Human Rights Protocol Considerations Research Group G. Grover
Internet-Draft Centre for Internet and Society
Updates: 8280 (if approved) N. ten Oever
Intended status: Informational University of Amsterdam
Expires: August 26, 2021 February 22, 2021
Guidelines for Human Rights Protocol and Architecture Considerations
draft-irtf-hrpc-guidelines-06
Abstract
This document sets guidelines for human rights considerations for
developers working on network protocols and architectures, similar to
the work done on the guidelines for privacy considerations [RFC6973].
This is an updated version of the guidelines for human rights
considerations in [RFC8280].
Status of This Memo
This Internet-Draft is submitted in full conformance with the
provisions of BCP 78 and BCP 79.
Internet-Drafts are working documents of the Internet Engineering
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and may be updated, replaced, or obsoleted by other documents at any
time. It is inappropriate to use Internet-Drafts as reference
material or to cite them other than as "work in progress."
This Internet-Draft will expire on August 26, 2021.
Copyright Notice
Copyright (c) 2021 IETF Trust and the persons identified as the
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the Trust Legal Provisions and are provided without warranty as
described in the Simplified BSD License.
Table of Contents
1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . 3
2. Vocabulary used . . . . . . . . . . . . . . . . . . . . . . . 3
3. Guidelines for developing human rights protocol
considerations . . . . . . . . . . . . . . . . . . . . . . . 3
3.1. Human rights threats . . . . . . . . . . . . . . . . . . 3
3.2. Conducting human rights reviews . . . . . . . . . . . . . 5
3.2.1. Analyzing drafts based on guidelines for human rights
considerations model . . . . . . . . . . . . . . . . 5
3.2.2. Analyzing drafts based on their perceived or
speculated impact . . . . . . . . . . . . . . . . . . 5
3.2.3. Expert interviews . . . . . . . . . . . . . . . . . . 5
3.2.4. Interviews with impacted persons and communities . . 5
3.2.5. Tracing impacts of implementations . . . . . . . . . 6
3.3. Guidelines for human rights considerations . . . . . . . 6
3.3.1. Connectivity . . . . . . . . . . . . . . . . . . . . 7
3.3.2. Privacy . . . . . . . . . . . . . . . . . . . . . . . 8
3.3.3. Content agnosticism . . . . . . . . . . . . . . . . . 8
3.3.4. Security . . . . . . . . . . . . . . . . . . . . . . 9
3.3.5. Internationalization . . . . . . . . . . . . . . . . 9
3.3.6. Censorship resistance . . . . . . . . . . . . . . . . 10
3.3.7. Open Standards . . . . . . . . . . . . . . . . . . . 11
3.3.8. Heterogeneity Support . . . . . . . . . . . . . . . . 13
3.3.9. Pseudonymity . . . . . . . . . . . . . . . . . . . . 14
3.3.10. Anonymity . . . . . . . . . . . . . . . . . . . . . . 15
3.3.11. Accessibility . . . . . . . . . . . . . . . . . . . . 16
3.3.12. Localization . . . . . . . . . . . . . . . . . . . . 17
3.3.13. Decentralization . . . . . . . . . . . . . . . . . . 17
3.3.14. Reliability . . . . . . . . . . . . . . . . . . . . . 18
3.3.15. Confidentiality . . . . . . . . . . . . . . . . . . . 19
3.3.16. Integrity . . . . . . . . . . . . . . . . . . . . . . 20
3.3.17. Authenticity . . . . . . . . . . . . . . . . . . . . 21
3.3.18. Adaptability . . . . . . . . . . . . . . . . . . . . 22
3.3.19. Outcome Transparency . . . . . . . . . . . . . . . . 22
3.3.20. Remedy and Attribution . . . . . . . . . . . . . . . 23
3.3.21. Misc. considerations . . . . . . . . . . . . . . . . 24
4. Document Status . . . . . . . . . . . . . . . . . . . . . . . 24
5. Acknowledgements . . . . . . . . . . . . . . . . . . . . . . 24
6. Security Considerations . . . . . . . . . . . . . . . . . . . 24
7. IANA Considerations . . . . . . . . . . . . . . . . . . . . . 24
8. Research Group Information . . . . . . . . . . . . . . . . . 25
9. References . . . . . . . . . . . . . . . . . . . . . . . . . 25
9.1. Informative References . . . . . . . . . . . . . . . . . 25
9.2. URIs . . . . . . . . . . . . . . . . . . . . . . . . . . 30
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Authors' Addresses . . . . . . . . . . . . . . . . . . . . . . . 30
1. Introduction
This document outlines a set of human rights protocol considerations
for protocol developers. It provides questions engineers should ask
themselves when developing or improving protocols if they want to
understand how their decisions can potentially influence the exercise
of human rights on the Internet. It should be noted that the impact
of a protocol cannot solely be deduced from its design, but its usage
and implementation should also be studied to form a full protocol
human rights impact assessment.
The questions are based on the research performed by the Human Rights
Protocol Considerations (hrpc) research group which has been
documented before these considerations. The research establishes
that human rights relate to standards and protocols, and offers a
common vocabulary of technical concepts that influence human rights
and how these technical concepts can be combined to ensure that the
Internet remains an enabling environment for human rights. With
this, the contours of a model for developing human rights protocol
considerations has taken shape.
This document is a further iteration of the guidelines that can be
found in [RFC8280]. The methods for conducting human rights reviews
(Section 3.2), and guidelines for human rights considerations
(Section 3.3) in this document are being tested for relevance,
accuracy and validity.
2. Vocabulary used
3. Guidelines for developing human rights protocol considerations
3.1. Human rights threats
Threats to the exercise of human rights on the Internet come in many
forms. Protocols and standards may harm or enable the right to
freedom of expression, right to freedom of information, right to non-
discrimination, right to equal protection, right to participate in
cultural life, arts and science, right to freedom of assembly and
association, right to privacy, and the right to security. An end-
user who is denied access to certain services or content may be
unable to disclose vital information about the malpractices of a
government or other authority. A person whose communications are
monitored may be prevented or dissuaded from exercising their right
to freedom of association or participate in political processes
[Penney]. In a worst-case scenario, protocols that leak information
can lead to physical danger. A realistic example to consider is when
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individuals perceived as threats to the state are subjected to
torture, extra-judicial killing or detention on the basis of
information gathered by state agencies through the monitoring of
network traffic.
This document presents several examples of how threats to human
rights materialize on the Internet. This threat modeling is inspired
by [RFC6973] Privacy Considerations for Internet Protocols, which is
based on security threat analysis. This method is a work in progress
and by no means a perfect solution for assessing human rights risks
in Internet protocols and systems. Certain specific human rights
threats are indirectly considered in Internet protocols as part of
the security considerations [BCP72], but privacy considerations
[RFC6973] or reviews, let alone human rights impact assessments of
protocols are not standardized or implemented.
Many threats, enablers and risks are linked to different rights.
This is not surprising if one takes into account that human rights
are interrelated, interdependent and indivisible. Here however we're
not discussing all human rights because not all human rights are
relevant to ICTs in general and protocols and standards in particular
[Bless]: "The main source of the values of human rights is the
International Bill of Human Rights that is composed of the Universal
Declaration of Human Rights [UDHR] along with the International
Covenant on Civil and Political Rights [ICCPR] and the International
Covenant on Economic, Social and Cultural Rights [ICESCR]. In the
light of several cases of Internet censorship, the Human Rights
Council Resolution 20/8 was adopted in 2012, affirming that "the same
rights that people have offline must also be protected online."
[UNHRC2016] In 2015, the Charter of Human Rights and Principles for
the Internet [IRP] was developed and released. According to these
documents, some examples of human rights relevant for ICT systems are
human dignity (Art. 1 UDHR), non-discrimination (Art. 2), rights to
life, liberty and security (Art. 3), freedom of opinion and
expression (Art. 19), freedom of assembly and association (Art. 20),
rights to equal protection, legal remedy, fair trial, due process,
presumed innocent (Art. 7-11), appropriate social and international
order (Art. 28), participation in public affairs (Art. 21),
participation in cultural life, protection of the moral and material
interests resulting from any scientific, literary or artistic
production of which [they are] the author (Art. 27), and privacy
(Art. 12)." A partial catalog of human rights related to Information
and Communications technologies, including economic rights, can be
found in [Hill2014].
This is by no means an attempt to exclude specific rights or
prioritize some rights over others. If other rights seem relevant,
please contact the authors.
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3.2. Conducting human rights reviews
Human rights reviews can take place at different stages of the
development process of an Internet Draft. However, generally
speaking, it is easier to influence the development of a technology
at earlier stages than at later stages. This does not mean that
reviews at last-call are not relevant, but they are less likely to
result in significant changes in the reviewed document.
Methods for analyzing technology for specific human rights impacts
are still quite nascent. Currently five methods have been explored
by the Human Rights Review Team, often in conjunction with each
other:
3.2.1. Analyzing drafts based on guidelines for human rights
considerations model
This analysis of Internet-Drafts uses the model as described in
section 3.3. The outlined categories and questions can be used to
review an Internet Draft. The advantage of this is that it provides
a known overview, and document authors can go back to this document
as well as [RFC8280] to understand the background and the context.
3.2.2. Analyzing drafts based on their perceived or speculated impact
When reviewing an Internet-Draft, specific human rights impacts can
become apparent by doing a close reading of the draft and seeking to
understand how it might affect networks or society. While less
structured than the straight use of the human rights considerations
model, this analysis may lead to new speculative understandings of
links between human rights and protocols.
3.2.3. Expert interviews
Interviews with document authors, active members of the Working
Group, or experts in the field can help explore the characteristics
of the protocol and their effects. There are two main advantages to
this approach: one the one hand, it allows the reviewer to gain a
deeper understanding of the (intended) workings of the protocol; on
the other hand, it also allows for the reviewer to start a discussion
with experts or even document authors, which can help the review gain
traction when it is published.
3.2.4. Interviews with impacted persons and communities
Protocols impact users of the Internet. Interviews can help the
reviewer understand how protocols affect the people that use the
protocols. Since human rights are best understood from the
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perspective of the rights-holder, this approach will improve the
understanding of the real world effects of the technology. At the
same time, it can be hard to attribute specific changes to a
particular protocol, this is of course even harder when a protocol
has not been (widely) deployed.
3.2.5. Tracing impacts of implementations
The reality of deployed protocols can be at odds with the
expectations kept in mind during the protocol design and development.
[RFC8980] When a specification already has associated running code,
the code can be analyzed either in an experimental setting or on the
Internet where its impact can be observed. In contrast to reviewing
the draft text, this approach can allow the reviewer to understand
how the specifications works in practice, and potentially what
unknown or unexpected effects the technology has.
3.3. Guidelines for human rights considerations
This section provides guidance for document authors in the form of a
questionnaire about protocols and how technical decisions can shape
the exercise of human rights. The questionnaire may be useful at any
point in the design process, particularly after document authors have
developed a high-level protocol model as described in [RFC4101].
These guidelines do not seek to replace any existing referenced
specifications, but rather contribute to them and look at the design
process from a human rights perspective.
Protocols and Internet Standards might benefit from a documented
discussion of potential human rights risks arising from potential
misapplications of the protocol or technology described in the RFC.
This might be coupled with an Applicability Statement for that RFC.
Note that the guidance provided in this section does not recommend
specific practices. The range of protocols developed in the IETF is
too broad to make recommendations about particular uses of data or
how human rights might be balanced against other design goals.
However, by carefully considering the answers to the following
questions, document authors should be able to produce a comprehensive
analysis that can serve as the basis for discussion on whether the
protocol adequately takes specific human rights threats into account.
This guidance is meant to help the thought process of a human rights
analysis; it does not provide specific directions for how to write a
human rights considerations section (following the example set in
[RFC6973]).
In considering these questions, authors will need to be aware of the
potential of technical advances or the passage of time to undermine
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protections. In general, considerations of rights are likely to be
more effective if they are considered given a purpose and specific
use cases, rather than as abstract absolute goals.
Also note that while the section uses the word, 'protocol', the
principles identified in these questions may be applicable to other
types of solutions (extensions to existing protocols, architecture
for solutions to specific problems, etc.).
3.3.1. Connectivity
Question(s): Does your protocol add application-specific functions to
intermediary nodes? Could this functionality be added to end nodes
instead of intermediary nodes? Is your protocol optimized for low
bandwidth and high latency connections? Could your protocol also be
developed in a stateless manner?
Explanation: The end-to-end principle [Saltzer] holds that 'the
intelligence is end to end rather than hidden in the network'
[RFC1958]. Using the end-to-end principle in protocol design is
important to ensure the reliability and security of data
transmissions.
Considering the fact that network quality and conditions vary across
geography and time, it is also important to design protocols such
that they are reliable even on low bandwidth and high latency
connections.
Example: Middleboxes (which can be Content Delivery Networks,
Firewalls, NATs or other intermediary nodes that provide 'services'
besides packet forwarding) serve many legitimate purposes. However,
protocols relying on middleboxes can create potential for abuse, and
intentional and unintentional censoring, thereby influencing
individuals' ability to communicate online freely and privately.
Example: Encrypting connections, like done with HTTPS, can add a
significant network overhead and consequently make web resources less
accessible to those with low bandwidth and/or high latency
connections. [HTTPS-REL] Encrypting traffic is a net positive for
privacy and security, and thus protocol designers can acknowledge the
tradeoffs of connectivity made by such decisions.
Impacts:
- Right to freedom of expression
- Right to freedom of assembly and association
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3.3.2. Privacy
Question(s): Did you have a look at the Guidelines in the Privacy
Considerations for Internet Protocols [RFC6973] section 7? Does your
protocol maintain the confidentiality of metadata? Could your
protocol counter traffic analysis? Does your protocol adhere to data
minimization principles? Does your document identify potentially
sensitive data logged by your protocol and/or for how long that needs
to be retained for technical reasons?
Explanation: Privacy refers to the right of an entity (normally a
person), acting in its own behalf, to determine the degree to which
it will interact with its environment, including the degree to which
the entity is willing to share its personal information with others.
[RFC4949]. If a protocol provides insufficient privacy protection it
may have a negative impact on freedom of expression as users self-
censor for fear of surveillance, or find themselves unable to express
themselves freely.
Example: See [RFC6973]
Impacts:
- Right to freedom of expression
- Right to non-discrimination
3.3.3. Content agnosticism
Question(s): If your protocol impacts packet handling, does it use
user data (packet data that is not included in the header)? Is it
making decisions based on the payload of the packet? Does your
protocol prioritize certain content or services over others in the
routing process? Is the protocol transparent about the
prioritization that is made (if any)?
Explanation: Content agnosticism refers to the notion that network
traffic is treated identically regardless of payload, with some
exception where it comes to effective traffic handling, for instance
where it comes to delay tolerant or delay sensitive packets, based on
the header.
Example: Content agnosticism prevents payload-based discrimination
against packets. This is important because changes to this principle
can lead to a two-tiered Internet, where certain packets are
prioritized over others on the basis of their content. Effectively
this would mean that although all users are entitled to receive their
packets at a certain speed, some users become more equal than others.
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Impacts:
- Right to freedom of expression
- Right to non-discrimination
- Right to equal protection
3.3.4. Security
Question(s): Did you have a look at Guidelines for Writing RFC Text
on Security Considerations [BCP72]? Have you found any attacks that
are somewhat related to your protocol yet considered out of scope of
your document? Would these attacks be pertinent to the human rights
enabling features of the Internet (as described throughout this
document)?
Explanation: Security is not a single monolithic property of a
protocol or system, but rather a series of related but somewhat
independent properties. Not all of these properties are required for
every application. Since communications are carried out by systems
and access to systems is through communications channels, security
goals obviously interlock, but they can also be independently
provided. [BCP72].
Example: See [BCP72].
Impacts:
- Right to freedom of expression
- Right to freedom of assembly and association
- Right to non-discrimination
- Right to security
3.3.5. Internationalization
Question(s): Does your protocol have text string elements, in the
payload or headers, that have to be understood or entered by humans?
Does your protocol allow Unicode? If so, do you accept texts in one
charset (which must be UTF-8), or several (which is dangerous for
interoperability)? If character sets or encodings other than UTF-8
are allowed, does your protocol mandate a proper tagging of the
charset? Did you have a look at [RFC6365]?
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Explanation: Internationalization refers to the practice of making
protocols, standards, and implementations usable in different
languages and scripts (see Localization). In the IETF,
internationalization means to add or improve the handling of non-
ASCII text in a protocol. [RFC6365] A different perspective, more
appropriate to protocols that are designed for global use from the
beginning, is the definition used by W3C:
"Internationalization is the design and development of a
product, application or document content that enables easy
localization for target audiences that vary in culture, region,
or language." {{W3Ci18nDef}}
Many protocols that handle text only handle one charset (US-ASCII),
or leave the question of what coded character set and encoding are
used up to local guesswork (which leads, of course, to
interoperability problems). If multiple charsets are permitted, they
must be explicitly identified [RFC2277]. Adding non-ASCII text to a
protocol allows the protocol to handle more scripts, hopefully
representing users across the world. In today's world, that is
normally best accomplished by allowing Unicode encoded in UTF-8 only.
In the current IETF policy [RFC2277], internationalization is aimed
at user-facing strings, not protocol elements, such as the verbs used
by some text-based protocols. (Do note that some strings are both
content and protocol elements, such as the identifiers.) Given the
IETF's mission to make the Internet a global network of networks,
[RFC3935] developers should ensure that protocols work with languages
apart from English and character sets apart from Latin characters.
It is therefore crucial that at least the content carried by the
protocol can be in any script, and that all scripts are treated
equally.
Example: See localization
Impacts:
- Right to freedom of expression
- Right to political participation
- Right to participate in cultural life, arts and science
3.3.6. Censorship resistance
Question(s): Does your protocol make it apparent or transparent when
access to a resource it restricted and reasons thereof? Can your
protocol contribute to filtering in a way it could be implemented to
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censor data or services? Could this be designed to ensure this
doesn't happen? Does your protocol introduce new identifiers or
reuse existing identifiers (e.g. MAC addresses) that might be
associated with persons or content?
Explanation: Censorship resistance refers to the methods and measures
to prevent Internet censorship. See [draft-irtf-pearg-censorship]
for a survey of censorship techniques employed across the world,
which lays out protocol properties that have been exploited to censor
access to information.
Example: Identifiers of content exposed within a protocol might be
used to facilitate censorship, as in the case of Application Layer
based censorship, which affects protocols like HTTP. In HTTP, denial
or restriction of access can be made apparent by the use of status
code 451, which allows server operators to operate with greater
transparency in circumstances where issues of law or public policy
affect their operation [RFC7725].
If a protocol potentially enables censorship, protocol designers
should strive towards creating error codes that capture difference
scenarios (blocked due to administrative policy, unavailable because
of legal requirements, etc.) to minimise ambiguity for end-users.
In the development of the IPv6 protocol, it was discussed to embed a
Media Access Control (MAC) address into unique IP addresses. This
would make it possible for 'eavesdroppers and other information
collectors to identify when different addresses used in different
transactions actually correspond to the same node. This is why
standardisation efforts like Privacy Extensions for Stateless Address
Autoconfiguration in IPv6 [RFC4941] and MAC address randomization
[draft-zuniga-mac-address-randomization] have been pursued.
Impacts:
- Right to freedom of expression
- Right to political participation
- Right to participate in cultural life, arts and science
- Right to freedom of assembly and association
3.3.7. Open Standards
Question(s): Is your protocol fully documented in a way that it could
be easily implemented, improved, built upon and/or further developed?
Do you depend on proprietary code for the implementation, running or
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further development of your protocol? Does your protocol favor a
particular proprietary specification over technically-equivalent
competing specification(s), for instance by making any incorporated
vendor specification "required" or "recommended" [RFC2026]? Do you
normatively reference another standard that is not available without
cost (and could you do without it)? Are you aware of any patents
that would prevent your standard from being fully implemented
[RFC8179] [RFC6701]?
Explanation: The Internet was able to be developed into the global
network of networks because of the existence of open, non-proprietary
standards [Zittrain]. They are crucial for enabling
interoperability. Yet, open standards are not explicitly defined
within the IETF. On the subject, [RFC2026] states: "Various national
and international standards bodies, such as ANSI, ISO, IEEE, and ITU-
T, develop a variety of protocol and service specifications that are
similar to Technical Specifications defined at the IETF. National
and international groups also publish "implementors' agreements" that
are analogous to Applicability Statements, capturing a body of
implementation-specific detail concerned with the practical
application of their standards. All of these are considered to be
"open external standards" for the purposes of the Internet Standards
Process." Similarly, [RFC3935] does not define open standards but
does emphasize the importance of an "open process", i.e. "any
interested person can participate in the work, know what is being
decided, and make his or her voice heard on the issue."
Open standards (and open source software) allow users to glean
information about how the tools they are using work, including the
tools' security and privacy properties. They additionally allow for
permissionless innovation, which is important to maintain the freedom
and ability to freely create and deploy new protocols on top of the
communications constructs that currently exist. It is at the heart
of the Internet as we know it, and to maintain its fundamentally open
nature, we need to be mindful of the need for developing open
standards.
All standards that need to be normatively implemented should be
freely available and with reasonable protection for patent
infringement claims, so it can also be implemented in open source or
free software. Patents have often held back open standardization or
been used against those deploying open standards, particularly in the
domain of cryptography [newegg]. An exemption of this is sometimes
made when a protocol is standardized that normatively relies on
specifications produced by others SDOs that are not freely available.
Patents in open standards or in normative references to other
standards should have a patent disclosure [notewell], royalty-free
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licensing [patentpolicy], or some other form of fair, reasonable and
non-discriminatory terms.
Example: [RFC6108] describes a system for providing critical end-user
notifications to web browsers, which has been deployed by Comcast, an
Internet Service Provider (ISP). Such a notification system is being
used to provide near-immediate notifications to customers, such as to
warn them that their traffic exhibits patterns that are indicative of
malware or virus infection. There are other proprietary systems that
can perform such notifications, but those systems utilize Deep Packet
Inspection (DPI) technology. In contrast, that document describes a
system that does not rely upon DPI, and is instead based on open IETF
standards and open source applications.
Impacts:
- Right to freedom of expression
- Right to participate in cultural life, arts and science
3.3.8. Heterogeneity Support
Question(s): Does your protocol support heterogeneity by design?
Does your protocol allow for multiple types of hardware? Does your
protocol allow for multiple types of application protocols? Is your
protocol liberal in what it receives and handles? Will it remain
usable and open if the context changes? Does your protocol allow
there to be well-defined extension points? Do these extension points
allow for open innovation?
Explanation: The Internet is characterized by heterogeneity on many
levels: devices and nodes, router scheduling algorithms and queue
management mechanisms, routing protocols, levels of multiplexing,
protocol versions and implementations, underlying link layers (e.g.,
point-to-point, multi-access links, wireless, FDDI, etc.), in the
traffic mix and in the levels of congestion at different times and
places. Moreover, as the Internet is composed of autonomous
organizations and Internet service providers, each with their own
separate policy concerns, there is a large heterogeneity of
administrative domains and pricing structures. As a result, the
heterogeneity principle proposed in [RFC1958] needs to be supported
by design [FIArch].
Heterogeneity support in protocols can thus enable a wide range of
devices and (by extension) users to participate on the network.
Example: Heterogeneity is inevitable and needs be supported by
design. Multiple types of hardware must be allowed for, e.g.
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transmission speeds differing by at least 7 orders of magnitude,
various computer word lengths, and hosts ranging from memory-starved
microprocessors up to massively parallel supercomputers. Multiple
types of application protocols must be allowed for, ranging from the
simplest such as remote login up to the most complex such as commit
protocols for distributed databases. [RFC1958].
Impacts:
- Right to freedom of expression
- Right to political participation
3.3.9. Pseudonymity
Question(s): Have you considered the Privacy Considerations for
Internet Protocols [RFC6973], especially section 6.1.2 ? Does the
protocol collect personally derived data? Does the protocol generate
or process anything that can be, or be tightly correlated with,
personally identifiable information? Does the protocol utilize data
that is personally-derived, i.e. derived from the interaction of a
single person, or their device or address? Does this protocol
generate personally derived data, and if so how will that data be
handled?
Explanation: Pseudonymity - the ability to use a persistent
identifier not linked to one's offline identity - is an important
feature for many end-users, as it allows them different degrees of
disguised identity and privacy online. This can allow an enabling
environment for users to exercise other rights, including freedom of
expression and political participation, without fear or direct
identification or disrcimination.
Example: While designing a standard that exposes personal data, it is
important to consider ways to mitigate the obvious impacts. While
pseudonyms cannot be simply reverse engineered - some early
approaches simply took approaches such as simple hashing of IP
addresses, these could then be simply reversed by generating a hash
for each potential IP address and comparing it to the pseudonym -
limiting the exposure of personal data remains important.
Pseudonymity means using a pseudonym instead of one's "real" name.
There are many reasons for users to use pseudonyms, for instance to:
hide their gender, protect themselves against harassment, protect
their families' privacy, frankly discuss sexuality, or develop an
artistic or journalistic persona without repercussions from an
employer, (potential) customers, or social surrounding.
[geekfeminism] The difference between anonymity and pseudonymity is
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that a pseudonym often is persistent. "Pseudonymity is strengthened
when less personal data can be linked to the pseudonym; when the same
pseudonym is used less often and across fewer contexts; and when
independently chosen pseudonyms are more frequently used for new
actions (making them, from an observer's or attacker's perspective,
unlinkable)." [RFC6973]
Impacts:
- Right to non-discrimination
- Right to freedom of expression
- Right to political participation
- Right to freedom of assembly and association
3.3.10. Anonymity
Question(s): Does your protocol make use of persistent identifiers?
Can it be done without them? Did you have a look at the Privacy
Considerations for Internet Protocols [RFC6973], especially section
6.1.1 of that document?
Explanation: Anonymity refers to the condition of an identity being
unknown or concealed [RFC4949]. Even though full anonymity is hard
to achieve, it is a non-binary concept. Making pervasive monitoring
and tracking harder is important for many users as well as for the
IETF [RFC7258]. Achieving a higher level of anonymity is an
important feature for many end-users, as it allows them different
degrees of privacy online. Anonymity is an inherent part of the
right to freedom of opinion and expression and the right to privacy.
Avoid adding identifiers, options or configurations that create or
might lead to patterns or regularities that are not explicitly
required by the protocol.
If your protocol collects data and distributes it (see [RFC6235]),
you should anonymize the data, but keep in mind that "anonymizing"
data is notoriously hard. Do not think that just dropping the last
byte of an IP address "anonymizes" data. If your protocol allows for
identity management, there should be a clear barrier between the
identities to ensure that they cannot (easily) be associated with
each other.
Often protocols expose personal data, it is important to consider
ways to mitigate the obvious privacy impacts. A protocol that uses
data that could help identify a sender (items of interest) should be
protected from third parties. For instance, if one wants to hide the
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source/destination IP addresses of a packet, the use of IPsec in
tunneling mode (e.g., inside a virtual private network) can be
helpful to protect from third parties likely to eavesdrop packets
exchanged between the tunnel endpoints.
Example: An example is DHCP where sending a persistent identifier as
the client name was not mandatory but, in practice, done by many
implementations, before [RFC7844].
Impacts:
- Right to non-discrimination
- Right to political participation
- Right to freedom of assembly and association
- Right to security
3.3.11. Accessibility
Question(s): Is your protocol designed to provide an enabling
environment for all? Have you looked at the W3C Web Accessibility
Initiative for examples and guidance?
Explanation: Sometimes in the design of protocols, websites, web
technologies, or web tools, barriers are created that exclude people
from using the Web. The Internet should be designed to work for all
people, whatever their hardware, software, language, culture,
location, or physical or mental ability. When the Internet
technologies meet this goal, it will be accessible to people with a
diverse range of hearing, movement, sight, and cognitive ability.
[W3CAccessibility]
Example: The HTML protocol as defined in [HTML5] specifically
requires that every image must have an alt attribute (with a few
exceptions) to ensure images are accessible for people that cannot
themselves decipher non-text content in web pages.
Impacts:
- Right to non-discrimination
- Right to freedom of assembly and association
- Right to education
- Right to political participation
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3.3.12. Localization
Question(s): Does your protocol uphold the standards of
internationalization? Have you made any concrete steps towards
localizing your protocol for relevant audiences?
Explanation: Localization refers to the adaptation of a product,
application or document content to meet the language, cultural and
other requirements of a specific target market (a locale)
[W3Ci18nDef]. It is also described as the practice of translating an
implementation to make it functional in a specific language or for
users in a specific locale (see Internationalization).
Example: The Internet is a global medium, but many of its protocols
and products are developed with a certain audience in mind, that
often share particular characteristics like knowing how to read and
write in ASCII and knowing English. This limits the ability of a
large part of the world's online population from using the Internet
in a way that is culturally and linguistically accessible. An
example of a protocol that has taken into account the view that
individuals like to have access to data in their native language can
be found in [RFC5646]. This protocol labels the information content
with an identifier for the language in which it is written. And this
allows information to be presented in more than one language.
Impacts:
- Right to non-discrimination
- Right to participate in cultural life, arts and science
- Right to freedom of expression
3.3.13. Decentralization
Question(s): Can your protocol be implemented without a single point
of control? If applicable, can your protocol be deployed in a
federated manner? What is the potential for discrimination against
users of your protocol? How can your protocol be used to implicate
users? Does your protocol create additional centralized points of
control?
Explanation: Decentralization is one of the central technical
concepts of the architecture of the networks, and embraced as such by
the IETF [RFC3935]. It refers to the absence or minimization of
centralized points of control, a feature that is assumed to make it
easy for new users to join and new uses to unfold [Brown]. It also
reduces issues surrounding single points of failure, and distributes
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the network such that it continues to function even if one or several
nodes are disabled. With the commercialization of the Internet in
the early 1990s, there has been a slow move away from
decentralization, to the detriment of the technical benefits of
having a decentralized Internet.
Example: The bits traveling the Internet are increasingly susceptible
to monitoring and censorship, from both governments and Internet
service providers, as well as third (malicious) parties. The ability
to monitor and censor is further enabled by the increased
centralization of the network that creates central infrastructure
points that can be tapped in to. The creation of peer-to-peer
networks and the development of voice-over-IP protocols using peer-
to-peer technology in combination with distributed hash table (DHT)
for scalability are examples of how protocols can preserve
decentralization [Pouwelse].
Impacts:
- Right to freedom of expression
- Right to freedom of assembly and association
3.3.14. Reliability
Question(s): Is your protocol fault tolerant? Does it downgrade
gracefully, i.e. with mechanisms for fallback and/or notice? Can
your protocol resist malicious degradation attempts? Do you have a
documented way to announce degradation? Do you have measures in
place for recovery or partial healing from failure? Can your
protocol maintain dependability and performance in the face of
unanticipated changes or circumstances?
Explanation: Reliability and resiliency ensures that a protocol will
execute its function consistently and error resistant as described,
and function without unexpected result. A system that is reliable
degrades gracefully and will have a documented way to announce
degradation. It also has mechanisms to recover from failure
gracefully, and if applicable, allow for partial healing.
It is important here to draw a distinction between random degradation
and malicious degradation. Many current attacks against TLS, for
example, exploit TLS' ability to gracefully downgrade to older cipher
suites - from a functional perspective, this is useful; from a
security perspective, this can be disastrous. As with
confidentiality, the growth of the Internet and fostering innovation
in services depends on users having confidence and trust [RFC3724] in
the network. For reliability, it is necessary that services notify
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the users if a delivery fails. In the case of real-time systems in
addition to the reliable delivery the protocol needs to safeguard
timeliness.
Example: In the modern IP stack structure, a reliable transport layer
requires an indication that transport processing has successfully
completed, such as given by TCP's ACK message [RFC0793], and not
simply an indication from the IP layer that the packet arrived.
Similarly, an application layer protocol may require an application-
specific acknowledgment that contains, among other things, a status
code indicating the disposition of the request (See [RFC3724]).
Impacts:
- Right to freedom of expression
- Right to security
3.3.15. Confidentiality
Question(s): Does this protocol expose information related to
identifiers or data? If so, does it do so to each other protocol
entity (i.e., recipients, intermediaries, and enablers) [RFC6973]?
What options exist for protocol implementers to choose to limit the
information shared with each entity? What operational controls are
available to limit the information shared with each entity?
What controls or consent mechanisms does the protocol define or
require before personal data or identifiers are shared or exposed via
the protocol? If no such mechanisms or controls are specified, is it
expected that control and consent will be handled outside of the
protocol?
Does the protocol provide ways for initiators to share different
pieces of information with different recipients? If not, are there
mechanisms that exist outside of the protocol to provide initiators
with such control?
Does the protocol provide ways for initiators to limit the sharing or
express individuals' preferences to recipients or intermediaries with
regard to the collection, use, or disclosure of their personal data?
If not, are there mechanisms that exist outside of the protocol to
provide users with such control? Is it expected that users will have
relationships that govern the use of the information (contractual or
otherwise) with those who operate these intermediaries? Does the
protocol prefer encryption over clear text operation?
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Explanation: Confidentiality refers to keeping your data secret from
unintended listeners [BCP72]. The growth of the Internet depends on
users having confidence that the network protects their personal data
[RFC1984].
Example: Protocols that do not encrypt their payload make the entire
content of the communication available to the idealized attacker
along their path. Following the advice in [RFC3365], most such
protocols have a secure variant that encrypts the payload for
confidentiality, and these secure variants are seeing ever-wider
deployment. A noteworthy exception is DNS [RFC1035], as DNSSEC
[RFC4033] does not have confidentiality as a requirement. This
implies that, in the absence of the use of more recent standards like
DNS over TLS [RFC7858] or DNS over HTTPS [RFC8484], all DNS queries
and answers generated by the activities of any protocol are available
to the attacker. When store-and-forward protocols are used (e.g.,
SMTP [RFC5321]), intermediaries leave this data subject to
observation by an attacker that has compromised these intermediaries,
unless the data is encrypted end-to-end by the application-layer
protocol or the implementation uses an encrypted store for this data
[RFC7624].
Impacts:
- Right to privacy
- Right to security
3.3.16. Integrity
Question(s): Does your protocol maintain, assure and/or verify the
accuracy of payload data? Does your protocol maintain and assure the
consistency of data? Does your protocol in any way allow for the
data to be (intentionally or unintentionally) altered?
Explanation: Integrity refers to the maintenance and assurance of the
accuracy and consistency of data to ensure it has not been
(intentionally or unintentionally) altered.
Example: Integrity verification of data is important to prevent
vulnerabilities and attacks from on-path attackers. These attacks
happen when a third party (often for malicious reasons) intercepts a
communication between two parties, inserting themselves in the middle
changing the content of the data. In practice this looks as follows:
Alice wants to communicate with Bob.
Corinne forges and sends a message to Bob, impersonating Alice.
Bob cannot see the data from Alice was altered by Corinne.
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Corinne intercepts and alters the communication as it is sent between
Alice and Bob.
Corinne is able to control the communication content.
Impacts:
- Right to freedom of expression
- Right to security
3.3.17. Authenticity
Question(s): Do you have sufficient measures to confirm the truth of
an attribute of a single piece of data or entity? Can the attributes
get garbled along the way (see security)? If relevant, have you
implemented IPsec, DNSsec, HTTPS and other Standard Security Best
Practices?
Explanation: Authenticity ensures that data does indeed come from the
source it claims to come from. This is important to prevent certain
attacks or unauthorized access and use of data.
At the same time, authentication should not be used as a way to
prevent heterogeneity support, as is often done for vendor lock-in or
digital rights management.
Example: Authentication of data is important to prevent
vulnerabilities, and attacks from on-path attackers. These attacks
happen when a third party (often for malicious reasons) intercepts a
communication between two parties, inserting themselves in the middle
and posing as both parties. In practice this looks as follows:
Alice wants to communicate with Bob.
Alice sends data to Bob.
Corinne intercepts the data sent to Bob.
Corinne reads (and potentially alters) the message to Bob.
Bob cannot see the data did not come from Alice but from Corinne.
When there is proper authentication the scenario would be as follows:
Alice wants to communicate with Bob.
Alice sends data to Bob.
Corinne intercepts the data sent to Bob.
Corinne reads and alters the message to Bob.
Bob can see the data did not come from Alice.
Impacts:
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- Right to privacy
- Right to freedom of expression
- Right to security
3.3.18. Adaptability
Question(s): Is your protocol written in such a way that it would be
easy for other protocols to be developed on top of it, or to interact
with it? Does your protocol impact permissionless innovation? (See
Open Standards)
Explanation: Adaptability is closely interrelated with permissionless
innovation: both maintain the freedom and ability to freely create
and deploy new protocols on top of the communications constructs that
currently exist. It is at the heart of the Internet as we know it,
and to maintain its fundamentally open nature, we need to be mindful
of the impact of protocols on maintaining or reducing permissionless
innovation to ensure the Internet can continue to develop.
Example: WebRTC generates audio and/or video data. In order to
ensure that WebRTC can be used in different locations by different
parties, it is important that standard Javascript APIs are developed
to support applications from different voice service providers.
Multiple parties will have similar capabilities, in order to ensure
that all parties can build upon existing standards these need to be
adaptable, and allow for permissionless innovation.
Impacts:
- Right to education
- Freedom of expression
- Freedom of assembly and association
3.3.19. Outcome Transparency
Question(s): Are the effects of your protocol fully and easily
comprehensible, including with respect to unintended consequences of
protocol choices?
Explanation: Certain technical choices may have unintended
consequences.
Example: Lack of authenticity may lead to lack of integrity and
negative externalities, of which spam is an example. Lack of data
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that could be used for billing and accounting can lead to so-called
"free" arrangements which obscure the actual costs and distribution
of the costs, for example the barter arrangements that are commonly
used for Internet interconnection; and the commercial exploitation of
personal data for targeted advertising which is the most common
funding model for the so-called "free" services such as search
engines and social networks. Other unexpected outcomes might not be
technical, but rather architectural, social or economical.
Impacts:
- Freedom of expression
- Privacy
- Freedom of assembly and association
- Access to information
3.3.20. Remedy and Attribution
Question(s): Can your protocol facilitate a negatively impacted
party's right to the appropriate remedy without disproportionately
impacting other parties' human rights, especially their right to
privacy?
Explanation: Attribution (i.e. mechanisms in protocols or
architectures that are designed to make communications or artifacts
attributable to a certain computer or individual) may help victims of
crimes in seeking appropriate remedy, or allow law enforcement
agencies to identify a possible violator. However, attribution
mechanisms may impede the exercise of the right to privacy. The
Special Rapporteur for Freedom of Expression has also argued that
anonymity is an inherent part of freedom of expression. [Kaye]
Considering the adverse impact of attribution on the right to privacy
and freedom of expression, enabling attribution on an individual
level is probably not consistent with human rights.
Impacts:
- Right to remedy
- Right to security
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3.3.21. Misc. considerations
Question(s): Have you considered potential negative consequences
(individual or societal) that your protocol or document might have?
Explanation: Publication of a particular RFC under a certain status
has consequences. Publication as an Internet Standard as part of the
Standards Track may signal to implementers that the specification has
a certain level of maturity, operational experience, and consensus.
Similarly, publication of a specification an experimental document as
part of the non-standards track would signal to the community that
the document "may be intended for eventual standardization but [may]
not yet [be] ready" for wide deployment. The extent of the
deployment, and consequently its overall impact on end-users, may
depend on the document status presented in the RFC. See [BCP9] and
updates to it for a fuller explanation.
4. Document Status
This RG document is currently documenting best practices and
guidelines for human rights reviews of network protocols,
architectures and other Internet-Drafts and RFCs.
5. Acknowledgements
Thanks to:
- Corinne Cath-Speth for work on [RFC8280].
- Theresa Engelhard, Joe Hall, Avri Doria, Joey Salazar, Corinne
Cath-Speth, Farzaneh Badii, Sandra Braman and the hrpc list for
reviews and suggestions.
- Individuals who conducted human rights reviews for their work and
feedback: Amelia Andersdotter, Beatrice Martini, Karan Saini and
Shivan Kaul Sahib.
6. Security Considerations
As this document concerns a research document, there are no security
considerations.
7. IANA Considerations
This document has no actions for IANA.
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8. Research Group Information
The discussion list for the IRTF Human Rights Protocol Considerations
Research Group is located at the e-mail address hrpc@ietf.org [1].
Information on the group and information on how to subscribe to the
list is at https://www.irtf.org/mailman/listinfo/hrpc [2]
Archives of the list can be found at: https://www.irtf.org/mail-
archive/web/hrpc/current/index.html [3]
9. References
9.1. Informative References
[BCP72] IETF, "Guidelines for Writing RFC Text on Security
Considerations", 2003,
.
[BCP9] Bradner, S. and IETF, "The Internet Standards Process --
Revision 3", 1996,
.
[Bless] Bless, R. and C. Orwat, "Values and Networks", 2015.
[Brown] Brown, I. and M. Ziewitz, "A Prehistory of Internet
Governance", Research Handbook on Governance of the
Internet. Cheltenham, Edward Elgar. , 2013.
[draft-irtf-pearg-censorship]
Hall, J., Aaron, M., Adams, S., Jones, B., and N.
Feamster, "A Survey of Worldwide Censorship Techniques",
2020,
.
[draft-zuniga-mac-address-randomization]
Zuniga, JC., Bernardos, CJ., and A. Andersdotter, "MAC
address randomization", 2020,
.
[FIArch] "Future Internet Design Principles", January 2012,
.
[geekfeminism]
Geek Feminism Wiki, "Pseudonymity", 2015,
.
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[Hill2014]
Hill, R., "Partial Catalog of Human Rights Related to ICT
Activities", 2014,
.
[HTML5] W3C, "HTML5", 2014, .
[HTTPS-REL]
Meyer, E., "Securing Web Sites Made Them Less Accessible",
2018, .
[ICCPR] United Nations General Assembly, "International Covenant
on Civil and Political Rights", 1976,
.
[ICESCR] United Nations General Assembly, "International Covenant
on Economic, Social and Cultural Rights", 1966,
.
[IRP] Internet Rights and Principles Dynamic Coalition, "10
Internet Rights & Principles", 2014,
.
[Kaye] Kaye, D., "The use of encryption and anonymity in digital
communications", 2015,
.
[newegg] Mullin, J., "Newegg on trial: Mystery company TQP rewrites
the history of encryption", 2013, .
[notewell]
IETF, "Note Well", 2015,
.
[patentpolicy]
W3C, "W3C Patent Policy", 2004,
.
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[Penney] Penney, J., "Chilling Effects: Online Surveillance and
Wikipedia Use", 2016, .
[Pouwelse]
Pouwelse, Ed, J., "Media without censorship", 2012,
.
[RFC0793] Postel, J., "Transmission Control Protocol", STD 7,
RFC 793, DOI 10.17487/RFC0793, September 1981,
.
[RFC1035] Mockapetris, P., "Domain names - implementation and
specification", STD 13, RFC 1035, DOI 10.17487/RFC1035,
November 1987, .
[RFC1958] Carpenter, B., Ed., "Architectural Principles of the
Internet", RFC 1958, DOI 10.17487/RFC1958, June 1996,
.
[RFC1984] IAB and IESG, "IAB and IESG Statement on Cryptographic
Technology and the Internet", BCP 200, RFC 1984,
DOI 10.17487/RFC1984, August 1996,
.
[RFC2026] Bradner, S., "The Internet Standards Process -- Revision
3", BCP 9, RFC 2026, DOI 10.17487/RFC2026, October 1996,
.
[RFC2277] Alvestrand, H., "IETF Policy on Character Sets and
Languages", BCP 18, RFC 2277, DOI 10.17487/RFC2277,
January 1998, .
[RFC3365] Schiller, J., "Strong Security Requirements for Internet
Engineering Task Force Standard Protocols", BCP 61,
RFC 3365, DOI 10.17487/RFC3365, August 2002,
.
[RFC3724] Kempf, J., Ed., Austein, R., Ed., and IAB, "The Rise of
the Middle and the Future of End-to-End: Reflections on
the Evolution of the Internet Architecture", RFC 3724,
DOI 10.17487/RFC3724, March 2004,
.
[RFC3935] Alvestrand, H., "A Mission Statement for the IETF",
BCP 95, RFC 3935, DOI 10.17487/RFC3935, October 2004,
.
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[RFC4033] Arends, R., Austein, R., Larson, M., Massey, D., and S.
Rose, "DNS Security Introduction and Requirements",
RFC 4033, DOI 10.17487/RFC4033, March 2005,
.
[RFC4101] Rescorla, E. and IAB, "Writing Protocol Models", RFC 4101,
DOI 10.17487/RFC4101, June 2005,
.
[RFC4941] Narten, T., Draves, R., and S. Krishnan, "Privacy
Extensions for Stateless Address Autoconfiguration in
IPv6", RFC 4941, DOI 10.17487/RFC4941, September 2007,
.
[RFC4949] Shirey, R., "Internet Security Glossary, Version 2",
FYI 36, RFC 4949, DOI 10.17487/RFC4949, August 2007,
.
[RFC5321] Klensin, J., "Simple Mail Transfer Protocol", RFC 5321,
DOI 10.17487/RFC5321, October 2008,
.
[RFC5646] Phillips, A., Ed. and M. Davis, Ed., "Tags for Identifying
Languages", BCP 47, RFC 5646, DOI 10.17487/RFC5646,
September 2009, .
[RFC6108] Chung, C., Kasyanov, A., Livingood, J., Mody, N., and B.
Van Lieu, "Comcast's Web Notification System Design",
RFC 6108, DOI 10.17487/RFC6108, February 2011,
.
[RFC6235] Boschi, E. and B. Trammell, "IP Flow Anonymization
Support", RFC 6235, DOI 10.17487/RFC6235, May 2011,
.
[RFC6365] Hoffman, P. and J. Klensin, "Terminology Used in
Internationalization in the IETF", BCP 166, RFC 6365,
DOI 10.17487/RFC6365, September 2011,
.
[RFC6701] Farrel, A. and P. Resnick, "Sanctions Available for
Application to Violators of IETF IPR Policy", RFC 6701,
DOI 10.17487/RFC6701, August 2012,
.
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[RFC6973] Cooper, A., Tschofenig, H., Aboba, B., Peterson, J.,
Morris, J., Hansen, M., and R. Smith, "Privacy
Considerations for Internet Protocols", RFC 6973,
DOI 10.17487/RFC6973, July 2013,
.
[RFC7258] Farrell, S. and H. Tschofenig, "Pervasive Monitoring Is an
Attack", BCP 188, RFC 7258, DOI 10.17487/RFC7258, May
2014, .
[RFC7624] Barnes, R., Schneier, B., Jennings, C., Hardie, T.,
Trammell, B., Huitema, C., and D. Borkmann,
"Confidentiality in the Face of Pervasive Surveillance: A
Threat Model and Problem Statement", RFC 7624,
DOI 10.17487/RFC7624, August 2015,
.
[RFC7725] Bray, T., "An HTTP Status Code to Report Legal Obstacles",
RFC 7725, DOI 10.17487/RFC7725, February 2016,
.
[RFC7844] Huitema, C., Mrugalski, T., and S. Krishnan, "Anonymity
Profiles for DHCP Clients", RFC 7844,
DOI 10.17487/RFC7844, May 2016,
.
[RFC7858] Hu, Z., Zhu, L., Heidemann, J., Mankin, A., Wessels, D.,
and P. Hoffman, "Specification for DNS over Transport
Layer Security (TLS)", RFC 7858, DOI 10.17487/RFC7858, May
2016, .
[RFC8179] Bradner, S. and J. Contreras, "Intellectual Property
Rights in IETF Technology", BCP 79, RFC 8179,
DOI 10.17487/RFC8179, May 2017,
.
[RFC8280] ten Oever, N. and C. Cath, "Research into Human Rights
Protocol Considerations", RFC 8280, DOI 10.17487/RFC8280,
October 2017, .
[RFC8484] Hoffman, P. and P. McManus, "DNS Queries over HTTPS
(DoH)", RFC 8484, DOI 10.17487/RFC8484, October 2018,
.
[RFC8980] Arkko, J. and T. Hardie, "Report from the IAB Workshop on
Design Expectations vs. Deployment Reality in Protocol
Development", RFC 8980, DOI 10.17487/RFC8980, February
2021, .
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[Saltzer] Saltzer, J., Reed, D., and D. Clark, "End-to-End Arguments
in System Design", ACM TOCS, Vol 2, Number 4, November
1984, pp 277-288. , 1984.
[UDHR] United Nations General Assembly, "The Universal
Declaration of Human Rights", 1948,
.
[UNHRC2016]
United Nations Human Rights Council, "UN Human Rights
Council Resolution "The promotion, protection and
enjoyment of human rights on the Internet" (A/HRC/32/
L.20)", 2016, .
[W3CAccessibility]
W3C, "Accessibility", 2015,
.
[W3Ci18nDef]
W3C, "Localization vs. Internationalization", 2010,
.
[Zittrain]
Zittrain, J., "The Future of the Internet - And How to
Stop It", Yale University Press , 2008,
.
9.2. URIs
[1] mailto:hrpc@ietf.org
[2] https://www.irtf.org/mailman/listinfo/hrpc
[3] https://www.irtf.org/mail-archive/web/hrpc/current/index.html
Authors' Addresses
Gurshabad Grover
Centre for Internet and Society
EMail: gurshabad@cis-india.org
Grover & ten Oever Expires August 26, 2021 [Page 30]
Internet-Draft Guidelines for HRPC February 2021
Niels ten Oever
University of Amsterdam
EMail: mail@nielstenoever.net
Grover & ten Oever Expires August 26, 2021 [Page 31]