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OWASP TellTrail Project

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OWASP TellTrail Project

TellTrail lets individuals control the transfer of their personal data to third parties. People can specify "data policies" that dictate what data may be accessed, and who may access it. We want to make a responsible data ecosystem for everyone.


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Project Leaders

Loren Davie Judy Katzman Sean Auriti

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TellTrail Roadmap

TellTrail is an ambitious initiative comprised of three layers of effort, that work together to achieve an effect greater than the sum of its parts:

Technology: TellTrail will develop technology for the collection, distribution and verification of data citizen policies. It will also create a reference implementation of a data compliance library, to serve as an example of how to properly scrub data in response to TellTrail data policies.

Legal: TellTrail will create a certification program, using licenses that require the agreement of data consumers to adhere to data citizen policies. TellTrail will retain a certification trademark, which will be used by compliant organizations to indicate their compliance with data policies. Finally, TellTrail will operate an auditing program to provide a means for organizations to prove their compliance with data policies to the public.

Advocacy: TellTrail will execute a program of advocacy, spreading the TellTrail concept to the public and to the data industry. The goal of the advocacy program is to educate and popularize the public in the TellTrail approach to data privacy.

Phase 1: Initial Tool Development

The first step for TellTrail is to develop the core technology: the policy server, the web UI for the policy server, and the reference data cleaning library.

We will create a requirements document for the data policy server, and a high level technical architecture specification. Part of this will be the definition of the Policy Request Protocol (PRP) used by compliance tools to query the policy server for data policies. Formal definition of the PRP will allow for independent development of the policy server, web UI and compliance tools. The policy server will be developed in an API-first manner, meaning all functionality will be accessible via API. Our own web UI will use the same API. (The possible exception to this rule is the acquisition of API access tokens.)

We select an appropriate tech stack and develop the policy server. The purpose of the policy server is to collect and serve data citizen policies, implementing the PRP. The policy server will be developed as an open source project, with a proper test suite to verify its functionality.

We will develop a web user interface for data citizens to interact with the policy server. The main purpose of this is to allow citizens to specify their data policy, and to associate identity information with their policy. (Note: the policy server will not store plaintext identify information. We will hold salted, hashed identities, which is all we need to look up policies).

We will establish a hosting solution for the policy server and web UI. We will deploy both on this solution.

We will develop a reference data compliance library to demonstrate proper data cleaning techniques. The library, which will be well-documented and open source, will contain data sets with associated identity information. It will query the policy server via the PRP, and scrub the affected records from the data sets in response to the received data policies. The reference compliance library will also be an open source project.

Skills Required: Software Development, Operations, Security, Project Management

Phase 2: Development of Legal and Governance Framework

In order for TellTrail to function, it requires a legal framework. In this phase we would establish this framework.

We would establish a governance mechanism for TellTrail, such as a steering committee. This body would rule on TellTrail policy decisions moving forward. Potentially we would also establish an acting director at this point.

We would consult with legal counsel to determine the best course of action, vetting our plans with expert advice.

Assuming the plan was not significantly changed in response to legal counsel, we would establish a registered certification trademark for TellTrail with the USPTO. A certification mark (for example: “Certified Organic”) is a trademark used by entities other than the trademark holder. Use of the trademark is subject to license conditions, which usually means the trademark user is adhering to standards and practices determined by the trademark holder.

We would establish usage licenses for the trademark. Licensees would be data consumers, data exchanges and data producers. The current concept is that we would establish different levels of compliance, with associated letter grades (A, B, C) not unlike NYC Department of Health grades for restaurants. Higher grade levels indicate a higher level of compliance, and the certification mark the licensees would use would indicate their compliance level. The very highest levels would be reserved for audited organizations, but because we anticipate that significant effort is required to establish the auditing process, those grades would not be initially offered.

We would develop documentation for the licensing process, and create online web tools for applying for a license. The documentation would be Creative Commons licensed, and the sign up app would be open sourced.

We would develop a database of licensed organizations, classified by their letter grade, their role (data producer, data exchange, data consumer), and by their industry, and by the data categories in which they operate. This database would provide a public feedback mechanism, in which people could provide feedback on the organizations. In this feedback mechanism it would be possible to establish a complaint against the organization, indicating they were not honoring their TellTrail license. Complaints could potentially lead to an investigation by TellTrail, with the potential of the organization’s license being revoked.

As per the previous item, we would establish an investigation procedure to address complaints against registered organizations.

Skills Required: Legal, governance, software development, ops, communications, project management

Phase 3: Advocacy Program

With the technical and legal frameworks in place, the next hurdle to clear would be for TellTrail to let the world know. The goals of the advocacy program would be:

To let the general public know about TellTrail, its approach, and why it should be adopted.

To let companies and organizations that collect, use and sell data to know about TellTrail, and to let them feel public pressure to comply with its standards. Companies should be told that it is to their competitive advantage to be TellTrail compliant.

To this end we would engage in the following efforts:

We would establish a public facing advocacy website, explaining the TellTrail concept and why it is good for everyone in the ecosystem.

We would establish and operate social media accounts, promoting TellTrail.

We would seek conference attendance, to directly reach the data using industry. Conferences would be selected for their access to decision makers in the industry.

We would conduct a public relations campaign, garnering press coverage of TellTrail and its concept.

Skills Required: Design, communications, social media, evangelism, public relations.

Phase 4: Auditing Program

In the final phase for this road map, we would establish an Auditing Program, a means by which compliant organizations could publicly prove their compliance. A successful audit would grant the licensee the right to display a better letter grade than non-audited organizations.

Since auditing would put a workload onto TellTrail, a fee would be charged to an organization for an audit.

We would take the following actions to establish the Auditing Program:

  • Establishment of a standard by which an organization was considered to have passed the audit. In other words, what criteria are required for a pass?
  • Establish how long the the certification is valid.
  • Establishing an auditing procedure: how is an audit conducted by TellTrail?
  • Potentially, creation of auditing tools. Any tools created would be open source.
  • Establishment of an audit team to handle audits.
  • Clear online documentation of the audit process and how to apply, and an online application for an organization to apply for an audit.

Skills Required: Security, communications, software development, project management.

Getting Involved

The following items

  • Functional and deployed data policy server, with code open sourced
  • Open source code for a reference data compliance library - to be used in a data exchange
  • License(s) for use of the TellTrail certification trademark
  • Website explaining, and advocating for, the TellTrail concept.