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[ Policy Updates and Analysis from the Internet Standards World
[ Provided by
[ The Center for Democracy & Technology's
[ Internet Standards, Technology, and Policy Project
Welcome to the Standards Bulletin, a publication of CDT's Internet Standards, Technology, & Policy Project. This series is intended to provide updates and analysis about public policy implications of the work of the organizations that design the technical standards on which the Internet is based.
This Bulletin provides an overview and analysis of the privacy and public policy issues raised by the "ENUM" protocol, developed by the Internet Engineering Task Force ("IETF") to bridge the gap between the traditional telephone system and the Internet. This Bulletin also provides a report on the 56th meeting of the IETF, which took place March 16 through 21, 2003.
ENUM, a technology protocol that may provide a critical tool in the more widespread adoption of "voice over the Internet" services, also poses risks to privacy. CDT's Standards, Technology & Policy Project is today issuing a report analyzing a range of privacy and other public policy concerns raised by the ENUM protocol. The report sets out detailed policy recommendations that should be followed by national governments and service providers in any implementation of ENUM.
ENUM is a protocol that allows the translation of normal telephone numbers into a format that can be used to store and retrieve Internet addressing information, which can in turn be used to route communications over the Internet. With ENUM and "Voice over Internet Protocol" ("VoIP") technology, an increasingly amount of voice communications can be carried over the Internet instead of over the traditional telephone network. Initially, ENUM is likely to be deployed by corporations and other large institutions that seek to reduce their use of traditional telephone services (especially international and other long distance service). This technology has the potential to allow users -- corporations and individuals -- to save money and increase the choices they can exercise in their communications.
ENUM will facilitate the routing of telephone calls over the Internet in a manner that is seamless to the end users. To place a call with ENUM (using one possible implementation), (1) a person dials a standard phone number on a normal telephone (or on a telephone-like device connected to a computer), (2) the computer or telephone system uses ENUM to check if the called number can be reached over the Internet using VoIP technology, (3) if the number can be reached, a VoIP call is initiated, and (4) if the number cannot be reached over the Internet, the call is routed to the traditional telephone network.
ENUM is still in the development and testing stages. A number of nations around the world have initiated formal ENUM "test bed" implementations. The United States Department of Commerce has endorsed the U.S.'s participation in ENUM, and set out a series of guidelines to be met before formal tests or government-sanctioned implementations can proceed. Commercial ENUM deployment is likely to take place by the end of 2004.
ENUM's potential benefits also bring risks in terms of privacy and other public policy concerns. The simplest implementation of ENUM envisions that individuals' personal contact information (such as telephone numbers and e-mail addresses) will be stored in special records located in the Domain Name System (or DNS) of the global Internet. Because the DNS is publicly available, the placement of personal information in ENUM records in the DNS could compromise the privacy of its users, and could lead to additional spam and other problems.
However, a more complex use of ENUM (in conjunction with a device called a "proxy server" or "SIP server") offers the opportunity to gain the benefits of ENUM without sacrificing control over personal information. This approach would use the Session Initiation Protocol ("SIP"), or a similar protocol, to screen ENUM queries and only return contact information according to rules set by the party being contacted. To minimize the potential harmful effect of ENUM on privacy, it is vital that this second, more complex approach to ENUM be permitted and available in the marketplace.
Other important issues turn, for example, on (a) how much information individuals or companies will be required to provide in order to take advantage of ENUM, and (b) how much of that information will be revealed in a public database (similar to the "whois" database which reveals information about domain name holders). On this latter point, CDT believes that there is no need for a public whois-like database that would identify the user of an ENUM number. In a different vein, ENUM also raises a range of policy issues about how closely "ENUM numbers" should be tied to existing traditional telephone numbers.
One critical aspect of the global public policy issues surrounding ENUM is the fact that ENUM will, for the most part, be implemented within each country by the telephone authorities or companies that operate within that country. Thus, many critical decisions (for example, about how much information will be required to obtain an ENUM number) will be made on a country-by-country basis. It is critical that within each country, the relevant telephone authorities must closely consult with the public interest and civil society sector, the communications industry, and the computer industry.
To ensure that users can take advantage of ENUM without sacrificing privacy, any implementation of ENUM should follow a number of guidelines to ensure that there are a diversity of ENUM service providers and that those providers will be able to offer privacy-protecting ENUM options. CDT's report on ENUM details 14 specific policy recommendations. Among the specific recommendations are:
· At no time should any ENUM record be created without the express consent of the individual or entity that subscribes to the corresponding telephone number in the traditional telephone network. An ENUM user should explicitly "opt-in" to the ENUM service. · No publicly accessible whois-like database of ENUM subscribers should be created. · Prospective ENUM users should receive clear notice of the privacy risks and consequences of using ENUM. · ENUM policy within a country should be set in close consultation with the public interest and civil society sector and the relevant industry sectors."ENUM: Mapping Telephone Numbers onto the Internet -- Potential Benefits With Public Policy Risks" is available at http://www.cdt.org/standards/enum/.
The presentation "On Considering Privacy in IETF Protocols" is available at http://www.crypto.com/talks/ietf56-privacy.pdf. [pdf]
The charter of the Anti-Spam Research Group is available at http://www.irtf.org/charters/asrg.html.
CDT's report on the origins of spam is available at http://www.cdt.org/speech/spam/030319spamreport.shtml.
The issue of patents and standards was discussed in more detail in Standards Bulletin 1.03, http://www.cdt.org/standards/bulletin/1.03.shtml.
The charter of the Intellectual Property Rights Working Group is available at http://www.ietf.org/html.charters/ipr-charter.html.
The most recent submissions by the CDT Standards Project to the GEOPRIV working group are available at http://www.cdt.org/standards/.
CDT Standards Bulletin Subscription Information
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Detailed information about online civil liberties issues may be found at http://www.cdt.org/, and more information about Internet standards and public policy can be found at http://www.cdt.org/standards/.
This document may be redistributed freely in full or linked to http://www.cdt.org/standards/bulletin/2.01.shtml.
Excerpts may be re-posted with prior permission of ari@cdt.org
Standards Bulletin 2.01 Copyright 2003 Center for Democracy and Technology
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