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Introduction Response to Request for Comment on Data To Go: An FTC Workshop on Data Portability August 21, 2020 Introduction Thank you for the opportunity to provide comments as part of the Federal Trade Commission’s Workshop on Data Portability to take place on September 22, 2020. Apple, Facebook, Google, Microsoft, and Twitter collaborate to support the Data Transfer Project (DTP) ( datatransferproject.dev ), which supports direct, service-to-service portability. We appreciate the opportunity to share our work on this Project, including the principles and practical considerations that guide this work, in response to your questions. Direct portability enables individuals (“users”) to copy data between two authenticated accounts directly, without having to download the data and re-upload it to a new service. D TP is an open-source project that will make it easier for people to switch services, or try new and innovative products, by improving the ease and speed of data portability. In this comment, we briefly summarize the technical foundations of DTP and explain how our principles guided us toward this approach. More information on these topics, and others, can be found in the DTP White Paper. 1 However, this comment primarily provides an update on participation and governance of the Project in response to your questions about how companies are currently implementing data portability; the benefits and costs of data portability; and the security of data in transit between businesses. 1 Data Transfer Project Overview and Fundamentals (July 20, 2018), https://datatransferproject.dev/dtp-overview.pdf. 1 What is the Data Transfer Project History of the Project DTP was launched in 2018 to create an open-source, service-to-service data portability platform so that all individuals across the web could easily move their data between online service providers whenever they want. The current partners 2 are Google, Microsoft, Twitter, Facebook, and Apple. The partners believe portability can support innovation and enable users to easily take advantage of the offerings that best suit their needs. For example, DTP provides practical tools that let users backup or archive important information, organize information within multiple accounts, recover from account hijacking, and retrieve data from deprecated services. It is designed to support individual users, as opposed to commercial customers of a provider. Data portability can also present challenges for data security and privacy, but DTP partners have agreed to support and follow a set of principles to mitigate these concerns. Implementing measures such as encryption in transit guard against unauthorized access, diversion of data, or other types of fraud. The application of privacy principles, such as data minimization and transparency when transferring data between providers, also provide important privacy and security benefits for users. How Does DTP Work DTP is a collaboration of organizations committed to building a common framework with open-source code that can connect any two online service providers, enabling a seamless, direct, user initiated portability of data between the two providers. DTP is powered by an ecosystem of adapters that convert a range of proprietary formats into a small number of canonical formats useful for transferring data. This allows data transfer between any two service providers using the provider’s existing authorization mechanism, and allows each provider to maintain control over the security of their service. A service provider only has to write one adapter for a data type, which will then work with all other service providers that have built adapters for that data type. This also adds to the sustainability of the ecosystem, since companies can attract new customers, or build a user base for new products, by supporting and maintaining the ability to easily import and export a user’s data. 2 To become a partner in the Data Transfer Project, an organization must agree to follow the principles and best practices described in the DTP White Paper, contribute to DTP efforts, and participate in DTP by committing to add and maintain adapters. These organizations have their logos on the DTP website and represent the Project in public conversations. 2 When a user initiates a data transfer, their encrypted information flows from one provider directly to another that is chosen by the user. Only the source service and the destination service (and hosting entity, if it is not the source or destination service) have access to the data. No other DTP partners or third parties have access to a copy of the data as part of the transfer. It is worth noting that DTP doesn’t include any automated deletion architecture. Once an account holder has verified that the desired data is migrated, they would have to delete their data from their original service using that service’s deletion tool if they wanted the data deleted. The DTP partners each offer deletion tools for their users, and encourage all providers to do the same. Importing and exporting data directly can benefit users and the broader ecosystem of service providers in a variety of industries. Direct transfer is more practical and efficient for users by shifting the burden of transferring or copying data from their hardware to the service provider’s infrastructure. This is especially important for users in emerging markets, or on slow or metered connections, as our project does not require a user to download and upload the data over what may be low bandwidth connections and at potentially significant personal expense. Our Principles Partners in DTP agree to support and promote the following principles, which are described in the White Paper3 and are listed on our website.4 ● Build for users Data portability tools should be easy to find, intuitive to use, and readily available for users. They should also be open and interoperable with standard industry formats, where applicable, so that users can easily transfer data between services or download it for their own purposes. ● Privacy and security Service p roviders on each side of the portability transaction should have strong privacy and security measures—such as encryption in transit—to guard against unauthorized access, diversion of data, or other types of fraud. It is important to apply privacy principles such as data minimization and transparency when transferring data between providers. When users initiate a transfer they should be told in a clear and concise manner about the types and scope of data being transferred as well as how the data will be used at the destination service. Users should also be advised about the privacy and security practices of the destination service. These measures will help to educate users about the data being transferred and how the data will be used at the destination service. More details are in the Privacy and Security section below. 3 Data Transfer Project Overview and Fundamentals (July 20, 2018), https://datatransferproject.dev/dtp-overview.pdf. 4 Data Transfer Project FAQ, h ttps://datatransferproject.dev/faq. 3 ● Reciprocity While portability offers more choice and flexibility for users, it will be important to ensure that flexibility is consistent across the ecosystem. A user’s decision to move data to another service provider should not result in any loss of transparency or control over that data. Specifically, individuals should have assurance that data imported to a provider can likewise be exported again, if they so choose. There should not be a dead-end for users in transferring their data, and any service provider that only offers import should be transparent and upfront about this. ● Focus on user’s data Portability efforts should emphasize data and use cases that support the individual user. Focusing on content a user creates, imports, approves for collection, or has control over, reduces the friction for users who want to switch among products or services or use their data in novel ways, because the data they export is meaningful to them. Portability should not extend to data that may negatively impact the privacy of other users, or data collected to improve a service, including data generated to improve system performance or train models that may be commercially sensitive or proprietary. This approach encourages companies to continue to support data portability, knowing that their proprietary technologies are not threatened by data portability requirements. For a detailed taxonomy of such data, see ISO/IEC 19944:2017. ● Respect Everyone We live in a collaborative world: people connect and share on social media, they edit docs together, and they comment on videos, pictures, and more. Data portability tools should focus only on providing data that is directly tied to the person requesting the transfer. We think this strikes the right balance between portability, privacy, and benefits of trying a new service. We believe these principles promote user choice and encourage responsible product development, maximizing the benefits to users and mitigating the potential drawbacks. Privacy and Security One of the questions posed in the request for comment is “who should be responsible for the security of personal data in transit between businesses?” This is a question that DTP necessarily confronted while developing our protocols. The security and privacy of user data is a foundational principle of DTP. Because there are multiple parties involved in the data transfer (the user, Hosting Entity, 5 Providers,6 and partners) 5 A Hosting Entity is the entity that runs a Host Platform of DTP. In most cases it will be the provider sending or receiving the data, but could be a trusted third party that wants to enable data transfer among a specific group of organizations. 6 Providers are any company or entity that holds user data. Providers may or may not be partners. Provider is similar to Cloud Service Provider as defined in ISO/IEC 17788:2014 section 3.2.15.
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