New features make the web a stronger and livelier platform. Throughout the feature development process there are both foreseeable and unexpected security and privacy risks. These risks may arise from the nature of the feature, some of its part(s), or unforeseen interactions with other features. Such risks and may be mitigated through careful design and application of security and privacy design patterns.
Standardizing web features presents unique challenges. Descriptions, protocols and algorithms need to be considered strictly before they are broadly adopted by vendors with large user bases. If features are found to have undesirable privacy properties after they are standardized, then, browser vendors may break compatibility in their implementations to protect users' privacy as the user agent is the user’s agent.
This is why each Working Group needs to consider security and privacy by design and by default. This consideration is mandatory. Assessing the impact of a mechanism on privacy should be done from the ground up, during each iteration of the specification. Thinking about security and privacy risks and mitigations early in a project is the best approach as it helps ensure the privacy of your feature at an architectural level and ensures the result, descriptions, protocols, and algorithms incorporate privacy by default as opposed to through possible implementation mitigations.
1.1. How To Use The Questionnaire
This document is meant to help developers and reviewers. It encourages early review by posing a number of questions that you as an individual reader, writer, or contributor can ask and that working groups and spec editors need to consider, prior requesting a formal review. The intent includes highlighting areas which historically may have had implications to user’s security or privacy, and thereby to focus the editor, working group attention, and reviewers' attention. As such, the questionnaire is evidence and research based and provides examples and past cases.
The audience of this document is general:
The editors and contributors who are responsible for the development of the feature,
The W3C TAG, who receive the questionnaire along with the request, and in line with the W3C Process,
External audience (developers, designers, etc.) wanting to understand the possible security and privacy implications.
2. Questions to Consider
2.1. What information might this feature expose to Web sites or other parties, and for what purposes is that exposure necessary?
Just because information can be exposed to the web doesn’t mean that it should be. How does exposing this information to an origin benefit a user? Is the benefit outweighed by the potential risks? If so, how?
In answering this question, it often helps to ensure that the use cases your feature and specification is enable are made clear in the specification itself to ensure that TAG and PING understand the feature-privacy tradeoffs being made.
2.2. Is this specification exposing the minimum amount of information necessary to power the feature?
Regardless of what data is being exposed, is the specification exposing the bare minimum necessary to achieve the desired use cases? If not, why not and why expose the additional information?
2.3. How does this specification deal with personal information or personally-identifiable information or information derived thereof?
Personal information is data about a user (home address) or information that could be used to identify a user (alias or email address). This is distinct from personally identifiable information (PII), as the exact definition of what’s considered PII varies from jurisdiction to jurisdiction.
If the specification under consideration exposes personal information or PII or their derivatives that could still identify an individual to the web, it’s important to consider ways to mitigate the obvious impacts. For instance:
A feature which uses biometric data (fingerprints or retina scans) should refuse to expose the raw data to the web, instead using the raw data only to unlock some origin-specific and ephemeral secret and transmitting that secret instead.
Including a factor of user mediation should be considered, in order to ensure that no data is exposed without a user’s explicit choice (and hopefully understanding). One way to achieve this may be the use of Permission API [PERMISSIONS], or additional dialogs like in Payment Request API [PAYMENT-REQUEST]
2.4. How does this specification deal with sensitive information?
Just because data is not personal information or PII, that does not mean that it is not sensitive information; moreover, whether any given information is sensitive may vary from user to user. Data to consider if sensitive includes: financial data, credentials, health information, location, or credentials. When this data is exposed to the web, steps should be taken to mitigate the risk of exposing it.
Credential Management [CREDENTIAL-MANAGEMENT-1] allows sites to request
a user’s credentials from a user agent’s password manager in order to
sign the user in quickly and easily. This opens the door for abuse, as
a single XSS vulnerability could expose user data trivially to
the risk by offering the username and password as only an opaque
and strongly suggests that authors use Content Security Policy [CSP] with reasonable connect-src and form-action values to further mitigate the risk of exfiltration.
Geolocation information can serve many use cases at a much less granular precision than the user agent can offer. For instance, a restaurant recommendation can be generated by asking for a user’s city-level location rather than a position accurate to the centimeter.
A Geofencing proposal [GEOFENCING-EXPLAINED] ties itself to service workers and therefore to encrypted and authenticated origins.
2.5. Does this specification introduce new state for an origin that persists across browsing sessions?
Allowing an origin to persist data on a user’s device across browsing sessions introduces the risk that this state may be used to track a user without their knowledge or control, either in a first party or third party contexts. New state persistence mechanisms should not be introduced without mitigations to prevent it from being used to track users across domains or without control over clearing this state. And, are there specific caches that a user agent should specially consider?
Service Worker [SERVICE-WORKERS] intercept all requests made by an origin, allowing sites to function perfectly even when offline. A maliciously-injected service worker, however, would be devastating (as documented in Service Workers §6 Security Considerations). They mitigate the risks an active network attacker or XSS vulnerability present by requiring an encrypted and authenticated connection in order to register a service worker.
Platform-specific DRM implementations might expose origin-specific information in order to help identify users and determine whether they ought to be granted access to a specific piece of media. These kinds of identifiers should be carefully evaluated to determine how abuse can be mitigated; identifiers which a user cannot easily change are very valuable from a tracking perspective, and protecting the identifiers from an active network attacker is an important concern.
indexedDB, etc. all
allow an origin to store information about a user, and retrieve it later,
directly or indirectly. User agents mitigate the risk that these kinds of
storage mechanisms will form a persistent identifier by offering users the
ability to wipe out the data contained in these types of storage.
2.6. What information from the underlying platform, e.g. configuration data, is exposed by this specification to an origin?
If so, is the information exposed from the underlying platform consistent across origins? This includes but is not limited to information relating to the user configuration, system information including sensors, and communication methods.
When a specification exposes specific information about a host to an origin, if that information changes rarely and is not variable across origins, then it can be used to uniquely identify a user across two origins — either directly because any given piece of information is unique or because the combination of disparate pieces of information are unique and can be used to form a fingerprint [FINGERPRINTING-GUIDANCE]. Specifications and user agents should treat the risk of fingerprinting by carefully considering the surface of available information, and the relative differences between software and hardware stacks. Sometimes reducing fingerprintability may as simple as ensuring consistency, i.e. ordering the list of fonts, but sometimes may be more complex.
Such information should not be revealed to an origin without a user’s knowledge and consent barring mitigations in the specification to prevent the information from being uniquely identifying or able to unexpectedly exfiltrate data.
RENDERER string exposed by some WebGL implementations
improves performance in some kinds of applications, but does so at the
cost of adding persistent state to a user’s fingerprint. These kinds of
device-level details should be carefully weighed to ensure that the costs
are outweighed by the benefits.
NavigatorPlugins list exposed via the DOM practically never
changes for most users. Some user agents have taken steps to reduce the
entropy introduced by disallowing direct enumeration of the plugin list.
2.7. Does this specification allow an origin access to sensors on a user’s device
If so, what kind of sensors and information derived from those sensors does this standard expose to origins?
Information from sensors may serve as a fingerprinting vector across origins. In addition, sensor also reveals something about my device or environment and that fact might be what is sensitive. In addition, as technology advances, mitigations in place at the time a specification is written may have to be reconsidered as the threat landscape changes.
Sensor data might even become a cross-origin identifier when the sensor reading is relatively stable, for example for short time periods (seconds, minutes, even days), and is consistent across-origins. In fact, if two user-agents expose the same sensor data the same way, it may become a cross-browser, possibly even a cross-device identifier.
As gyroscopes advanced, their sampling rate had to be lowered to prevent them from being used as a microphone as one such example [GYROSPEECHRECOGNITION].
ALS sensors could allowed for an attacker to exfiltrate whether or not a user had visited given links [OLEJNIK-ALS].
Even relatively short lived data, like the battery status, may be able to serve as an identifier if misused/abused [OLEJNIK-BATTERY].
2.8. What data does this specification expose to an origin? Please also document what data is identical to data exposed by other features, in the same or different contexts.
As noted above in § 3.3 Same-Origin Policy Violations, the same-origin policy is an important security barrier that new features need to carefully consider. If a specification exposes details about another origin’s state, or allows POST or GET requests to be made to another origin, the consequences can be severe.
Content Security Policy [CSP] unintentionally exposed redirect targets cross-origin by allowing one origin to infer details about another origin through violation reports (see [HOMAKOV]). The working group eventually mitigated the risk by reducing a policy’s granularity after a redirect.
Beacon [BEACON] allows an origin to send POST requests to an endpoint on another origin. They decided that this feature didn’t add any new attack surface above and beyond what normal form submission entails, so no extra mitigation was necessary.
2.9. Does this specification enable new script execution/loading mechanisms?
HTML Imports [HTML-IMPORTS] create a new script-loading mechanism, using
script, which might be easy to overlook when evaluating an application’s attack surface. The working group notes this risk, and ensured that they required reasonable interactions with Content Security Policy’s script-src directive.
What about style?
2.10. Does this specification allow an origin to access other devices?
If so, what devices does this specification allow an origin to access?
Accessing other devices, both via network connections and via direct connection to the user’s machine (e.g. via Bluetooth, NFC, or USB), could expose vulnerabilities - some of these devices were not created with web connectivity in mind and may be inadequately hardened against malicious input, or with the use on the web.
Exposing other devices on a user’s local network also has significant privacy risk:
If two user agents have the same devices on their local network, an attacker may infer that the two user agents are running on the same host or are being used by two separate users who are in the same physical location.
Enumerating the devices on a user’s local network provides significant entropy that an attacker may use to fingerprint the user agent.
If the specification exposes persistent or long lived identifiers of local network devices, that provides attackers with a way to track a user over time even if a user takes steps to prevent such tracking (e.g. clearing cookies and other stateful tracking mechanisms).
Direct connections might be also be used to bypass security checks that other APIs would provide. For example, attackers used the WebUSB API to access others sites' credentials on a hardware security, bypassing same-origin checks in an early U2F API. [YUBIKEY-ATTACK]
The Network Service Discovery API [DISCOVERY-API] recommended CORS preflights before granting access to a device, and requires user agents to involve the user with a permission request of some kind.
Likewise, the Web Bluetooth [WEB-BLUETOOTH] has an extensive discussion of such issues in Web Bluetooth §2 Security and privacy considerations, which is worth reading as an example for similar work.
2.11. Does this specification allow an origin some measure of control over a user agent’s native UI?
Features that allow for control over a user agent’s UI (e.g. full screen mode) or changes to the underlying system (e.g. installing an ‘app’ on a smartphone home screen) may surprise users or obscure security / privacy controls. To the extent that your feature does allow for the changing of a user agent’s UI, can it effect security / privacy controls? What analysis confirmed this conclusion?
2.12. What temporary identifiers might this this specification create or expose to the web?
If a standard exposes a temporary identifier to the web, the identifier should be short lived and should rotate on some regular duration to mitigate the risk of this identifier being used to track a user over time. When a user clears state in their user agent, these temporary identifiers should be cleared to prevent re-correlation of state using a temporary identifier.
If this specification does create or expose a temporary identifier to the web, how is it exposed, when, to what entities, and, how frequently is it rotated?
Example temporary identifiers include TLS Channel ID, Session Tickets, and IPv6 addresses.
The index attribute in the Gamepad API [GAMEPAD] — an integer that starts at zero, increments, and is reset — is a good example of a privacy friendly temporary identifier.
2.13. How does this specification distinguish between behavior in first-party and third-party contexts?
The behavior of a feature should be considered not just in the context of its being used by a first party origin that a user is visiting but also the implications of its being used by an arbitrary third party that the first party includes. When developing your specification, consider the implications of its use by third party resources on a page and, consider if support for use by third party resources should be optional to conform to the specification. If supporting use by third party resources is mandatory for conformance, please explain why and what privacy mitigations are in place. This is particularly important as user agents may take steps to reduce the availability or functionality of certain features to third parties if the third parties are found to be abusing the functionality.
2.14. How does this specification work in the context of a user agent’s Private Browsing or "incognito" mode?
Each major user agent implements a private browsing / incognito mode feature with significant variation across user agents in threat models, functionality, and descriptions to users regarding the protections afforded [WU-PRIVATE-BROWSING].
One typical commonality across user agents' private browsing / incognito modes is that they have a set of state than the user agents’ in their ‘normal’ modes.
Does the specification provide information that would allow for the correlation of a single user’s activity across normal and private browsing / incognito modes? Does the specification result in information being written to a user’s host that would persist following a private browsing / incognito mode session ending?
There has been research into both:
Using features to fingerprint a browser and correlate private and non-private mode sessions for a given user. [OLEJNIK-PAYMENTS]
2.15. Does this specification have a "Security Considerations" and "Privacy Considerations" section?
Documenting the various concerns and potential abuses in "Security Considerations" and "Privacy Considerations" sections of a document is a good way to help implementers and web developers understand the risks that a feature presents, and to ensure that adequate mitigations are in place. Simply adding a section to your specification with yes/no responses to the questions in this document is insufficient.
If it seems like a feature does not have security or privacy impacts, then say so inline in the spec section for that feature:
There are no known security or privacy impacts of this feature.
Saying so explicitly in the specification serves several purposes:
Shows that a spec author/editor has explicitly considered security and privacy when designing a feature.
Provides some sense of confidence that there might be no such impacts.
Challenges security and privacy minded individuals to think of and find even the potential for such impacts.
Demonstrates the spec author/editor’s receptivity to feedback about such impacts.
Demonstrates a desire that the specification should not be introducing security and privacy issues
[RFC3552] provides general advice as to writing Security Consideration sections. Generally, there should be a clear description of the kinds of privacy risks the new specification introduces to for users of the web platform. Below is a set of considerations, informed by that RFC, for writing a privacy considerations section.
Authors must describe:
What privacy attacks have been considered?
What privacy attacks have been deemed out of scope (and why)?
What privacy mitigations have been implemented?
What privacy mitigations have considered and not implemented (and why)?
In addition, attacks considered must include:
Unexpected exfiltration of data through abuse of sensors;
Unexpected usage of the specification / feature by third parties;
If the specification includes identifiers, the authors must document what rotation period was selected for the identifiers and why.
If the specification introduces new state to the user agent, the authors must document what guidance regarding clearing said storage was given and why.
There should be a clear description of the residual risk to the user after the privacy mitigations has been implemented.
The crucial aspect is to actually considering security and privacy. All new specifications must have security and privacy considerations sections to be considered for wide reviews. Interesting features added to the web platform generally often already had security and/or privacy impacts.
2.16. Does this specification allow downgrading default security characteristics?
Does this feature allow for a site to opt-out of security settings to accomplish some piece of functionality? If so, in what situations does your specification allow such security setting downgrading and what mitigations are in place to make sure optional downgrading doesn’t dramatically increase risks?
2.17. What should this questionnaire have asked?
This questionnaire is not exhaustive. After completing a privacy review, it may be that there are privacy aspects of your specification that a strict reading, and response to, this questionnaire, would not have revealed. If this is the case, please convey those privacy concerns, and indicate if you can think of improved or new questions that would have covered this aspect.
3. Threat Models
To consider security and privacy it is convenient to think in terms of threat models, a way to illuminate the possible risks.
There are some concrete privacy concerns that should be considered when developing a feature for the web platform [RFC6973]:
Surveillance: Surveillance is the observation or monitoring of an individual’s communications or activities.
Stored Data Compromise: End systems that do not take adequate measures to secure stored data from unauthorized or inappropriate access.
Intrusion: Intrusion consists of invasive acts that disturb or interrupt one’s life or activities.
Misattribution: Misattribution occurs when data or communications related to one individual are attributed to another.
Correlation: Correlation is the combination of various pieces of information related to an individual or that obtain that characteristic when combined.
Identification: Identification is the linking of information to a particular individual to infer an individual’s identity or to allow the inference of an individual’s identity.
Secondary Use: Secondary use is the use of collected information about an individual without the individual’s consent for a purpose different from that for which the information was collected.
Disclosure: Disclosure is the revelation of information about an individual that affects the way others judge the individual.
Exclusion: Exclusion is the failure to allow individuals to know about the data that others have about them and to participate in its handling and use.
In the mitigations section, this document outlines a number of techniques that can be applied to mitigate these risks.
Enumerated below are some broad classes of threats that should be considered when developing a web feature.
3.1. Passive Network Attackers
A passive network attacker has read-access to the bits going over the wire between users and the servers they’re communicating with. She can’t modify the bytes, but she can collect and analyze them.
Due to the decentralized nature of the internet, and the general level of interest in user activity, it’s reasonable to assume that practically every unencrypted bit that’s bouncing around the network of proxies, routers, and servers you’re using right now is being read by someone. It’s equally likely that some of these attackers are doing their best to understand the encrypted bits as well, including storing encrypted communications for later cryptanalysis (though that requires significantly more effort).
The IETF’s "Pervasive Monitoring Is an Attack" document [RFC7258] is useful reading, outlining some of the impacts on privacy that this assumption entails.
Governments aren’t the only concern; your local coffee shop is likely to be gathering information on its customers, your ISP at home is likely to be doing the same.
3.2. Active Network Attackers
ISPs and caching proxies regularly cache and compress images before delivering them to users in an effort to reduce data usage. This can be especially useful for users on low-bandwidth, high-latency devices like phones.
If your ISP is willing to modify substantial amounts of traffic flowing through it for profit, it’s difficult to believe that state-level attackers will remain passive.
3.3. Same-Origin Policy Violations
The same-origin policy is the cornerstone of security on the web; one origin should not have direct access to another origin’s data (the policy is more formally defined in Section 3 of [RFC6454]). A corollary to this policy is that an origin should not have direct access to data that isn’t associated with any origin: the contents of a user’s hard drive, for instance. Various kinds of attacks bypass this protection in one way or another. For example:
Cross-site scripting attacks involve an attacker tricking an origin into executing attacker-controlled code in the context of a target origin.
Cross-site request forgery attacks trick user agents into exerting a user’s ambient authority on sites where they’ve logged in by submitting requests on their behalf.
3.4. Third-Party Tracking
The simplest example is injecting a link to a site that behaves differently under specific condition, for example based on the fact that user is or is not logged to the site. This may reveal that the user has an account on a site.
3.5. Legitimate Misuse
Even when powerful features are made available to developers, it does not mean that all the uses should always be a good idea, or justified; in fact, data privacy regulations around the world may even put limits on certain uses of data. In the context of first party, a legitimate website is potentially able to interact with powerful features to learn about the user behavior or habits. For example:
Tracking the user while browsing the website via mechanisms such as mouse move tracking
Behavioral profiling of the user based on the usage patterns
Accessing powerful features enabling to reason about the user system, himself or the user surrounding, such as a webcam, Web Bluetooth or sensors
This point is admittedly different from others - and underlines that even if something may be possible, it does not mean it should always be done, including the need for considering a privacy impact assessment or even an ethical assessment. When designing a specification with security and privacy in mind, all both use and misuse cases should be in scope.
4. Mitigation Strategies
To mitigate the security and privacy risks you’ve identified in your specification as you’ve filled out the questionnaire, you may want to apply one or more of the mitigations described below to your feature.
4.1. Data Minimization
Minimization is a strategy that involves exposing as little information to other communication partners as is required for a given operation to complete. More specifically, it requires not providing access to more information than was apparent in the user-mediated access or allowing the user some control over which information exactly is provided.
For example, if the user has provided access to a given file, the object representing that should not make it possible to obtain information about that file’s parent directory and its contents as that is clearly not what is expected.
In context of data minimization it is natural to ask what data is passed around between the different parties, how persistent the data items and identifiers are, and whether there are correlation possibilities between different protocol runs.
For example, the W3C Device APIs Working Group has defined a number of requirements in their Privacy Requirements document. [DAP-PRIVACY-REQS]
Data minimization is applicable to specification authors and implementers, as well as to those deploying the final service.
As an example, consider mouse events. When a page is loaded, the application has no way of knowing whether a mouse is attached, what type of mouse it is (e.g., make and model), what kind of capabilities it exposes, how many are attached, and so on. Only when the user decides to use the mouse — presumably because it is required for interaction — does some of this information become available. And even then, only a minimum of information is exposed: you could not know whether it is a trackpad for instance, and the fact that it may have a right button is only exposed if it is used. For instance, the Gamepad API makes use of this data minimization capability. It is impossible for a Web game to know if the user agent has access to gamepads, how many there are, what their capabilities are, etc. It is simply assumed that if the user wishes to interact with the game through the gamepad then she will know when to action it — and actioning it will provide the application with all the information that it needs to operate (but no more than that).
The way in which the functionality is supported for the mouse is simply by only providing information on the mouse’s behaviour when certain events take place. The approach is therefore to expose event handling (e.g., triggering on click, move, button press) as the sole interface to the device.
Two features that have minimized the data they make available are:
The user agent should not expose high precision readouts
Limit maximum sampling frequency,
4.2. Default Privacy Settings
Users often do not change defaults, as a result, it is important that the default mode of a specification minimizes the amount, identifiability, and persistence of the data and identifiers exposed. This is particularly true if a protocol comes with flexible options so that it can be tailored to specific environments.
4.3. Explicit user mediation
If the security or privacy risk of a feature cannot otherwise be mitigated in a specification, optionally allowing an implementer to prompt a user may be the best mitigation possible, understanding it does not entirely remove the privacy risk. If the specification does not allow for the implementer to prompt, it may result in divergence implementations by different user agents as some user agents choose to implement more privacy-friendly version.
It is possible that the risk of a feature cannot be mitigated because the risk is endemic to the feature itself. For instance, [GEOLOCATION-API] reveals a user’s location intentionally; user agents generally gate access to the feature on a permission prompt which the user may choose to accept. This risk is also present and should be accounted for in features that expose personal data or identifiers.
Designing such prompts is difficult as is determining the duration that the permission should provide.
Often, the best prompt is one that is clearly tied to a user action, like the file picker, where in response to a user action, the file picker is brought up and a user gives access to a specific file to an individual site.
Generally speaking, the duration and timing of the prompt should be inversely proportional to the risk posed by the data exposed. In addition, the prompt should consider issues such as:
How should permission requests be scoped? Especially when requested by an embedded third party iframe?
Should persistence be based on the pair of top-level/embedded origins or a different scope?
How is it certain that the prompt is occurring in context of requiring the data and at a time that it is clear to the user why the prompt is occurring.
Explaining the implications of permission before prompting the user, in a way that is accessible and localized -- _who_ is asking, _what_ are they asking for, _why_ do they need it?
What happens if the user rejects the request at the time of the prompt or if the user later changes their mind and revokes access.
These prompts should also include considerations for what, if any, control a user has over their data after it has been shared with other parties. For example, are users able to determine what information was shared with other parties?
4.4. Explicitly restrict the feature to first party origins
As described in the "Third-Party Tracking" section, a significant feature of the web is the mixing of first and third party content in a single page, but, this introduces risk where the third party content can use the same set of web features as the first party content.
Authors should explicit specify the feature’s scope of availability:
When a feature should be made available to embedded third parties -- and often first parties should be able to explicitly control that (using iframe attributes or feature policy)
Whether a feature should be available in the background or only in the top-most, visible tab.
Whether a feature should be available to offline service workers.
Whether events will be fired simultaneously
Third party’s access to a feature should be an optional implementation for conformance.
4.5. Secure Contexts
If the primary risk that you’ve identified in your specification is the threat posed by active network attacker, offering a feature to an insecure origin is the same as offering that feature to every origin because the attacker can inject frames and code at will. Requiring an encrypted and authenticated connection in order to use a feature can mitigate this kind of risk.
Secure contexts also protect against passive network attackers. For example, if a page uses the Geolocation API and sends the sensor-provided latitude and longitude back to the server over an insecure connection, then any passive network attacker can learn the user’s location, without any feasible path to detection by the user or others.
However, requiring a secure context is not sufficient to mitigate many privacy risks or even security risks from other threat actors than active network attackers.
4.6. Drop the feature
Possibly the simplest way to mitigate potential negative security or privacy impacts of a feature is to drop the feature, though you should keep in mind that some security or privacy risks may be removed or mitigated by adding features to the platform. Every feature in a spec should be seen as potentially adding security and/or privacy risk until proven otherwise. Discussing dropping the feature as a mitigation for security or privacy impacts is a helpful exercise as it helps illuminate the tradeoffs between the feature, whether it is exposing the minimum amount of data necessary, and other possible mitigations.
Consider also the cumulative effect of feature addition to the overall impression that users have that it is safe to visit a web page. Doing things that complicate users' understanding that it is safe to visit websites, or that complicate what users need to understand about the safety of the web (e.g., adding features that are less safe) reduces the ability of users to act based on that understanding of safety, or to act in ways that correctly reflect the safety that exists.
Every specification should seek to be as small as possible, even if only for the reasons of reducing and minimizing security/privacy attack surface(s). By doing so we can reduce the overall security and privacy attack surface of not only a particular feature, but of a module (related set of features), a specification, and the overall web platform.
Mozilla dropped devicelight, deviceproximity and userproximity events
4.7. Making a privacy impact assessment
Some features are potentially supplying very sensitive data, and it is the responsibility of the end-developer, system owner, or manager to realize this and act accordingly in the design of his/her system. Some use may warrant conducting a privacy impact assessment, especially when data relating to individuals may be processed.
Specifications that expose such sensitive data should include a recommendation that websites and applications adopting the API — but not necessarily the implementing user agent — conduct a privacy impact assessment of the data that they collect.
A features that recommends such is:
[GENERIC-SENSOR] advises to consider performing of a privacy impact assessment
Documenting these impacts is important for organizations although it should be noted that there are limitations to putting this onus on organizations. Research has shown that sites often do not comply with security/privacy requirements in specifications. For example, in [DOTY-GEOLOCATION], it was found that none of the studied websites informed users of their privacy practices before the site prompted for location.