Privacy Req 15
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PRIVACY-15. ATTRIBUTE SEGREGATION
Wherever feasible, identifier data MUST be segregated from attribute data.
User attributes can be used to narrow the pool of potential real world human beings to the point where the real world identity can be determined. That said, there are a set of user static identifiers which must be protected from disclosure above more general user information. An example of the identifiers that need special protection include:
1. Legal Name
2. Social Security Number
3. Street address of domicile
4. Cell phone number
5. Email address
When recent identity protocols (like OpenID Connect) are used, it is technically possible to authenticate a user with no user identifiers or attributes at all. In that case the user identifiers in the protocol between digital entities should be opaque to the extent that any party outside of the Identity Provider and the Relying party will not be able to use those identifiers in any other context. In that case other baseline requirements will apply.
Further reference materials to aid organizations interested in conforming to these Requirements can be found at the wiki page Supplemental Privacy Guidance; this has been archived at https://workspace.idesg.org/kws/public/download.php/56/Supplemental-Privacy-Guidance.docx
APPLIES TO ACTIVITIES
APPLIES TO ROLES
1 - RELYING PARTIES
4 – Intermediaries