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When looking at the definition of user-controllable, which is used on 3.3.4 Error Prevention (Legal, Financial, Data ), there have been questions raised about what the term "accessed" means.
user-controllable data that is intended to be accessed by users Note: This does not refer to such things as Internet logs and search engine monitoring data. Example: Name and address fields for a user's account.
The Understanding document contains the current explanation:
User-controllable data is data that is intended to be accessed by users. (e.g., name and address for the user's account.) It does not refer such things as internet logs and search engine monitoring data.
Proposal: replace this paragraph with the following:
User-controllable data is user-viewable data that the user can change and/or delete through an intentional action. Examples of the user controlling such data would be updating the phone number and address for the user's account, or deleting a record of past invoices from a website. It does not refer such things as internet logs and search engine monitoring data that the user can't view or interact with directly.