2nd of November 1999 (http://www.w3.org/TR/1999/WD-P3P-19991102). A change log is included at the end of this document for convenience. This call addresses the comments received during the Last Call period, which ended April 30, 2000. A revised version of this specification is expected to advance toward W3C Recommendation status after two interoperable implementations have been demonstrated.

This document is a draft document that may be updated, replaced, or obsoleted by other documents at any time. It is therefore inappropriate to use W3C Working Drafts as reference material or to cite them as other than "work in progress." A list of current W3C working drafts can be found at http://www.w3.org/TR/.

Please send comments to www-p3p-public-comments@w3.org (archived at http://lists.w3.org/Archives/Public/www-p3p-public-comments/). Alternatively, if you do not wish your comment to be made public, you can send your comments to p3p-comments@w3.org. In this case, your comments will only be accessible to W3C members (at http://lists.w3.org/Archives/Member/p3p-comments/).

Introduction
Referencing Policies
Policy Syntax and Semantics
Data Schemas
Appendices
Appendix 1: References (Normative)
Appendix 2: References (Non-normative)
Appendix 3: The P3P Base Data Schema Definition (Normative)
Appendix 4: XML Schema Definitions (Normative)
Appendix 5: XML DTD Definition (Normative)
Appendix 6: ABNF Notation (Non-normative)
Appendix 7: P3P Guiding Principles (Non-normative)
Appendix 8: Working Group Contributors (Non-normative)

1. Introduction

The Platform for Privacy Preferences Project (P3P) enables Web sites to express their privacy practices in a standard format that can be retrieved automatically and interpreted easily by user agents. P3P user agents will allow users to be informed of site practices (in both machine- and human-readable formats) and to automate decision-making based on these practices when appropriate. Thus users need not read the privacy policies at every site they visit.

Although P3P provides a technical mechanism for ensuring that users can be informed about privacy policies before they release personal information, it does not provide a technical mechanism for making sure sites act according to their policies. Products implementing this specification MAY provide some assistance in that regard, but that is up to specific implementations and outside the scope of this specification. However, P3P is complementary to laws and self-regulatory programs that can provide enforcement mechanisms. In addition, P3P does not include mechanisms for transferring data or for securing personal data in transit or storage. P3P may be built into tools designed to facilitate data transfer. These tools should include appropriate security safeguards.

1.1 The P3P1.0 Specification

The P3P1.0 specification defines the syntax and semantics of P3P privacy policies, and the mechanisms for associating policies with Web resources. P3P policies consist of statements made using the P3P vocabulary for expressing privacy practices. P3P policies also reference elements of the P3P base data schema -- a standard set of data elements that all P3P user agents should be aware of. The P3P specification includes a mechanism for defining new data elements and data sets, and a simple mechanism that allows for extensions to the P3P vocabulary.

1.1.1 Goals and Capabilities of P3P 1.0

P3P version 1.0 is a protocol designed to inform Web users of the data-collection practices of Web sites. It provides a way for a Web site to encode its data-collection and data-use practices in a machine-readable XML format known as a P3P policy. The P3P specification defines:

A standard schema for data a Web site may wish to collect, known as the "P3P base data schema"
A standard set of uses, recipients, data categories, and other privacy disclosures
An XML format for expressing a privacy policy
A means of associating privacy policies with Web pages or sites
A mechanism for transporting P3P policies over HTTP

The goal of P3P version 1.0 is twofold. First, it allows Web sites to present their data-collection practices in a standardized, machine-readable, easy-to-locate manner. Second, it enables Web users to understand what data will be collected by sites they visit, how that data will be used, and what data/uses they may "opt-out" of or "opt-in" to.

1.1.2 Example of P3P in Use

As an introduction to P3P, let us consider one common scenario that makes use of P3P. Sheila has decided to check out a store called CatalogExample, located at http://www.catalog.example.com/. Let us assume that CatalogExample has placed P3P policies on all their pages, and that Sheila is using a Web browser with P3P built in.

Sheila types the address for CatalogExample into her Web browser. Her browser is able to automatically fetch the P3P policy for that page. The policy states that the only data the site collects on its home page is the data found in standard HTTP access logs. Now Sheila's Web browser checks this policy against the preferences Sheila has given it. Is this policy acceptable to her, or should she be notified? Let's assume that Sheila has told her browser that this is acceptable. In this case, the homepage is displayed normally, with no pop-up messages appearing. Perhaps her browser displays a small icon somewhere along the edge of its window to tell her that a privacy policy was given by the site, and that it matched her preferences.

Next, Sheila clicks on a link to the site's online catalog. The catalog section of the site has some more complex software behind it. This software uses cookies to implement a "shopping cart" feature. Since more information is being gathered in this section of the web site, the Web server provides a seperate P3P policy to cover this section of the site. Again, let's assume that this policy matches Sheila's preferences, so she gets no pop-up messages. Sheila continues and selects a few items she wishes to purchase. Then she proceeds to the checkout page.

The checkout page of CatalogExample requires some additional information: Sheila's name, address, credit card number, and telephone number. Another P3P policy is available that describes the data that is collected here and states that her data will be used only for completing the current transaction, her order.

Sheila's browser examines this P3P policy. Imagine that Sheila has told her browser that she wants to be warned whenever a site asks for her telephone number. In this case, the browser will pop up a message saying that this Web site is asking for her telephone number, and explaining the contents of the P3P statement. Sheila can then decide if this is acceptable to her. If it is acceptable, she can continue with her order; otherwise she can cancel the transaction.

Alternatively, Sheila could have told her browser that she wanted to be warned only if a site is asking for her telephone number and was going to give it to third parties and/or use it for uses other than completing the current transaction. In that case, she would have received no prompts from her browser at all, and she could proceed with completing her order.

Note that this scenario describes one hypothetical implementation of P3P. Other types of user interfaces are also possible.

1.1.3 P3P Policies

P3P policies use an XML encoding of the P3P vocabulary to identify the legal entity making the representation of privacy practices in a policy, enumerate the types of data or data elements collected, and explain how the data will be used. In addition, policies identify the data recipients, and make a variety of other disclosures including information about dispute resolution, and the address of a site's human-readable privacy policy. P3P policies must cover all relevant data elements and practices (but note that legal issues regarding law enforcement demands for information are not addressed by this specification; it is possible that a site that otherwise abides by its policy of not redistributing data to others may be required to do so by force of law). P3P declarations are positive, meaning that sites state what they do, rather than what they do not do. The P3P vocabulary is designed to be descriptive of a site's practices rather than simply an indicator of compliance with a particular law or code of conduct. However, user agents may be developed that can test whether a site's practices are compliant with a law or code.

P3P policies represent the practices of the site. Intermediaries such as telecommunication providers, Internet service providers, proxies and others may be privy to the exchange of data between a site and a user, but their practices may not be governed by the site's policies.

1.1.4 P3P User Agents

P3P1.0 user agents can be built into web browsers, browser plug-ins, or proxy servers. They can also be implemented as Java applets or JavaScript; or built into electronic wallets, automatic form-fillers, or other user data management tools. P3P user agents look for P3P headers in HTTP responses and in P3P LINK tags embedded in HTML content. These special headers and tags indicate the location of a relevant P3P policy. User agents can fetch the policy from the indicated location, parse it, and display symbols, play sounds, or generate user prompts that reflect a site's P3P privacy practices. They can also compare P3P policies with privacy preferences set by the user and take appropriate actions. P3P can perform a sort of "gate keeper" function for data transfer mechanisms such as electronic wallets and automatic form fillers. A P3P user agent integrated into one of these mechanisms would retrieve P3P policies, compare them with user's preferences, and authorize the release of data only if a) the policy is consistent with the user's preferences and b) the requested data transfer is consistent with the policy. If one of these conditions is not met, the user might be informed of the discrepancy and given an opportunity to authorize the data release themselves.

1.1.5 Implementing P3P1.0 on Servers

Web sites can implement P3P1.0 on their servers by translating their human-readable privacy policies into P3P syntax and then publishing the resulting files. Automated tools can assist site operators in performing this translation. P3P1.0 can be implemented on existing HTTP 1.1-compliant Web servers without requiring additional or upgraded software. Servers may publish their privacy policies at a well-known location, or they may reference their P3P policies in HTML content using a LINK tag. Alternatively, compatible servers may be configured to insert a P3P extension header into all HTTP responses that indicates the location of a site's P3P policy, using the HTTP Extension Framework.

Web sites have some flexibility in how they use P3P: they can opt for one P3P policy for their entire site or they can designate different policies for different parts of their sites. A P3P policy MUST cover all data generated or exchanged as part of a site's HTTP interactions with visitors. In addition, some sites may wish to write policies that cover all data an entity collects, regardless of how the data is collected.

1.1.6 Future Versions of P3P

The P3P Specification Working Group removed significant sections from earlier drafts of the P3P1.0 specification in order to facilitate rapid implementation and deployment of a P3P first step. The group envisions the release of future versions of the P3P specification after P3P1.0 is deployed. This specification would likely include improvements based on feedback from implementation and deployment experience as well as four major components that were part of the original P3P vision but not included in P3P1.0:

a mechanism to allow sites to offer a choice of P3P policies to visitors
a mechanism to allow visitors (through their user agents) to explicitly agree to a P3P policy
mechanisms to allow for non-repudiation of agreements between visitors and web sites
a mechanism to allow user agents to transfer user data to services

1.2 About this Specification

This document, along with its normative references, includes all the specification necessary for the implementation of interoperable P3P applications.

The [ABNF] notation used in this specification is specified in RFC2234 and summarized in Appendix 7. However, note that such syntax is only a grammar representative of the XML syntax: all the syntactic flexibilities of XML are also implicitly included; e.g. whitespace rules, quoting using either single quote (') or double quote ("), character escaping, comments, case sensitivity, order of attributes.

The following key words are used throughout the document and should be read as interoperability requirements. This specification uses words as defined in RFC2119 [KEY] for defining the significance of each particular requirement. These words are:

MUST or MUST NOT: This word or the adjective "required" means that the item is an absolute requirement of the specification.
SHOULD or SHOULD NOT: This word or the adjective "recommended" means that there may exist valid reasons in particular circumstances to ignore this item, but the full implications should be understood and the case carefully weighed before choosing a different course.
MAY: This word or the adjective "optional" means that this item is truly optional. One vendor may choose to include the item because a particular marketplace requires it or because it enhances the product, for example; another vendor may omit the same item.

1.3 Terminology

Character: Strings consist of a sequence of zero or more characters, where a character is defined as in the XML Recommendation [XML]. A single character in P3P thus corresponds to a single Unicode abstract character with a single corresponding Unicode scalar value (see [UNICODE]).
Data Element: An individual data entity, such as last name or telephone number. For interoperability, P3P1.0 specifies a base set of data elements.
Data Category: A significant attribute of a data element or data set that may be used by a trust engine to determine what type of element is under discussion, such as physical contact information. P3P1.0 specifies base data categories.
Data Set: A known grouping of data elements, such as "user.home.postal". P3P1.0 specifies a number of base data schemas.
Equable Practice: A practice that is very similar to another in that the purpose, recipients, and identifiable use are the same or more constrained than the original, and the other disclosures are not substantially different. For example, two sites with otherwise similar practices that follow different -- but similar -- sets of industry guidelines.
Personally Identifiable Data: Any information relating to an identified or identifiable individual.
Policy: A collection of one or more privacy statements together with information asserting the identity, URI, assurances, and dispute resolution procedures of the service covered by the policy.
Practice: The set of disclosures regarding data usage, including purpose, recipients, and other disclosures.
Preference: A rule, or set of rules, that determines what action(s) a user agent will take. A preference might be expressed as a formally defined computable statement (e.g., the [APPEL] preference exchange language).
Purpose: The reason(s) for data collection and use.
Repository: A mechanism for storing user information under the control of the user agent.
Service: A program that issues policies and (possibly) data requests. By this definition, a service may be a server (site), a local application, a piece of locally active code, such as an ActiveX control or Java applet, or even another user agent.
Service Provider (Data Controller, Legal Entity): The person or legal entity which offers information, products or services from a Web site, collects information, and is responsible for the representations made in a practice statement.
Statement: A P3P statement is a set of privacy practice disclosures relevant to a collection of data elements.
URI: A Uniform Resource Identifier used to identify Web resources. For definitive information on URI syntax and semantics, see [URI]. URIs that appear within XML or HTML have to be treated as specified in [CHARMODEL], section Character Encoding in URI References. This does not apply to URIs appearing in HTTP header fields; the URIs there should always be fully escaped.
User: An individual (or group of individuals acting as a single entity) on whose behalf a service is accessed and for which personal data exists.
User Agent: A program whose purpose is to mediate interactions with services on behalf of the user under the user's preferences. A user may have more than one user agent, and agents need not reside on the user's desktop, but any agent must be controlled by and act on behalf of only the user. The trust relationship between a user and her agent may be governed by constraints outside of P3P. For instance, an agent may be trusted as a part of the user's operating system or Web client, or as a part of the terms and conditions of an ISP or privacy proxy.

1.4 Pending Changes

The working group has decided, based on input from implementation teams, that certain additional features are needed in P3P1.0. The working group has decided the additional features that are required, but has not completed its job of specifying those features as of the writing of this draft. The features are listed here as guidance to potential implementers:

A "mini-policy" feature in policy reference files. This feature will provide a way to provide a summary of a P3P policy, covering a very limited set of data elements, within a policy reference file.
The ability to include P3P policies inline in policy reference files. Currently, policy reference files specify the URL where a P3P policy can be found. An additional feature will be added allowing placing the text of the policy inside the policy reference file itself.

2. Referencing Policies

2.1 Overview and Purpose of Policy References

Referencing a P3P policy is one of the first steps in the operation of the P3P protocol. Services use policy references to state what policy applies to a specific URI or set of URIs. User agents will use policy references to locate the privacy policy which applies to a page, so that they can process that policy for the benefit of their user.

Policy references are used extensively as a performance optimization. Privacy policies are typically several kilobytes of data, while a URI that references a privacy policy is typically less than 100 bytes. In addition to the bandwidth savings, policy references also reduce the need for computation: policies can be uniquely associated with URIs, so that a user agent need only parse and process a policy once rather than process it with every document to which the policy applies. Furthermore, by placing the information about relevant policies in a centralized location, Web site administration is simplified.

2.1.1 Mechanisms

A policy reference file is used to associate a policy with a URI. The location of the policy reference file can be indicated using one of three mechanisms. The policy reference file may be located in a predefined "well-known" location, or a document may indicate a policy reference file through an HTML LINK tag, or through the HTTP Extension Framework. The policy reference file specifies the P3P policy that applies to that document, and possibly to other URIs as well. The policy reference file is an [RDF]/[XML] file that can specify the policy for a single Web document, portions of a Web site, or for an entire site. The policy reference file may refer to one or more P3P policies; this allows for a single reference file to cover an entire site, even if different P3P policies apply to different portions of the site.

Note that policies are applied at the level of HTTP entities. An entity, retrieved by fetching a URI, has a P3P policy associated with it. A "page" from the user's perspective may be composed of multiple HTTP entities; each entity may have its own P3P policy associated with it. As a practical note, however, placing many different P3P policies on different entities on a single page may make rendering the page and informing the user of the relevant policies difficult for user agents. Additionally, services SHOULD attempt to craft their policy reference files such that a single policy reference file covers any given "page"; this will speed up the user's browsing experience.

For a user agent to process the policy which applies to a given entity, it must locate the policy reference file for that entity, fetch the policy reference file, parse the policy reference file, fetch any required P3P policies, and then parse the P3P policy or policies.

This document does not specify how P3P policies may be associated with documents retrieved by means other than HTTP. However, it does not preclude future development of mechanisms for associating P3P policies with documents retrieved over other protocols.

2.2 Locating Policy Reference Files

This section describes the mechanisms used to indicate the location of a policy reference file. Detailed syntax is also given for the supported mechanisms.

2.2.1 Well-Known Location

Web sites using P3P may choose to place a policy reference file in a "well-known" location. To do this, a policy reference file would be placed in the root directory of the site, under the name p3p.xml. Thus a user agent could request this policy reference file by using a GET request for the resource /p3p.xml.

Note that sites are not required to use this mechanism. Additionally, if a site chooses to use this mechanism, the policy reference file located in the well-known location is not required cover the entire site. For example, sites where not all of the content is under the control of a single organization MAY choose not to use this mechanism, or MAY choose to post a policy reference file which only covers a limited portion of the site.

Use of the well-known location for a policy reference file does not preclude use of other mechanisms for specifying a policy reference file. Portions of the site MAY use any of the other supported mechanisms to specify a policy reference file, so long as the non-ambiguity requirements are met.

For example, imagine a shopping-mall Web site run by the MallExample company. On their Web site (mall.example.com), companies offering goods or services at the mall would get a company-specific subtree of the site, perhaps in the path /companies/company-name. The MallExample company may choose to put a policy reference file in the well-known location which covers all of their site except the /companies subtree. Then if the ShoeStoreExample company has some content in /companies/shoestoreexample, they could use one of the other mechanisms to indicate the location of a policy reference file covering their portion of the mall.example.com site.

One case where using the well-known location for policy reference files is expected to be particularly useful is in the case of seperate application servers. The other mechanisms allowed for specifying the location of a policy reference file require that some URI on the host being accessed must be fetched to locate the policy reference file. However, the well-known location mechanism has no such requirement. Consider the example of an HTML form located on www.example.com. Imagine that the action URI on that form points to server cgi.example.com. The policy reference file which covers the form is unable to make any statements about the action URI which processes the form. However, the site administrator publishes a policy reference file at http://cgi.example.com/p3p.xml which can cover the action URI, thus enabling a user agent to easily locate the P3P policy which applies to the action URI before submitting the form contents.

2.2.2 Using The HTTP Extension Framework

P3P makes use of the HTTP Extension Framework [HTTP-EXT]. The HTTP Extension Framework allows new HTTP headers to be defined and used. All HTTP headers associated with a given extension in a request or response are to be prefixed by an arbitrary two-digit namespace identifier. This prefix may be chosen by implementations on a per-message basis. This guarantees a unique namespace for the extension's headers. In addition, the extension must identify itself (with a URI) when it declares the namespace.

2.2.2.1 Use of the HTTP Extension Framework

The HTTP Extension Framework requires a globally unique URI identifying the extension (the extension declaration). The P3P extension declaration is the following URI:

http://www.w3.org/2000/P3Pv1

Any document retrieved by HTTP may point to a policy reference file through the use of a new response header, the PolicyRef header. The PolicyRef header contains the URI of a policy reference file, which will state the P3P policy covering the document that pointed to the reference file, and possibly others as well. This URI MUST NOT be used for any other purpose beyond identifying and referencing P3P policies.

The P3P extension declaration and policy reference header SHOULD be inserted whenever a P3P-enabled server responds to a relevant request, including when it responds to HEAD and OPTIONS requests.

As it is possible for non-P3P-enabled user agents to properly interpret and process responses that include the P3P policy reference, P3P is an "optional" extension in the terms of the HTTP Extension Framework. Since policy references may be processed by agents anywhere along the response chain, P3P is an end-to-end HTTP extension. Thus, the header used to declare the P3P extension is Opt.

2.2.2.2 Header Syntax

The policy reference header syntax is:

[1]	policy-reference-header	=	nsprefix `-PolicyRef: ` URI
Here, `URI` is defined as per RFC 2396 [URI]. `nsprefix` is the two-digit namespace declaration selected for the P3P headers in this message, according to [HTTP-EXT]. It may be any two-digit number that does not conflict with other namespace declarations in the response.

In keeping with the rules for other HTTP headers, the PolicyRef portion of this header may be written in any case.

Example 2.1:

1. Client makes a GET request.

GET /index.html HTTP/1.1
Host: catalog.example.com
Accept: */*
Accept-Language: de, en
User-Agent: WonderBrowser/5.2 (RT-11)

2. Server returns content and the PolicyRef header pointing to the policy of the page.

HTTP/1.1 200 OK
Opt: "http://www.w3.org/2000/P3Pv1"; ns=11
11-PolicyRef: http://catalog.example.com/P3P/PolicyReferences.xml
Content-Type: text/html
Content-Length: 7413
Server: CC-Galaxy/1.3.18

2.2.3 Syntax Using the `link` Tag

Servers may serve HTML content with embedded link tags that indicate the location of the relevant P3P policy reference file. This use of P3P does not require a P3P-aware server; content may be modified to include the embedded link tags without requiring any changes to the way the server operates.

The link tag encodes the information that could be expressed using the P3P PolicyRef header. The link tag takes the following form:

[2]	p3p-link-tag	=	`<link rel="P3Pv1" href="` URI `">`
Here, `URI` is defined as per RFC 2396 [URI].

For example, the policy reference expressed in Example 2.1 using HTTP headers could be expressed equally well by including in the web page http://catalog.example.com/index.html the following piece of HTML:

<link rel="P3Pv1" 
    href="http://catalog.example.com/P3P/PolicyReferences.xml">

Since it is embedded in an HTML document, the character encoding for the p3p-link-tag will be the same as that of the HTML document. In contrast to P3P policy and policy reference documents (see section 2.3 and section 3 below), the p3p-link-tag need not be encoded using [UTF-8].

Note that if user agents support retrieving HTML content over HTTP, they MUST handle both mechanisms (policy references in HTTP headers or in link tags) interchangeably; neither of the two mechanisms overrides the other. See also the requirements for non-ambiguity.

2.3 Policy Reference File Syntax and Semantics

A policy reference file is used to associate P3P policies with certain regions of URI-space. Regardless of the mechanism documents use to link to a policy reference file, the syntax of that reference file remains the same. The policy reference file is used to make any or all of the following statements:

The URI where a P3P policy is found
The URIs or regions of URI-space covered by this policy
The URIs or regions of URI-space not covered by this policy
The access methods for which this policy is applicable
The period of time for which those claims are considered to be valid

The first four statements are made in the body of the policy reference file. The last is made using HTTP expiration headers on the policy reference file.

2.3.1 Example Policy Reference File

Consider the case of a Web site wishing to make the following statements:

P3P policy /P3P/Policy1.xml applies to the entire site, except the subtrees /catalog, /cgi-bin, and /servlet.
P3P policy /P3P/Policy2.xml applies to all documents in the /catalog directory (and its subdirectories).
P3P policy /P3P/Policy3.xml applies to all documents in the /cgi-bin and /servlet directories (and their subdirectories), except for /servlet/unknown.
No statement is made about what P3P policy applies to /servlet/unknown.
These statements are valid for 8 hours.

These statements could be represented by the following [RDF]:

Example 2.2:

<POLICY-REFERENCES
    xmlns="http://www.w3.org/2000/P3Pv1"
    xmlns:web="http://www.w3.org/1999/02/22-rdf-syntax-ns#" >
  <web:RDF>

    <POLICY-REF web:about="/P3P/Policy1.xml">
      <PREFIX>/</PREFIX>
      <EXCLUDE>/catalog/</EXCLUDE>
      <EXCLUDE>/cgi-bin/</EXCLUDE>
      <EXCLUDE>/servlet/</EXCLUDE>
    </POLICY-REF>

    <POLICY-REF web:about="/P3P/Policy2.xml">
      <PREFIX>/catalog/</PREFIX>
    </POLICY-REF>

    <POLICY-REF web:about="/P3P/Policy3.xml">
      <PREFIX>/cgi-bin/</PREFIX>
      <PREFIX>/servlet/</PREFIX>
      <EXCLUDE>/servlet/unknown</EXCLUDE>
    </POLICY-REF>

  </web:RDF>
</POLICY-REFERENCES>

To indicate that the claims made by this policy reference file are good for 8 hours, the origin server serving this page would return a Cache-Control: max-age=28800 header with this file. Alternatively, the origin server could generate an Expires header dated 8 hours past the Date header in the response.

2.3.2 Policy Reference File Definition

This section defines the syntax and semantics of P3P policy reference files. All policies MUST be encoded using [UTF-8]. P3P servers MUST encode their policy references using this syntax. P3P user agents MUST be able to parse this syntax.

One significant point to make about the syntax of policy reference files is that the syntax defined here does not have an extension mechanism. The syntax for P3P policies has a powerful extension mechanism, but that mechanism is not supported for policy reference files.

2.3.2.1 Policy Reference File Lifetimes

The lifetime of a policy reference file tells user agents how long they can rely on the claims made in the reference file. For example, if a policy reference file has a lifetime of 16 hours, then a user agent need not reload that file for 16 hours, and can assume that the references made in that reference file are good for 16 hours. All of the policy references made in a single policy reference file will receive the same lifetime. The only way to specify different lifetimes for P3P policies is to use separate policy reference files for each policy.

The lifetime of a policy reference file is determined by the HTTP cache control headers served with the reference file. However, user agents MUST NOT use heuristic expiration based on last-modified to compute a lifetime for the reference file. User agents MUST compute a lifetime for the policy reference file based on Expires, Cache-Control, or Pragma headers served with the file if they are available. The semantics of these headers are defined by [HTTP]. If none of these headers is available, the lifetime MUST be set to 24 hours from the time the document was sent from the origin server. Origin servers SHOULD use one of the headers listed above to give an explicit lifetime for their policy reference files.

The possible presence of caches in the network and the heuristic expiration mechanism in HTTP considerably complicates lifetime considerations. Consider the case of policy reference files that have no explicit cache lifetime defined by the origin server (i.e., none of the headers listed above are included in the response). A network cache will, in all likelihood, compute a cache lifetime for the policy reference file based on its last-modified date; the resulting cache lifetime could be significantly longer that 24 hours. If a user agent then retrieves this policy reference file from an HTTP 1.0 cache, the user agent has no way to know how long the reference file may have been in the cache. It would then be impossible for the user agent to determine if the reference file's lifetime has already expired, or when it will expire. HTTP 1.1 caches improve the situation somewhat, as HTTP 1.1-compliant caches MUST send an Age header when serving a request from their cache. However, even this is not sufficient; the cache could return a file with an age exceeding the 24-hour lifetime defined here, resulting in a useless policy reference file. To avoid these problems, user agents MUST insure that they load a fresh copy of the policy reference file when it is fetched. Thus, a user agent MUST include either a Pragma: no-cache or a Cache-Control: no-cache request-header when fetching a policy reference file. The former is suggested for compatibility with HTTP 1.0 caches.

Note that it is impossible for a client to accurately predict the amount of latency that may affect an HTTP request. Thus, if the policy reference file covering a request is going to expire soon, clients MAY wish to consider warning their users and/or revalidating the policy reference file before continuing with the request.

2.3.2.2 The `POLICY-REFERENCES` element

The POLICY-REFERENCES element contains a complete policy reference file. Exactly one POLICY-REFERENCES element MUST be in a policy reference file. This element MUST contain one RDF element.

POLICY-REFERENCES: contains one RDF element. This element has no attributes (other than possibly some namespace declarations).

[3]	policies	=	`<POLICY-REFERENCES xmlns="http://www.w3.org/2000/P3Pv1" ` rdf-ns-def `>` rdf `</POLICY-REFERENCES>`
[4]	rdf-ns-def	=	xmlns `:` rdf-ns-prefix `="http://www.w3.org/1999/02/22-rdf-syntax-ns#"`
[5]	rdf-ns-prefix	=	NCName
Here `NCName` is defined in Namespaces in XML [Namespace]

2.3.2.3 The `RDF` element

The RDF element encapsulates RDF expressions in a policy reference file. This element MUST contain one or more POLICY-REF (policy reference) elements.

POLICY-REFERENCES: contains one or more discrete policy references. This element has no attributes.

[6]

rdf

`<` rdf-ns-prefix `:` `RDF>`
policy-ref
`</` rdf-ns-prefix `:` `RDF/>`

2.3.2.4 The `POLICY-REF` element

A policy reference file may refer to multiple P3P policies, specifying information about each. The POLICY-REF element is an RDF resourece, and describes attributes of a single P3P policy. Elements within the POLICY-REF element give the location of the policy and specify the areas of URI-space that each policy covers.

POLICY-REF: contains information about a single P3P policy.
(rdf-nf-prefix:)about (mandatory attribute): URI of the P3P policy. If this is a relative URI, it is interpreted relative to the URI of the policy reference file. This may be either a direct or an indirect policy reference; see Direct and Indirect Policy References for a definition of these terms.

[7]	policy-ref	=	`<POLICY-REF ` rdf-ns-prefix `:` `about="` URI `">` prefix exclude *method-element `</POLICY-REF>`
Here, `URI` is defined as per RFC 2396 [URI].

2.3.2.5 The `PREFIX` and `EXCLUDE` elements

Each PREFIX or EXCLUDE element specifies one local URI-prefix. They are used to specify the portion of the Web site that is covered by the policy referenced by the enclosing POLICY-REF element.

When PREFIX (and optionally, EXCLUDE) elements are present in a POLICY-REF element, it means that the policy specified in the space attribute of the POLICY-REF element applies to all the URIs at the requested host corresponding to the local-URI(s) specified by the PREFIXes, but not specified by an EXCLUDE element.

If a METHOD element specifies one or more methods for an enclosing policy reference, it follows that all methods not mentioned are consequently not covered by this policy. In the case that this is the only policy reference for a given URI prefix, user agents MUST assume that NO policy is in effect for all methods NOT mentioned in the policy reference file.

If no PREFIX element is included in a POLICY-REF element, it MUST be implicitly assumed that the policy given by the href applies to the resource that linked to this policy reference file. It is an error for a policy reference file to contain two or more POLICY-REF elements without PREFIX elements. It is legal, but pointless, to supply an EXCLUDE element without any PREFIX elements; in that case, the EXCLUDE elements MUST be ignored by user agents.

A policy reference file can only cover URIs on the same host as the reference file. Therefore, the PREFIX and EXCLUDE elements MUST specify only local URI prefixes; they MUST NOT refer to URIs on other hosts. This requirement does NOT apply to the location of the P3P policy file (the web:about attribute on the POLICY-REF element).

Note that policy reference files do not support any sort of regular expressions. The only mechanism offered in a POLICY-REF element is to refer to the current document (implicitly, by not giving a PREFIX element), or to use a relative URI-prefix. It is not possible, for example, to state that a certain P3P policy applies to all URIs ending with the extension ".asp", or to any URIs containing more than 3 instances of the letter 't'.

Further, notice that PREFIX and EXCLUDE matching is done as a simple string prefix matching. As a result, a missing "/" at the end of a directory prefix might lead to unexpected results. For example, the element <EXCLUDE>/images/logos</EXCLUDE> (notice the missing '/' at the end of the href) will not only exclude all resources in the /images/logos/ subdirectory but also, for example, a file with the relative URI /images/logoschool.jpg .

[8]	prefix	=	`<PREFIX>` URI`</PREFIX>`
[9]	exclude	=	`<EXCLUDE>` URI `</EXCLUDE>`
Here, `URI` is defined as per RFC 2396 [URI].

2.3.2.6 The `METHOD` element

By default, a policy reference applies to the stated URIs regardless of the method used to access the resource. However, a Web site may wish to define different P3P policies depending on the method to be applied to a resource. For example, a site may wish to collect more data from users when they are performing PUT or DELETE methods than when performing GET methods.

The METHOD element in a policy reference file is used to state that the enclosing policy reference only applies when the specified methods are used to access the referenced resources. The METHOD element may be repeated to indicate multiple applicable methods. If the METHOD element is not present in a POLICY-REF element, then that POLICY-REF element covers the resources indicated regardless of the method used to access them.

So, to state that /P3P/Policy1.xml applies to all documents in the subtree /docs/ for GET and HEAD methods, while /P3P/Policy2.xml applies for PUT and DELETE methods, the following policy reference would be written:

Example 2.3:

<POLICY-REFERENCES
    xmlns="http://www.w3.org/2000/P3Pv1"
    xmlns:web="http://www.w3.org/1999/02/22-rdf-syntax-ns#">
  <web:RDF>

    <POLICY-REF web:about="/P3P/Policy1.xml">
      <PREFIX>/docs/</PREFIX>
      <METHOD>GET</METHOD>
      <METHOD>HEAD</METHOD>
    </POLICY-REF>

    <POLICY-REF web:about="/P3P/Policy2.xml">
      <PREFIX>/docs/</PREFIX>
      <METHOD>PUT</METHOD>
      <METHOD>DELETE</METHOD>
    </POLICY-REF>

  </web:RDF>
</POLICY-REFERENCES>

Note that HTTP requires the same behavior for GET and HEAD requests, thus it is inappropriate to specify different P3P policies for these methods. The syntax for the METHOD element is:

[10]	method-element	=	`<METHOD>` Method `</METHOD>`
Here, `Method` is defined in the section 5.1.1 of [HTTP1.1].

2.3.3 Direct and Indirect References

Policy reference files may refer directly or indirectly to policies. A direct reference to a policy is a policy URI that, when fetched, returns the XML document which makes up that policy. An indirect reference to a policy is a policy URI that, when fetched, returns a new policy URI. The new policy URI returned by an indirect reference MAY, itself, be an indirect reference, though this is discouraged for performance reasons.

Direct and indirect references are recognized by the HTTP return code given by the server when fetched. When the URI of a direct policy reference is fetched, the server SHOULD return a 200-class HTTP return code or a 301 (Moved Permanently) HTTP return code (or an error code, if appropriate). It MUST NOT give a 302 (Found), return code as a response. When the URI of an indirect policy reference is fetched, a 302 return code MUST be given, unless an error (400- or 500-class) return code is appropriate. When a 302 return code is returned, it MUST include a Location response header giving the actual policy URI.

Services MAY choose to use direct or indirect policy references as appropriate (so long as the requirements under Immutability of Policies are respected). A direct policy reference will result in the best performance for user agents that are processing those policies. Due to the immutability rule, if a user agent receives a direct policy reference to a URI that it has already fetched, then no additional network activity is required in order to process that policy. This results in quicker response time for the user agent.

2.3.3.1 Purpose of Indirect Policy References

Indirect policy references require at least one additional network round trip to locate the actual policy. This results in reduced performance for the user agent. However, it allows for more flexible policy deployment for certain organizations. An example will assist in illustrating:

Imagine that an imaginary company, CatalogExample, is establishing a worldwide Web presence. Its default Web site, www.catalog.example.com, provides links to a number of country-specific sites. For purposes of this example, assume that CatalogExample starts by deploying four localized sites: usa.catalog.example.com (USA), www.catalog.example.co.uk (United Kingdom), www.catalog.example.com.ru (Russia), and www.catalog.example.co.jp (Japan). Let us assume that each of these sites has their content developed locally. This allows the sites to be better tailored to their local audiences.

However, the CatalogExample company has decided that it will have a single privacy policy that will apply to all of their sites around the world. They could do this by deploying that privacy policy on their master Web site (www.catalog.example.com), and having pages on their localized servers reference that policy. When CatalogExample company wishes to update their privacy policy, then by the Immutability of Policies rule, they must place that policy at a new URI. Then the policy references on all of their sites must be changed. This will probably involve work by several Webmasters and Webmistresses in various parts of the globe. The problem becomes far worse when CatalogExample expands to more of the world, and has perhaps 20 or 50 localized Web sites.

Indirect policy references are intended as a solution to this management problem. Each of the local CatalogExample sites can contain a policy URI pointing to the main CatalogExample server. Fetching this URI returns a reference to the currently-applicable privacy policy. For example, imagine that the CatalogExample company wants to gather customers' e-mail addresses to send them a note listing weekly specials. Each of the local servers could use an indirect policy URI of http://www.catalog.example.com/privacy/P3P/policy-weeklyspecial. Resolving this URI would then return a link to the actual privacy policy; perhaps this might be http://www.catalog.example.com/privacy/P3P/policy-weeklyspecial-3.xml. Now, when the corporation wishes to update the privacy policy that applies to the weekly special registration form, they need only update in a single location, regardless of how many servers reference that policy.

In general, services should use direct policy references whenever it is feasible. Indirect policy references are expected to be used only by organizations with large and diverse Web presences.

Note that services SHOULD make indirect policy references only across URIs that are under the same organizational control, to help insure the accuracy of the policy statement. However, there is no technical means to enforce this requirement. Indirect policy references MAY be to URIs on other hosts or even in other domains, depending on the structure of an organization's Web presence.

2.3.3.2 Handling Indirect References

When a user agent receives a policy reference, there is no way for it to tell if it is a direct or indirect policy reference. To process the policy properly, the user agent MUST fetch the URI specified in the policy reference. If that reference returns a 302 (Found) return code, then the user agent MUST fetch the URI given in the Location header to locate the actual policy. Note that once a policy is fetched by direct reference, it need not be fetched again (as long as the user agent records the relevant information). However an indirect reference requires rechecking to make sure it has not changed (unless an Expires or Cache-Control HTTP header indicates that it has not changed).

2.3.4 Embedded Content

HTML pages often contain links to other resources that are directly embedded in the page, such as images, sounds, layers or frames. Thus, in order to render the page, the user agents needs to make additional requests which might or might not be covered by the policy in effect for the page that is currently laid out.

As described in section 2.3 Policy Reference File Syntax and Semantic, the preferred method for such situations is to predeclare all policies in effect using the <PREFIX> and <EXCLUDE> elements in the policy reference file. See example 2.2. in section 2.3.1 Example Policy Reference File, as well as the definitions in section 2.3.2 Policy Reference File Definition for reference.

If a user agent is unable to find a matching prefix for a given URI that links to embedded content (e.g., the src-attribute of an IMG-tag) it SHOULD initially assume that NO policy is in effect for the given resource. However, user agents MAY try to issue a HEAD request to such an embedded URI not covered in the headers of the current page before actually requesting the resource, in order to find the policy in effect.

2.3.5 Forms and Related Mechanisms

Forms are a special type of embedded content, as they often link to CGI scripts or other server-side applications in their action URIs, which might not support HEAD requests.

If a user agent is unable to find a matching prefix for a given action URI in the policy reference file that was referenced from the page, it SHOULD assume that no policy is in effect. Under these circumstances, user agents SHOULD check the well-known location on the host of the action URI to attempt to find a policy reference file which covers the action URI. If this does not provide a P3P policy to cover the action URI, then a user agent MAY try to issue a HEAD request to an action URI before actually submitting any data in order to find the policy in effect. Services SHOULD ensure that server-side applications can properly respond to such HEAD requests and return the corresponding policy reference link in the headers. In case the underlying application does not understand the HEAD request and no policy has been predeclared for the action URI in question, user agents MUST assume that no policy is in effect and SHOULD inform the user about this or take the corresponding actions according to the user's preferences.

Note that services might want to make use of the <METHOD> element in order to declare policies for server-side applications that only cover a subset of supported methods, e.g., POST or GET. Under such circumstances, it is acceptable that the application in question only supports the methods given in the policy reference file (i.e., HEAD requests need not be supported). User agents SHOULD NOT attempt to issue a HEAD request to an action URI if the relevant methods specified in the form's method attribute have been properly predeclared in the page's policy reference file.

In some cases, different data is collected at the same action URI depending on some selection in the form. For example, a search service might offer to both search for people (by name and/or email) and (arbitrary) images. Using a set of radio buttons on the form, a single server-side application located at one and the same action URI handles both cases and collects the required information necessary for the search.

If a service wants to predeclare the data collection practices of the server-side application it currently only has the option of declaring all of the data collection practices in a single policy file (using a <PREFIX> declaration matching the action URI). For all practical purposes, user agents MUST assume that all data elements are collected under every circumstances. This solution offers the convenience of a single policy but might not properly reflect the fact that only parts of the listed data elements are collected at a time. Services SHOULD make sure that a simple HEAD request to the action URI (i.e., without any arguments, especially without the value of the selected radio button) will return a policy that covers all cases.

Note that for form submissions using the GET method, it is possible to include part of the submission data (which is appended to the action URI when using the GET method) in the <PREFIX> element, thus declaring different policies for different submission cases. However, although feasible, this method is deprecated for the following reasons:

Dependent on user agent: Even though [HTML 4.01] requires user agents to always send form data in the order specified in the HTML source, non-compliant user agents might not assemble query strings in a guaranteed fashion.
Dependent on page source: If a page designer wants to redesign a page at a later time, any reordering of input elements might break the previous order, thus rendering the predeclared policy links useless.
Restricts element order on page: In order to make use of the <PREFIX> mechanism¸ page designers must ensure that the differentiating element(s) appears first on the page.

2.4 Referencing Policies

2.4.1 Non-ambiguity

A very important rule of policy references is that of non-ambiguity: For each resource at a website there MUST be at most one policy active at any given time. Thus two policy reference files on a given site MUST NOT declare two or more different policy URIs for the same resource.

While the need to check for such ambiguities within a single policy reference file is obvious, user agents MAY also track policy declarations across an entire website, in order to detect ambiguities in policy declarations.

See also the section on Immutability of Policies for a discussion of non-ambiguity over time (immutability).

2.4.2 Multiple Languages

Multiple language versions (translations) of the same policy can be offered by the server using the HTTP "Content-Language" header to properly indicate that a particular language has been used for the policy. This is useful so that human-readable fields such as entity and consequence can be presented in multiple languages. The same mechanism can also be used to offer multiple language versions for data schemas.

Whenever Content-Language is used to distinguish policies at the same URI that are offered in multiple languages, the policies MUST have the same meaning in each language. Two policies (or two data schemas) are taken to be identical if

All formal (not natural language) protocol elements are semantically identical (i.e., attribute order does not matter, the presence or absence of a default value does not matter, but attribute values matter)
All natural language protocol elements correspond one-to-one, and for each correspondence, one has to be a careful translation of the other (maybe indirectly via third languages).

Since both policies and data schemas need to be immutable (compare section 2.4.3 Immutability of Policies below), translations should be done very carefully. If a change is necessary because a translation error has been found, a new policy URI has to be used. This means that even more care is necessary for data schema translations.

Due to the use of the Accept-Language mechanism, implementors should take note that user agents may see different language versions despite sending the same Accept-Language request header if a new language version of a policy or data schema has been added.

2.4.3 Immutability of Policies

An essential requirement on policies is the so-called immutability of policies: with one exception, policies that are directly referenced at a certain URI cannot be changed. This way, the URI of a policy acts like a unique identifier for the policy, and any new policy must therefore use a new different URI. The only exception to this general principle is when multiple language versions (translations) of the same policy are offered by the server using the HTTP "Content-Language" tag.

P3P clients MAY check for immutability of policies, by comparing a cached version of a policy (and its Content-Language if present) with the corresponding freshly retrieved policy (and Content-Language if present). If a user agent discovers that the two policies are different but retain the same URI, then it MUST treat the resource covered by the changed policy as if it has no P3P policy, UNLESS they have two different values of Content-Language.

Note that immutability of policies only holds to policies that are directly referenced: the URI returned when an indirect policy reference is fetched MAY change over time; after all, this is the purpose behind indirect policy references. Indirect policy references MUST NOT be changed into direct policy references; if this is desired, a new policy-URI MUST be used.

2.5 Additional Requirements

2.5.1 The "Safe Zone"

Every P3P-enabled user agent and service SHOULD ensure that all the relevant communications that take place as part of fetching a P3P policy are part of a special "safe zone" in which minimal data collection takes place and any data that is collected is used only in non-identifiable ways. In particular, requests to the well-known location for policy reference files SHOULD be covered by these "safe zone" practices.

To support this safe zone, P3P user agents SHOULD suppress the transmission of data unnecessary for the purpose of finding a site's policy until the policy has been fetched. Thus user agents SHOULD NOT send the HTTP Referer header, cookies, or user agent information while requesting a P3P policy. User agent implementors need to be aware that there is a privacy trade-off with using the Accept-Language HTTP header when requesting a P3P policy. Sending the correct Accept-Language header will allow fetching the P3P policy in the user's preferred natural language (if available), but does expose a certain amount of information about the identity of the user. User agents MAY wish to allow users to decide when the Accept-Language header should be sent.

In addition, P3P user agents MAY issue a HEAD request to a site in order to learn the location of the relevant policy before making other requests. This is a useful way to obtain a site's policy without making a request that could result in the transmission of data. However, since it might be possible for sites to detect the user's identify from the Accept-Language header (see the [HTTP1.1] Specification, section 15.1.4 Privacy Issues Connected to Accept Headers), HEAD requests may be issued without an Accept-Language header in order to get the machine-readable part of the policy, and only if that is reasonably satisfactory, the policy in the appropriate language is fetched if necessary.

Servers SHOULD NOT require the receipt of an HTTP Referer header, cookies, user agent information, or other information unnecessary for responding to the request in order to serve a policy file. In addition, servers SHOULD NOT use in an identifiable way any information collected while serving a policy file or responding to a HEAD request.

Servers MAY return a PolicyRef header in the response headers when a P3P policy is requested. However, it is important to note that the PolicyRef header MUST be ignored, and that the "safe zone" requirements described in this section apply instead. Returning a PolicyRef header in such cases is permitted in consideration of the fact that administrators may find it easier to apply a P3P policy to all documents on a server, and that requiring policies to be served without a PolicyRef header may result in extra work for site administrators.

Note that the safezone requirements do not say that sites cannot keep identifiable information -- only that they SHOULD NOT use in an identifiable way any information collected while serving a policy file. Tracking down the source of a denial of service attack, for example, would be a legitimate reason to use this information and ignore the SHOULD.

2.5.2 Non-Discrimination of Policies

There are two important further requirements on the server side:

Reference a policy in response to any request:: P3P-compliant servers SHOULD include a link to a policy reference file for a web resource whenever possible.
Support HTTP HEAD requests: P3P-compliant servers SHOULD support HEAD requests for any documents that can be retrieved with GET requests. Whenever technically feasible, servers should give a valid response to a HEAD request for documents which are normally accessed by other HTTP methods as well (such as POST).

2.5.3 Security of Policy Transport

P3P policies and references to P3P policies SHOULD NOT, in themselves, contain any sensitive information. This means that there are no additional security requirements for transporting a reference to a P3P policy beyond the requirements of the document it is associated with; so, if an HTML document would normally be served over a non-encrypted session, then the P3P protocol would not require nor recommend that the document be served over an encrypted session when a reference to a P3P policy is included with that document.

3. Policy Syntax and Semantics

P3P policies are encoded in XML. They may also be represented using the RDF data model; however, an RDF representation is not included in this specification. (The working group plans to make this available as a W3C Note prior to submitting P3P as a Proposed Recommendation.)

Section 3.1 begins with an example of an English language privacy policy and a corresponding P3P policy. P3P policies include general assertions that apply to the entire policy as well as specific assertions -- called statements -- that apply only to the handling of particular types of data referred to by data references. Section 3.2 describes the policy element and policy-level assertions. Section 3.3 describes statements and data references.

In the sections that follow a number of XML elements are introduced. Each element is given in <> brackets, followed by a list of valid attributes. All listed attributes are optional, except when tagged as mandatory. Note that many XML elements are shown in the BNF with separate beginning and ending tags to allow optional elements inside them. If no elements are included, then, following standard XML rules, a self-closing element may be used instead.

3.1 Example policies

3.1.1 English language policies

The following are two examples of English-language privacy policy to be encoded as a P3P policy. Both policies are for one example company, CatalogExample, which has different policies for those browsing their site and those actually purchasing products.

Example 3.1: CatalogExample's Privacy Policy for Browsers

At CatalogExample, we care about your privacy. When you come to our site to look for an item, we will only use this information to improve our site and will not store it in an identifiable way.

CatalogExample, Inc. is a licensee of the PrivacySealExample Program. The PrivacySeal Program ensures your privacy by holding Web site licensees to high privacy standards and confirming with independent auditors that these information practices are being followed.

Questions regarding this statement should be directed to:
CatalogExample 4000 Lincoln Ave. Birmingham, MI 48009 USA E-mail: catalog@example.com Telephone 248-EXAMPLE (248-392-6753)

If we have not responded to your inquiry or your inquiry has not been satisfactorily addressed, you can contact PrivacySealExample at http://www.privacyseal.example.org. CatalogExample will correct all errors or wrongful actions arising in connection with the privacy policy.

What We Collect and Why:
When you browse through our site we collect:

the basic information about your computer and connection to make sure that we can get you the proper information and for security purposes.
aggregate information on what pages consumers access or visit to improve our site.

Data retention:
We purge the browsing information that we collect regularly.

Here is Example 3.1 in a more formal description, using the P3P element and attribute names [with the section of the spec that was used cited in brackets for easy reference]:

Disclosure URI: http://www.catalog.example.com/PrivacyPracticeBrowsing.html
[3.2.1 Policy]
Entity: CatalogExample
4000 Lincoln Ave.
Birmingham, MI 48009
USA
catalog@example.com
+1 (248) 392-6753
[3.2.2 Entity]
Access to Identifiable Information: None
[3.2.3 Access]
Disputes:
resolution type: independent
service: http://www.privacyseal.example.org
description: PrivacySealExample
[3.2.4 Disputes]
Remedies: we'll correct any harm done wrong
[3.2.5 Remedies]
We collect:
dynamic.clickstream.server
dynamic.http.useragent
[4.5 Base Data Schema]
For purpose: Web site and system administration, research and development
[3.3.3 Purpose]
Recipients: Only ourselves and our agents
[3.3.4 Recipients]
Retention: As long as appropriate for the stated purposes
[3.3.5 Retention]

Example 3.2: CatalogExample's Privacy Policy for Shoppers

At CatalogExample, we care about your privacy. We will never share your credit card number or any other financial information with any third party. With your permission only, we will share information with carefully selected marketing partners that meet either the preferences that you've specifically provided or your past purchasing habits. The more we and know about your likes and dislikes, the better we can tailor offerings to your needs.

CatalogExample is a licensee of the PrivacySealExample Program. The PrivacySealExample Program ensures your privacy by holding Web site licensees to high privacy standards and confirming with independent auditors that these information practices are being followed.

Questions regarding this statement should be directed to:
CatalogExample 4000 Lincoln Ave. Birmingham, MI 48009 USA E-mail: catalog@example.com Telephone +1 248-EXAMPLE (+1 248-392-6753)

If we have not responded to your inquiry or your inquiry has not been satisfactorily addressed, you can contact PrivacySealExample - http://privacyseal.example.org/privacyseal. CatalogExample will correct all errors or wrongful actions arising in connection with the privacy policy.

When you browse through our site we collect:

the basic information about your computer and connection to make sure that we can get you the proper information and for security purposes; and
aggregate information on what pages consumers access or visit to improve our site

If you choose to purchase an item we will ask you for more information including:

your name and address so that we can have your purchase delivered to you and so we can contact you in the future;
your email address and phone number so we can contact you;
a login and password to use to update your information at any time in the future; and
financial information to complete your purchase (you may choose to store this for future use)
optionally, you can enter other demographic information so that we can tailor services to you in the future.

Also on this page we will give you the option to choose if you would like to receive email, phone calls or written service from CatalogExample or from our carefully selected marketing partners who maintain similar privacy practices. If you would like to receive these solicitations simply check the appropriate boxes. You can choose to stop participating at any time simply by changing your preferences.

Changing and Updating personal information
Consumers can change all of their personal account information by going to the preferences section of CatalogExample at http://catalog.example.com/preferences.html. You can change your address, phone number, e-mail address, password as well as your privacy settings.

Cookies
CatalogExample uses cookies only to see if you have been an CatalogExample customer in the past and, if so, customize services based on your past browsing habits and purchases. We do not store any personal data in the cookie nor do we share or sell the any of the information with other parties or affiliates.

Data retention
We will keep the information about you and your purchases for as long as you remain our customer.

3.1.2 XML encoding of policies

The following pieces of [XML] capture the information as expressed in the above two examples. P3P policies are statements that are properly expressed as well-formed XML. The policy syntax will be explained in more detail in the sections that follow.

XML Encoding of Example 3.1:

<POLICY xmlns="http://www.w3.org/2000/P3Pv1"
  discuri="http://www.catalog.example.com/PrivacyPracticeBrowsing.html">
 <ENTITY>
  <DATA-GROUP>
   <DATA ref="#business.name">CatalogExample</DATA>
   <DATA ref="#business.contact-info.postal.street.line1">4000 Lincoln Ave.</DATA>
   <DATA ref="#business.contact-info.postal.city">Birmingham</DATA>
   <DATA ref="#business.contact-info.postal.stateprov">MI</DATA>
   <DATA ref="#business.contact-info.postal.postalcode">48009</DATA>
   <DATA ref="#business.contact-info.postal.countrycode">USA</DATA>
   <DATA ref="#business.contact-info.online.email">catalog@example.com</DATA>
   <DATA ref="#business.contact-info.telecom.telephonenum.intcode">1</DATA>
   <DATA ref="#business.contact-info.telecom.telephonenum.loccode">248</DATA>
   <DATA ref="#business.contact-info.telecom.telephonenum.number">3926753</DATA>
  </DATA-GROUP>
 </ENTITY>
 <DISPUTES-GROUP>
  <DISPUTES resolution-type="independent"
    service="http://www.PrivacySeal.example.org"
    short-description="PrivacySeal.example.org">
   <REMEDIES><correct/></REMEDIES>
   <IMG src="http://www.PrivacySeal.example.org/Logo.gif"/>
  </DISPUTES>
 </DISPUTES-GROUP>
 <ACCESS><nonident/></ACCESS>
 <STATEMENT>
  <PURPOSE><admin/><develop/></PURPOSE>
  <RECIPIENT><ours/></RECIPIENT>
  <RETENTION><stated-purpose/></RETENTION>
  <DATA-GROUP>
   <DATA ref="#dynamic.clickstream.server"/>
   <DATA ref="#dynamic.http.useragent"/>
  </DATA-GROUP>
 </STATEMENT>
</POLICY>

XML Encoding of Example 3.2:

<POLICY xmlns="http://www.w3.org/2000/P3Pv1"
  discuri="http://www.catalog.example.com/PrivacyPracticeBrowsing.html">
 <ENTITY>
  <DATA-GROUP>
   <DATA ref="#business-info.name">CatalogExample</DATA>
   <DATA ref="#business-info.contact-info.postal.street.line1">4000 Lincoln Ave.</DATA>
   <DATA ref="#business-info.contact-info.postal.city">Birmingham</DATA>
   <DATA ref="#business-info.contact-info.postal.stateprov">MI</DATA>
   <DATA ref="#business-info.contact-info.postal.postalcode">48009</DATA>
   <DATA ref="#business-info.contact-info.postal.countrycode">USA</DATA>
   <DATA ref="#business-info.contact-info.online.email">catalog@example.com</DATA>
   <DATA ref="#business.contact-info.telecom.telephonenum.intcode">1</DATA>
   <DATA ref="#business-info.contact-info.telecom.telephonenum.loccode">248</DATA>
   <DATA ref="#business-info.contact-info.telecom.telephonenum.number">3926753</DATA>
  </DATA-GROUP>
 </ENTITY>
 <DISPUTES-GROUP>
  <DISPUTES resolution-type="independent"
    service="http://www.PrivacySeal.example.org"
    short-description="PrivacySeal.example.org">
   <REMEDIES><correct/></REMEDIES>
   <IMG src="http://www.PrivacySeal.example.org/Logo.gif"/>
  </DISPUTES>
 </DISPUTES-GROUP>
 <ACCESS><contact_and_other/></ACCESS>
 <STATEMENT>
  <PURPOSE><admin/><develop/></PURPOSE>
  <RECIPIENT><ours/></RECIPIENT>
  <RETENTION><stated-purpose/></RETENTION>
  <DATA-GROUP>
   <DATA ref="#dynamic.clickstream.server"/>
   <DATA ref="#dynamic.http.useragent"/>
  </DATA-GROUP>
 </STATEMENT>
 <STATEMENT>
  <PURPOSE><current/></PURPOSE>
  <RECIPIENT><ours/></RECIPIENT>
  <RETENTION><stated-purpose/></RETENTION>
  <DATA-GROUP>
   <DATA ref="#user.name"/>
   <DATA ref="#user.home-info.postal"/>
   <DATA ref="#user.home-info.telecom.phone"/>
   <DATA ref="#user.business-info.postal"/>
   <DATA ref="#user.business-info.telecom.phone"/>
   <DATA ref="#user.home-info.online.email"/>
   <DATA ref="#miscdata>
   <CATEGORIES><financial/><CATEGORIES/>
   </DATA>
  </DATA-GROUP>
 </STATEMENT>
 <STATEMENT>
  <PURPOSE>
   <contact change_preferences="yes"/>
   <customization change_preferences="yes"/>
   <targeting change_preferences="yes"/>
  </PURPOSE>
  <RECIPIENT><ours/><same/></RECIPIENT>
  <RETENTION><stated-purpose/></RETENTION>
  <DATA-GROUP>
   <DATA ref="#user.name" optional="yes"/>
   <DATA ref="#user.home-info.address" optional="yes"/>
   <DATA ref="#user.home-info.postal" optional="yes"/>
   <DATA ref="#user.home-info.telecom.phone" optional="yes"/>
   <DATA ref="#user.business-info.postal" optional="yes"/>
   <DATA ref="#user.business-info.telecom.phone" optional="yes"/>
   <DATA ref="#user.home-info.online.email" optional="yes"/>
  </DATA-GROUP>
 </STATEMENT>
 <STATEMENT>
  <CONSEQUENCE>Lets you access your own information</CONSEQUENCE>
  <PURPOSE><customization change_preferences="yes"/></PURPOSE>
  <RECIPIENT><ours/><same/></RECIPIENT>
  <RETENTION><stated-purpose/></RETENTION>
  <DATA-GROUP>
   <DATA ref="#dynamic.miscdata">
    <CATEGORIES><uniqueid/></CATEGORIES>
   </DATA>
  </DATA-GROUP>
 </STATEMENT>
 <STATEMENT>
  <CONSEQUENCE>A site with products you would appreciate</CONSEQUENCE>
  <PURPOSE>
    <customization change_preferences="yes"/>
    <targeting change_preferences="yes"/>
  </PURPOSE>
  <RECIPIENT><ours/><same/></RECIPIENT>
  <RETENTION><stated-purpose/></RETENTION>
  <DATA-GROUP>
   <DATA ref="#user.bdate.ymd.year" optional="yes"/>
   <DATA ref="#user.gender" optional="yes"/>
  </DATA-GROUP>
 </STATEMENT>
 <STATEMENT>
  <CONSEQUENCE>A site with clothes you would appreciate</CONSEQUENCE>
  <PURPOSE><customization/><develop/></PURPOSE>
  <RECIPIENT><ours/></RECIPIENT>
  <RETENTION><indefinitely/></RETENTION>
  <DATA-GROUP>
   <DATA ref="#dynamic.cookies"><CATEGORIES><state/></CATEGORIES></DATA>
   <DATA ref="#dynamic.miscdata"><CATEGORIES><preference/></CATEGORIES></DATA>
  </DATA-GROUP>
 </STATEMENT>
</POLICY>

3.2 Policies

This section defines the syntax and semantics of P3P policies. All policies MUST be encoded using [UTF-8]. P3P servers MUST encode their policies using this syntax. P3P user agents MUST be able to parse this syntax.

3.2.1 The `POLICY` element

The POLICY element contains a complete P3P policy. Each P3P policy MUST contain exactly one POLICY element. The policy element MUST contain an ENTITY element that identifies the legal entity making the representation of the privacy practices contained in the policy. In addition, the policy element MUST contain an ACCESS element, at least one STATEMENT element, and optionally a DISPUTES-GROUP element and one or more extensions.

<POLICY>: includes one or more statements. Each statement includes a set of disclosures as applied to a set of data elements.
discuri (mandatory attribute): URI of the natural language privacy statement

[11]	policy	=	`<POLICY xmlns="http://www.w3.org/2000/P3Pv1" discuri=` quoted-URI `>` extension [dataschema] entity access [disputes-group] 1statement-block *extension `</POLICY>`
[12]	quoted-URI	=	`"` URI `"`
Here, URI is defined as per RFC 2396 [URI].

3.2.2 The ENTITY element

The ENTITY element gives a precise description of the legal entity making the representation of the privacy practices.

<ENTITY>: identifies the legal entity making the representation of the privacy practices contained in the policy

The ENTITY element contains a description of the legal entity consisting of DATA elements referencing (all or part of) the fields of the business dataset: it MUST contain both the legal entity's name as well as contact information such as postal address, telephone number, email address, or other information that individuals may use to contact the entity about their privacy policy. Note that some laws and codes of conduct require entities to include a postal address or other specific information in their contact information.

[13]

entity

"<ENTITY>"
*extension
entitydescription
*extension
"</ENTITY>"

[14]

entitydescription

<DATA-GROUP>
`<DATA ref="#business.name"/>` PCDATA </DATA>
*(`<DATA ref="#business." string `/>` PCDATA </DATA>)
</DATA-GROUP>

Here, string is defined as a sequence of characters (with " and & escaped) among the values that are allowed by the business dataset. PCDATA is defined as in [XML].

3.2.3 The `ACCESS` element

The ACCESS element indicates whether the site provides access to various kinds of information.

<ACCESS>: the ability of the individual to view identifiable information and address questions or concerns to the service provider. Service providers MUST disclose one value for the access attribute. The method of access is not specified. Any disclosure is not meant to imply that access to all data is possible, but that some of the data may be accessible and that the user should communicate further with the service provider to determine what capabilities they have.
Note that service providers may also wish to provide capabilities to access information collected through means other than the Web at the discuri. However, the scope of P3P statements are limited to data collected through HTTP or other Web transport protocols. Also, if access is provided through the Web, use of strong authentication and security mechanisms for such access is recommended; however, security issues are outside the scope of this document.

The ACCESS element must contain one of the following elements:

<nonident/>: Identifiable Data is Not Used
<all/>: All Identifiable Information: access is given to all identifiable information.
<contact_and_other/>: Identifiable Contact Information and Other Identifiable Information: access is given to identifiable online and physical contact information as well as to other information linked to an identifiable person.
<ident_contact/>: Identifiable Contact Information: access is given to identifiable online and physical contact information (e.g., users can access things such as a postal address).
<other_ident/>: Other Identifiable Information: access is given to certain other information linked to an identifiable person (e.g., users can access things such as their online account charges).
<none/>: None: no access to identifiable information is given.

[15]

access

"<ACCESS>"
access_disclosure
*extension
</ACCESS>

[16]

access-disclosure

"<nonident/>"    | ; Identifiable Data is Not Used
"<ident_contact/>"     | ; Identifiable Contact Information
"<other_ident/>"       | ; Other Identifiable Information
"<contact_and_other/>" | ; Identifiable and
                           Other Contact Information
"<all/>"               | ; All Identifiable Information
"<none/>"                ; None

3.2.4 The `DISPUTES` element

A policy SHOULD contain a DISPUTES-GROUP element, which contains one or more DISPUTES elements. These elements describe dispute resolution procedures that may be followed for disputes about a services' privacy practices. Each DISPUTES element can optionally contain a LONG-DESCRIPTION element, an IMG element, and a REMEDIES element. Service providers with multiple dispute resolution procedures should use a separate DISPUTES element for each. Since different dispute procedures have separate remedy processes, each DISPUTES element would need a separate LONG-DESCRIPTION, IMG tag and REMEDIES element, if they are being used.

<DISPUTES>

Describes dispute resolution procedures that may be followed for disputes about a services' privacy practices, or in case of protocol violation.

resolution-type (mandatory attribute)

takes one of the following four values:

Customer service [service]: Individual may complain to the web site's customer service representative for resolution of disputes regarding the use of collected data. The description MUST include information about how to contact customer service.
Independent organization [independent]: Individual may complain to an independent organization for resolution of disputes regarding the use of collected data. The description MUST include information about how to contact the third party organization.
Court [court]: Individual may file a legal complaint against the web site.
Applicable law [law]: Disputes arising in connection with the privacy statement will be resolved in accordance with the law referenced in the description.

service (mandatory attribute)

URI of the customer service web page or independent organization, or URI for information about the relevant court or applicable law

verification

URI or certificate that can be used for verification purposes. It is anticipated that seal providers will provide a mechanism for verifying a site's claim that they have a seal.

short-description

A short human readable description of the name of the appropriate legal forum, applicable law, or third party organization; or contact information for customer service if not already provided at the service URI. No more than 255 characters.

The DISPUTES element can contain a LONG-DESCRIPTION element, where a human readable description is present: this should contain the name of the appropriate legal forum, applicable law, or third party organization; or contact information for customer service if not already provided at the service URI.

<LONG-DESCRIPTION>: This element contains a (possibly long) human readable description.

<IMG>: An image logo (for example, of the independent organization or relevant court)
src (mandatory attribute): URI of the image logo
width: width in pixels of the image logo
height: height in pixels of the image logo
alt: very short textual alternative for the image logo

[17]	disputes-group	=	"<DISPUTES-GROUP>" extension 1dispute *extension "</DISPUTES-GROUP>"
[18]	dispute	=	"<DISPUTES" " resolution-type=" '"'("service"\|"independent"\|"court"\|"law")'"' " service=" quoted-URI [" verification=" quoted-string] [" short-description=" quoted-string] "/>" [longdescription] [image] [remedies] *extension "</DISPUTES>"
[19]	longdescription	=	<LONG-DESCRIPTION> PCDATA </LONG-DESCRIPTION>
[20]	image	=	"<IMG src=" quoted-URI [" width=" `"` number `"`] [" height=" `"` number `"`] [" alt=" quoted-string] "/>"
[21]	quoted-string	=	`"` string `"`
Here, string is defined as a sequence of characters (with " and & escaped), and `PCDATA` is defined as in [XML].

Note that there can be multiple assurance services, specified via multiple occurrences of DISPUTES within the DISPUTES-GROUP element. These fields are expected to be used in a number of ways, including representing that one's privacy practices are self assured, audited by a third party, or under the jurisdiction of a regulatory authority.

3.2.5 The `REMEDIES` element

Each DISPUTES element SHOULD contain a REMEDIES element that specifies the possible remedies in case a policy breach occurs.

<REMEDIES>: Remedies in case a policy breach occurs.

The REMEDIES element must contain one or more of the following:

<correct/>: Errors or wrongful actions arising in connection with the privacy policy will be remedied by the service.
<money/>: If the service provider violates its privacy policy it will pay the individual an amount specified in the human readable privacy policy or the amount of damages.
<law/>: Remedies for breaches of the policy statement will be determined based on the law referenced in the human readable description.

[22]	remedies	=	"<REMEDIES>" 1remedy extension "</REMEDIES>"
[23]	remedy	=	"<correct/>" \| "<money/>" \| "<law/>"

3.3 Statements

Statements describe data practices that are applied to particular types of data.

3.3.1 The `STATEMENT` element

The STATEMENT element is a container that groups together a PURPOSE element, a RECIPIENT element, a RETENTION element, a DATA-GROUP element, and optionally a CONSEQUENCE element and one or more extensions. All of the data referenced by the DATA-GROUP is handled according to the disclosures made in the other elements contained by the statement. Thus, sites may group elements that are handled the same way and create a statement for each group. Sites that would prefer to disclose separate purposes and other information for each kind of data they collect can do so by creating a separate statement for each data element.

<STATEMENT>: data practices as applied to data elements.

[24]

statement-block

"<STATEMENT>"
*extension
[consequence]
purpose
recipient
retention
1*data-group
*extension
"</STATEMENT>"

To simplify practice declaration, service providers may aggregate any of the disclosures (purposes, recipients, and identifiable use) within a statement over data elements. Service providers MUST make such aggregations as an additive operation. For instance, a site that distributes your age to ours (ourselves and our agents), but distributes your zip code to unrelated (unrelated third parties), MAY say they distribute your name and zip code to ours and unrelated. Such a statement appears to distribute more data than actually happens. It is up to the service provider to determine if their disclosure deserves specificity or brevity.

Also, one must always disclose all options that apply. Consider a site with the sole purpose of collecting information for the purposes of contact (Contacting Visitors for Marketing of Services or Products). Even though this is considered to be for the current (Completion and Support of Current Activity) purpose, the site must state both contact and current purposes. Consider a site which distributes information to ours in order to redistribute it to public: the site must state both ours and public recipients.

3.3.2 The `CONSEQUENCE` element

STATEMENT elements may optionally contain a CONSEQUENCE element that can be shown to a human user to provide further explanation about a site's practices.

<CONSEQUENCE>: Consequences that can be shown to a human user to explain why the suggested practice may be valuable in a particular instance even if the user would not normally allow the practice.

[25]

consequence

"<CONSEQUENCE>" 
PCDATA
"</CONSEQUENCE>"

3.3.3 The `PURPOSE` element

Each STATEMENT element MUST contain a PURPOSE element that contains one or more purposes of data collection or uses of data. Sites MUST classify their data practices into one or more of the six specified purposes.

<PURPOSE>: purposes for data processing relevant to the Web.

The PURPOSE element MUST contain one or more of the following:

<current/>: Completion and Support of Current Activity: Information may be used by the service provider to complete the activity for which it was provided, such as the provision of information, communications, or interactive services -- for example to return the results from a Web search, to forward email, or place an order.
<admin/>: Web Site and System Administration: Information may be used for the technical support of the Web site and its computer system. This would include processing computer account information, and information used in the course of securing and maintaining the site.
<develop/>: Research and Development: Information may be used to enhance, evaluate, or otherwise review the site, service, product, or market. This does not include personal information used to tailor or modify the content to the specific individual nor information used to evaluate, target, profile or contact the individual.
<customization/>: Affirmative Customization: Information may be used to tailor or modify the content or design of the site only to specifications affirmatively selected by the particular individual during a single visit or multiple visits to the site. For example, a financial site that lets users select several stocks whose current prices are displayed whenever the user visits.
<tailoring/>: One-time Tailoring: Information may be used to tailor or modify content or design of the site not affirmatively selected by the particular individual where the information is used only for a single visit to the site and not used for any kind of future customization. For example, an online store that suggests other items a visitor may wish to purchase based on the items he has already placed in his shopping basket.
<pseudonym/>: Pseudononymous Profiling: Information may be used to create or build a record of a particular individual or computer that is tied to a pseudononymous identifier, without tying personally-identifiable information (such as name, address, phone number, email address, or IP address) to the record. This profile will be used to determine the habits, interests, or other characteristics of individuals, but it will not be used to attempt to identify specific individuals.
<profiling/>: Individual Profiling: Information may be used to create or build a record on the particular individual or computer for the purpose of compiling habits or personally identifiable information of that individual or computer. For example, an online store that suggests items a visitor may wish to purchase based on items he has purchased during previous visits to the web site.
<contact/>: Contacting Visitors for Marketing of Services or Products: Information may be used to contact the individual for the promotion of a product or service. This includes notifying visitors about updates to the Web site.
<other-purpose> string </other-purpose>: Other Uses: Information may be used in other ways not captured by the above definitions. (A human readable explanation should be provided in these instances).

Each type of purpose can have the following optional attribute:

change_preferences: Whether or not the site allows individuals to change their preferences with regard to a particular purpose. The default is "no". If the "yes" value is used it indicates that the site offers some mechanism for individuals to request that their data not be used for that purpose. There MUST be information about how to take advantage of this mechanism at the discuri.

[26]	yesno	=	"yes" \| "no"
[27]	purpose	=	"<PURPOSE>" 1purposevalue extension "</PURPOSE>"
[28]	purposevalue	=	"<current" [change] "/>" \| ; Completion and Support of Current Activity "<admin" [change] "/>" \| ; Web Site and System Administration "<develop" [change] "/>" \| ; Research and Development "<contact" [change] "/>" \| ; Contacting Visitors for Marketing of Services or Products "<customization" [change] "/>" \| ; Affirmative Customization "<targeting" [change] "/>" \| ; One-time Targeting "<profiling" [change] "/>" \| ; Individual Profiling "<other-purpose" [change] " >" PCDATA "</other-purpose>"; Other Uses
[29]	change	=	" change_preferences=" `"` yesno `"`

Service providers MUST use the above elements to explain the purpose of data collection. Service providers MUST disclose all that apply. If a service provider does not disclose that a data element will be used for a given purpose, that is a representation that data will not be used for that purpose. Service providers that disclose that they use data for "other" purposes MUST provide human readable explanations of those purposes.

Note, that the working group discussed at length the possibility of allowing sites to distinguish between purposes they may engage in and purposes they will engage in. The consensus of the working group was that such a distinction is not necessary. However, some members disagreed with this conclusion stating:

Yes, no and may all need to be response options in the vocabulary. If no and may are the only options, then the meaning of may is corrupted to equal yes. May should be an option that reflects its true meaning -- yes or no. If may by default means yes, because yes is not provided as a response option, the consumer will be misled. May should be used to imply that there are a set of rules underlying the term that consumers can refer to understand a privacy policy. If may means yes, the consumer is less likely to investigate via a click-through to the Web site's privacy policy. Potentially, this seemingly simple solution -- no and may -- will be a significant barrier to commerce as consumers are confused by the meaning of the truncated choices of only no and may. Those who argue that providing all three choices -- yes, may, no -- is an attempt by Web sites to mislead consumers are missing the point. In the arena of privacy protection, accuracy in stating a privacy policy is critical to building trust and confidence in the consumer about how information is used. In the interest of software simplicity, limiting consumer preference choices to no and may will do a disservice to the consumer -- and to the Web sites that are trying to communicate accurately with consumers about their policies.

3.3.4 The `RECIPIENT` element

Each STATEMENT element MUST contain a RECIPIENT element that contains one or more recipients of the collected data. Sites MUST classify their recipients into one or more of the six recipients specified.

<RECIPIENT>: the legal entity, or domain, beyond the service provider and its agents where data may be distributed.

The RECIPIENT element MUST contain one or more of the following:

<ours/>: Ourselves and/or our agents: Ourselves and our agents. An agent in this instance is defined as a third party that processes data only on behalf of the service provider for the completion of the stated purposes. (e.g., The service provider and its printing bureau which prints address labels and does nothing further with the information.)
<delivery/>: Delivery services possibly following different practices: Legal entities performing delivery services that may use data for purposes other than completion of the stated purpose. This should also be used for delivery services whose data practices are unknown.
<same/>: Legal entities following our practices: Legal entities who use the data on their own behalf under equable practices. (e.g., consider a service provider that grants the user access to collected personal information, and also provides it to a partner who uses it once but discards it. Since the recipient, who has otherwise similar practices, cannot grant the user access to information that it discarded, they are considered to have equable practices.)
<other-recipient/>: Legal entities following different practices: Legal entities that are constrained by and accountable to the original service provider, but may use the data in a way not specified in the service provider's practices (e.g. The service provider collects data that is shared with a partner who may use it for other purposes. However, it is in the service provider's interest to ensure that the data is not used in a way that would be considered abusive to the users' and its own interests.)
<unrelated/>: Unrelated third parties: Legal entities whose data usage practices are not known by the original service provider.
<public/>: Public fora: Public fora such as bulletin boards, public directories, or commercial CD-ROM directories.

[30]

recipient

"<RECIPIENT>" 
1*recipientvalue 
*extension
"</RECIPIENT>"

[31]

recipientvalue

"<ours/>"               |  ; only ourselves and our agents
"<same/>"               |  ; legal entities following our practices
"<other-recipient/>"    |  ; legal entities following different practices
"<delivery/>"           |  ; delivery services following different practices
"<public/>"             |  ; public fora
"<unrelated/>"             ; unrelated third parties

Service providers MUST disclose all the recipients that apply. Note that in some cases the above set of recipients may not completely describe all the recipients of data. For example, the issue of transaction facilitators, such as shipping or payment processors, who are necessary for the completion and support of the