- Wg-ancr - mailman.kantarainitiative.org

Fw: Public Comment to the Joint Committee on Advancing Information Technology, the Internet and Cybersecurity
by Salvatore D'Agostino 22 Apr '25

22 Apr '25

________________________________ From: Salvatore D'Agostino Sent: Monday, April 14, 2025 4:56 PM To: Tricia.Farley-Bouvier(a)mahouse.gov <Tricia.Farley-Bouvier(a)mahouse.gov>; Michael.Moore(a)masenate.gov <Michael.Moore(a)masenate.gov> Cc: Daniel Schleifer <dan(a)idmachines.com>; gigi.agassini(a)gmail.com <gigi.agassini(a)gmail.com> Subject: Public Comment to the Joint Committee on Advancing Information Technology, the Internet and Cybersecurity Joint Committee on Advanced Information Technology, the Internet and Cybersecurity Chairs, Thank you for the opportunity to comment on the legislation under consideration. The ability of security and privacy professionals to apply their skills for good are greatly enhanced by the power of law. Too often security measures and privacy compliance are put in place only as a reaction to something gone wrong. The comprehensive slate of legislation here empowers better design and operation of data processing systems, and associated products and services by organizations and citizens. Massachusetts and the United States have, in the past, led the way in terms of privacy rights and frameworks. The Fair Information Practice Principles (FIPPs<https://www.fpc.gov/resources/fipps/>) that are adopted into the ISO/IEC 29100:2024<https://www.iso.org/standard/85938.html> Privacy framework from 50 years ago still apply today. It is good to see Massachusetts come back into the fight with other states across the country in enacting substantial legislation. The Kantara Initiative, where I chair a workgroup<https://kantarainitiative.org/work-groups/ancr/> on Anchored Notice and Consent Receipt, recently published for public comment a set of transparency performance indicators that can be used to measure whether there is a valid basis for consent. This legislation provides the ability to add further to legal requirements that help to define consent. S45 and H78 for example have excellent language around the requirements for consent. What exists today in too many cases are the dark patterns referenced in the legislation, provides a light to expose and change them. In the work we do we reference laws and frameworks to create security and privacy technology for people, this legislation helps. At IDmachines, we believe that there is a great opportunity for innovation when it comes to privacy and security for people. We believe this can be done in a way that benefits all stakeholders, and provide a better data economy, and that we can do that in Massachusetts. In addition to the legislation we need privacy and security infrastructure for people. While that may seem like a big dig, it in fact can be done with a fraction of the investment and provide tremendous benefits to the Commonwealth its citizens and beyond. We can create an alternative to surveillance valley that provides more useful, secure, and private digital, and real world identity, access, and mobility. The establishment of a public registry for 3rd party collecting entities could be expanded to all PII Controllers, including all covered entities in the legislation. It could include all that operate in the state of MA. It would provide sufficient information so that people could understand who they are dealing with, as could a program operating on their behalf, as to whether their status as a covered entity was in good standing, in effect the availability of a certificate of good standing, and in the case of where they are not registered in the Commonwealth, the same from the jurisdiction of their registration. In the past, I had the honor to serve as the Chair and President of the Identity Ecosystem Steering Group, a public-private partnership in cooperation with the National Institute of Standards and Technology. We published and stood up an initial registry<https://idefregistry.edufoundation.kantarainitiative.org/>. There now exists an significant opportunity, even perhaps more than before. The attached recommendation gives an example of the information that could be aggregated into controller records in that registry. It would better enable direct digital interactions between people and organizations. It is possible to go beyond managing data brokers to enabling dynamic direct data, business, and personal exchanges and reduce the need and impact of things in the middle. Respectfully, Salvatore D’Agostino IDmachines LLC 4 Lamson Place Cambridge, MA 02139-2612 +1 617.201.4809 @idmachines https://idmachines.com<https://idmachines.com/> Disclaimer The information contained in this communication from the sender is confidential. It is intended solely for use by the recipient and others authorized to receive it. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking action in relation of the contents of this information is strictly prohibited and may be unlawful. If you have received this email in error, please delete it and advise the sender.

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ANCR WG call reminder - tomorrow 23rd, April / 1.00pm EST
by Gigi Agassini 22 Apr '25

22 Apr '25

Dear ANCR WG. This is a friendly reminder about our meeting scheduled for tomorrow at 1:00 PM EST. Agenda: Please find the agenda here: Agenda Link<https://kantara.atlassian.net/wiki/x/DQBYOg> Call Link: Join the Meeting<https://us06web.zoom.us/j/87282263538?pwd=K0RwY1g1b3pKeHdBcXpjeExVZUFpQT09> I look forward to seeing you all tomorrow. Kindest Regards, Gigi Agassini

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ANCR WG Minutes and Reminder for ANCR WG working session tomorrow
by Gigi Agassini 15 Apr '25

15 Apr '25

Dear ANCR WG. Thank you for attending Wednesday 9th's meeting. Please find the link to the minutes, which include the actions and discussions we covered: https://kantara.atlassian.net/wiki/x/MIBROQ If you notice anything missing or have any questions, please don't hesitate to reach out. This is a reminder for our ANCR WG Working session tomorrow Wednesday, April 16th at 1.00pm EST. meeting link: https://us06web.zoom.us/j/87282263538?pwd=K0RwY1g1b3pKeHdBcXpjeExVZUFpQT09 Best regards, Gigi Agassini

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FW: NEW | Privacy Framework 1.1 Initial Public Draft Release
by Salvatore D'Agostino 14 Apr '25

14 Apr '25

From: NIST Cybersecurity and Privacy Program <csrc.nist(a)service.govdelivery.com> Sent: Monday, April 14, 2025 3:07 PM To: Salvatore D'Agostino <sal(a)idmachines.com> Subject: NEW | Privacy Framework 1.1 Initial Public Draft Release <https://content.govdelivery.com/attachments/fancy_images/USNIST/2019/04/248…> View As Web Page<https://links-1.govdelivery.com/CL0/https:%2F%2Fcontent.govdelivery.com%2Fa…> <https://content.govdelivery.com/attachments/fancy_images/USNIST/2019/09/280…> NIST Cybersecurity and Privacy Program NEW | Privacy Framework 1.1 Initial Public Draft Release NIST is pleased to announce the release of the Privacy Framework 1.1 Initial Public Draft (IPD)<https://links-1.govdelivery.com/CL0/https:%2F%2Fdoi.org%2F10.6028%2FNIST.CS…>! The NIST Privacy Framework is a “living” tool meant to evolve to meet stakeholder needs, and the time has come to update to Version 1.1. This update builds on the success of Privacy Framework 1.0 by responding to current privacy risk management needs, realigning with NIST Cybersecurity Framework (CSF) 2.0, and enhancing usability. The following resources are included with the Privacy Framework 1.1 IPD release: * Privacy Framework 1.1 IPD Highlights video<https://links-1.govdelivery.com/CL0/https:%2F%2Fvimeo.com%2F1075421918%2F57…> that summarizes the development process and reviews key updates. * Mapping of Privacy Framework 1.0 Core to Privacy Framework 1.1 Core<https://links-1.govdelivery.com/CL0/https:%2F%2Fwww.nist.gov%2Fdocument%2Fp…> to help organizations trace changes to Core Categories and Subcategories between Framework versions. NIST welcomes stakeholder feedback on the Privacy Framework 1.1 IPD by June 13, 2025. For more information, including a comment template and instructions for submitting feedback, please click the button below. To receive periodic updates and hear about other opportunities to engage, subscribe to our Privacy Engineering mailing list<https://links-1.govdelivery.com/CL0/https:%2F%2Fpublic.govdelivery.com%2Fac…>. If you have questions, please contact us at privacyframework(a)nist.gov<mailto:privacyframework@nist.gov>. Read More<https://links-1.govdelivery.com/CL0/https:%2F%2Fcsrc.nist.gov%2Fpubs%2Fcswp…> NIST Cybersecurity and Privacy Program Questions/Comments about this notice: privacyframework(a)nist.gov<mailto:privacyframework@nist.gov> Connect with us <https://links-1.govdelivery.com/CL0/https:%2F%2Fwww.facebook.com%2FNIST/1/0…><https://links-1.govdelivery.com/CL0/https:%2F%2Ftwitter.com%2FNIST/1/010001…><https://links-1.govdelivery.com/CL0/https:%2F%2Fwww.youtube.com%2FNIST/1/01…><https://links-1.govdelivery.com/CL0/https:%2F%2Fwww.linkedin.com%2Fcompany%…><https://links-1.govdelivery.com/CL0/https:%2F%2Fwww.instagram.com%2Fnist%2F…> Received this email from a friend? Subscribe here<https://links-1.govdelivery.com/CL0/https:%2F%2Fpublic.govdelivery.com%2Fac…>. <https://links-1.govdelivery.com/CL0/https:%2F%2Fwww.nist.gov%2Fitl/1/010001…> Subscriber services: Manage Preferences<https://links-1.govdelivery.com/CL0/https:%2F%2Fpublic.govdelivery.com%2Fac…> | Unsubscribe<https://links-1.govdelivery.com/CL0/https:%2F%2Fpublic.govdelivery.com%2Fac…> | Help<https://links-1.govdelivery.com/CL0/https:%2F%2Fsubscriberhelp.govdelivery.…> _____ If you have questions or problems with the subscription service, please contact subscriberhelp.govdelivery.com<https://links-1.govdelivery.com/CL0/https:%2F%2Fsubscriberhelp.govdelivery.…>. Technical questions? Contact inquiries(a)nist.gov<mailto:inquiries@nist.gov>. (301) 975-NIST (6478). This service is provided to you at no charge by National Institute of Standards and Technology (NIST). 100 Bureau Drive, Stop 1070 · Gaithersburg, MD 20899 · 301-975-6478 <https://links-1.govdelivery.com/CL0/https:%2F%2Fsubscriberhelp.granicus.com…> <https://links-1.govdelivery.com/CI1/0100019635b28839-3eb0c0d8-62b7-4ac6-a21…>

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Pirvacy Activity in MA
by Salvatore D'Agostino 14 Apr '25

14 Apr '25

Hi WG, There are written comments due today. I am review this fairly comprehensive set of legislation, and will share my comments with the list. I can submit these as IDmachines and mention the WG, I can also put the WG name on comments. I will try to get these out by noon. Hearing Details - Joint Committee on Advanced Information Technology, the Internet and Cybersecurity<https://malegislature.gov/Events/Hearings/Detail/5114> Also please let me know about the general WG slides. Best, Sal IDmachines 4 Lamson Place Cambridge, MA 02139-2612 +1 617.201.4809 @idmachines https://idmachines.com<https://idmachines.com/> Please note our new address. Email, phones, other contacts remain the same. Disclaimer The information contained in this communication from the sender is confidential. It is intended solely for use by the recipient and others authorized to receive it. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking action in relation of the contents of this information is strictly prohibited and may be unlawful. If you have received this email in error, please delete it and advise the sender.

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slides for Kantara presntations
by Salvatore D'Agostino 13 Apr '25

13 Apr '25

Hi WG, Here are the two slides that will be used at Kantara presentation including EIC and Identiverse. These are due COB tomorrow, comments here. Hope everyone is enjoying the weekend. Best, Sal IDmachines 4 Lamson Place Cambridge, MA 02139-2612 +1 617.201.4809 @idmachines https://idmachines.com<https://idmachines.com/> Please note our new address. Email, phones, other contacts remain the same. Disclaimer The information contained in this communication from the sender is confidential. It is intended solely for use by the recipient and others authorized to receive it. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking action in relation of the contents of this information is strictly prohibited and may be unlawful. If you have received this email in error, please delete it and advise the sender.

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Call today
by Salvatore D'Agostino 09 Apr '25

09 Apr '25

Hi WG, We are still on our existing schedule for a call at noon today with the idea that we shift this to 1 PM starting in two weeks. Agenda pretty much maps to last call. We can review the comments received, work on our slides for the general Kantara presentation, determine what changes we want to make by 5 May and the end of the comment period. I have been reaching out to other communities to get feedback and can talk about that as well on the call. ANCR WG 20250409 Draft - WG - ANCR - Kantara Initiative<https://kantara.atlassian.net/wiki/spaces/WA/pages/961642544/ANCR+WG+202504…> Agenda https://us06web.zoom.us/j/87282263538?pwd=K0RwY1g1b3pKeHdBcXpjeExVZUFpQT09 Zoom Link Best, Sal IDmachines 4 Lamson Place Cambridge, MA 02139-2612 +1 617.201.4809 @idmachines https://idmachines.com<https://idmachines.com/> Please note our new address. Email, phones, other contacts remain the same. Disclaimer The information contained in this communication from the sender is confidential. It is intended solely for use by the recipient and others authorized to receive it. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking action in relation of the contents of this information is strictly prohibited and may be unlawful. If you have received this email in error, please delete it and advise the sender.

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Fwd: REMINDER - NOTICE FOR PUBLIC COMMENTS/IPR REVIEW: Transparency Performance Reporting (ANCR Draft Recommendation)
by Mark Lizar 06 Apr '25

06 Apr '25

Hi All, With this amazing announcement, We at ANCR ask, Is there Digital Trust without Consent? An identifier is a component of a consent receipt. Is there data sovereignty without consent, is there a digital wallet without consent ? Is there AI without consent? ANCR WG: the Blog Post WRT Real Consent Receipt <https://kantara.atlassian.net/wiki/x/egAfOQ?atlOrigin=eyJpIjoiMjAzZTM4N2ZkZ…> is posted to champion international data governance interoperability, with digital identification management. (A response to W3C DPV) Should Privacy Govern Surveillance ? Mark > Begin forwarded message: > > From: "Kantara Initiative" <general(a)kantarainitiative.org> > Subject: REMINDER - NOTICE FOR PUBLIC COMMENTS/IPR REVIEW: Transparency Performance Reporting (ANCR Draft Recommendation) > Date: 4 April 2025 at 11:42:46 GMT-4 > To: <mark(a)smartspecies.com> > Reply-To: "Kantara Initiative" <general(a)kantarainitiative.org> > > Unsubscribe <https://kantarainitiative.org/membership/?civiwp=CiviCRM&q=civicrm%2Fmailin…> > <https://kantarainitiative.org/membership/?civiwp=CiviCRM&q=civicrm/mailing/…> > Dear Kantara Initiative Community: > This is a reminder of formal notification that the Anchored Notice and Consent Receipt Work Group (ANCR) has approved the following document as a Draft Recommendation and its distribution for Public Comment and IPR Review: > > Document: Transparency Performance Reporting: A Tool for Assessment of Digital Identification Surveillance > > Version: 1.0 > > Document Date: 2025-02-12 > > Notice and Document available HERE <https://kantarainitiative.org/membership/?civiwp=CiviCRM&q=civicrm/mailing/…>. > > In accordance with the Kantara Initiative Operating Procedures <https://kantarainitiative.org/membership/?civiwp=CiviCRM&q=civicrm/mailing/…>, this document now enters a 45-day public comment and IPR review period in preparation for an All-Member Ballot to consider its approval as a Kantara Initiative Recommendation. This is an open invitation to comment. Kantara Initiative solicits feedback from potential users, developers, and other interested parties, whether Kantara Initiative members or not, for the sake of improving the interoperability and quality of its technical work. > > Public Review and IPR Review Period Opens: 2025-03-21, 01:00 PM ET > > Review Period Closes: 2025-05-05, 01:00 PM ET > > Document Abstract: > > Transparency Performance Reporting (TPR) is a novel approach to digital transparency and data control reporting. TPR clarifies when a notice and consent receipt is required and its validity and provides a litmus test for valid consent. TPR uses 4 transparency performance indicators (TPIs) – the timing of the notice, the content of the notice, access and usefulness of the notice, and sovereignty of authority and security – to measure the transparency of the Personally Identifiable Information (PII) Controller notice of risk to the personal data of the PII Principal. This represents a significant advancement for decentralizing digital identification and data surveillance governance within data flows. > > TPR includes mapping to privacy frameworks including Convention 108+, a commonwealth data governance framework that covers 2.5 billion people, and with it an interoperable set of requirements for security and privacy. The mappings show how the TPIs address the requirements for records of processing activities (GDPR Article 30), enable services to be accountable to international (internet) standards for data governance, and create a technical record foundation in a common set of rules allowing people to have their authoritative records of digital identification relationships. > > TPR was developed through volunteer work over three years in the Kantara Initiative Anchored Notice and Consent Receipt Work Group (ANCR) <https://kantarainitiative.org/membership/?civiwp=CiviCRM&q=civicrm/mailing/…>as a means of understanding and addressing ubiquitous platform and application surveillance while promoting glass-box security and privacy legal standards. > > ____________________ > > Kantara invites your review of this document and asks that you submit any comments and proposed revisions on or before 2025-05-05. As this deadline will be strictly adhered to, late submissions will not be taken into account. > > To Comment on the Recommendation: > > Single comment: Public Comment Form <https://kantarainitiative.org/membership/?civiwp=CiviCRM&q=civicrm/mailing/…> > Multiple comments: Kantara-Comment-Template ANCR Transparency Performance Reporting Recommendation.xlsx <https://kantarainitiative.org/membership/?civiwp=CiviCRM&q=civicrm/mailing/…> > Send your comments via email to staff@ kantarainitiative.org <https://kantarainitiative.org/membership/?civiwp=CiviCRM&q=civicrm/mailing/…> with the subject “(ANR TPR COMMENT SUBMISSION". > _____________ > > Intellectual Property Rights Notice: > > Intellectual Property Rights Notice: In accordance with the Kantara Initiative IPR Policy <https://kantarainitiative.org/membership/?civiwp=CiviCRM&q=civicrm/mailing/…>Appendix B Article 5 and the Kantara Initiative Operating Procedures <https://kantarainitiative.org/membership/?civiwp=CiviCRM&q=civicrm/mailing/…> Section 7.5, you have a period of 45 days to review the document for any Necessary Claims that may be implicated by the final Recommendation. > > Note that any submissions are deemed to be contributed under the IPR Option of ANCR: Reciprocal Royalty Free with Opt-out to Reasonable and Non-Discriminatory <https://kantarainitiative.org/membership/?civiwp=CiviCRM&q=civicrm/mailing/…> (RAND) > > While there is no requirement to review your patent portfolio for Necessary Claims, please be advised that unless you provide a licensing objection in accordance with the Kantara Initiative IPR Policy Article 5 or a notice of withdrawal in accordance with Kantara Initiative IPR Policy Article 6 on or before 2025-05-05 you will have committed to the licensing provisions as set forth by the Patent & Copyright: (Reciprocal Royalty Free with Opt-out to Reasonable and Non-Discriminatory <https://kantarainitiative.org/membership/?civiwp=CiviCRM&q=civicrm/mailing/…> (RAND)) IPR Policy with respect to any Necessary Claims implicated by the final approved document. > > ANCR Participants <https://kantarainitiative.org/membership/?civiwp=CiviCRM&q=civicrm/mailing/…> are required to make claims to IPR regarding these technical documents. Having signed the Group Participation Agreement (GPA) all members of ANCR should be familiar with these documents, which may create obligations regarding the disclosure and availability of a member’s patent, copyright, trademark, and license rights that read on an approved Kantara Initiative Recommendation. > > Kantara Initiative invites any other persons who know of any part of this Group output that would infringe on third-party intellectual property rights to disclose such infringement claims so that these claims may be provided to the Group members for resolution. If you are not an ANCR Participant, you have no IPR licensing obligation to any of these documents. > > To submit an Intellectual Property Rights infringement claim, email staff(a)kantarainitiative.org <mailto:staff@kantarainitiative.org> with the subject "ANCR TPR IPR CLAIM". > > ____________________ > > Please contact the Kantara Initiative staff at staff(a)kantarainitiative.org <mailto:staff@kantarainitiative.org> with any questions regarding this notice. > > We thank you for your time and continued support of Kantara Initiative! > > >

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FYI - 27091 AI Transparency text submitted with consent receipt use case
by Mark Lizar 04 Apr '25

04 Apr '25

HI All, I have provided some text to propose pii principal transparency, am not sure if it will be used, or useful. But, the excercise has been very helpful. Pleas find this attached, Mark

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Clarifying the Consent Receipt Use Case in 27560
by Mark Lizar 31 Mar '25

31 Mar '25

HI Everyone, Now that 27560 is going to be open, I have looked into recent work on 27560, and 29184, so I could try and locate where the consent receipt use case has gone awry exactly, in addition, to provide Transparency Report Specific references to support the use of Consent Receipts, to enable Controller compliance. Its clear the Consent Receipt use case to regulate digital identity trust and address surveillance capitalism is still a big deal, and something that perhaps the ANCR WG can support, to educate the industry on a way for human data control and interoperability with consent and identity management. Aka the Consent Receipt. To this end, I have drafted some comments/ update to the Consent Receipt use case, to the W3C DPV, Group and to provide the legal references to request updates to the proposed 27560. Would these comments be supported by ANCR. WG? Best, Marl Core Consent Receipt Use Case - Permission for Identification (or self-identifying with consent) As the researcher, developer and editor of the Consent Receipt, and editor of the Transparency Performane Report at the ANCR WG. I would like to clarity the core use case for the consent receipt, to demonstrate how to decentralised the govern of digital identification and surveillance with enforceable privacy, transparency, and consent regulation. To this end, I would request a review of notice and consent in DPV (and 27560), with regards to the associated guidance found in particular Associating Identity with Consent <https://harshp.com/research/publications/038-comparison-notice-requirements…> “Additionally, GDPR encourages using an identifier so that controllers can demonstrate the individual’s given consent (Art.7-1), enable them to withdraw it (Art.7-3), and provide them with a history of their consent events (Art.15).”https://harshp.com/research/publications/038-comparison-notice-req… Referencing Guidelines 05/2020 on consent under Regulation 2016/679 ( point to the guidance which has a different interpretation that what is provided here) “64. >>>> Furthermore, there may be situations where a data controller is processing personal data that does not require the identification of a data subject (for example, with pseudonymized data). In such cases, Article 11.1 may also be relevant as it states that a data controller shall not be obliged to maintain, acquire, or process additional information to identify the data subject solely to comply with the GDPR.” In Article 29 Working Party: Guidelines on transparency under Regulation 2016/679 “106. At the same time, the duty to demonstrate that valid consent has been obtained by a controller should not in itself lead to excessive amounts of additional data processing. This means that controllers should have enough data to show a link to the processing (to show consent was obtained) but shouldn’t be collecting any more information than necessary.” The context of the use case The consent receipt version 1.1 , which was adopted as ISO/IEC 27560, was developed through five years of research and two years of drafting and volunteer community work, originating from Hackathons and Campaigns to stop the biggest lie on the internet: whcich is “Our Data Is Collected without Consent.” Which is now showing to cause significant harms on society (References available upon request) The Issue being addressed If an individual must first be identified to access rights to stop being surveilled online, then privacy is not a right; it is a consumer protection with limited capacity to see and control who can surveil PII principals. This is referred to as the surveillance capitalism use case, which the MVCR and Consent Receipt work solves. Key Points: Without this, people can be surveilled, their data scraped (like with AI), and then they have to opt-out of being tracked, referencing a ‘Consumer Protection’ Paradigm where privacy isn't a fundamental right, and consent is required to surveil people. The consent receipt is the solution to this challenge. Using a standard interaction pattern, well-known in society for trust, that requires fair and proportionate transparency (as explained in Guidance for use of GDPR). It's very simple: Put up a sign, provide a notice, and ask for permission—fundamental components of human etiquette, being polite, and reducing frictions. How does it work; How does this consent receipt work so PII principals can provide permission before being surveilled. A Controller presents their identity in a standard notice (layer 1 of online interaction). This generates a notified record when the PII principal interacts with it. That notified processing activity is mirrored as a consent receipt. A controller digital identifier is provided to the PII principal, instead of a PII principal identifier being taken secretly from the data subject. The data subject can use the receipt (in a secure private space like a digital wallet) to interact with the Controller, send more PII, provide permission to be digitally identified, and self-identify. Consent can be withdrawn with a click. Please consider that at this time, 27560, which is called a consent record, uses a PII principal identifier is in the record header (with an unknown 3rd party ID - for un-notified tracking of people), indicating that this is not consent but a USA-style consumer protection record. Which has significant, security and privacy implications, AS USA Law only affords US citizens consumer rights not afforded to EU or Canadians, under USA Foreign Intelligence Surveillance Laws. As you can imagine, without a real consent receipt and transparency before surveillance, it provides people with much weaker consumer protection, and leaves Canadians open, without rights, or data sovereignty, having a geo-political impact to the international market. Please update text, here especially,https://harshp.com/research/publications/038-comparison-notice-r…

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