Posts tagged ‘re-identification’
I have a new paper (PDF) with Vitaly Shmatikov in the June issue of the Communications of the ACM. We talk about the technical and legal meanings of “personally identifiable information” (PII) and argue that the term means next to nothing and must be greatly de-emphasized, if not abandoned, in order to have a meaningful discourse on data privacy. Here are the main points:
The notion of PII is found in two very different types of laws: data breach notification laws and information privacy laws. In the former, the spirit of the term is to encompass information that could be used for identity theft. We have absolutely no issue with the sense in which PII is used in this category of laws.
On the other hand, in laws and regulations aimed at protecting consumer privacy, the intent is to compel data trustees who want to share or sell data to scrub “PII” in a way that prevents the possibility of re-identification. As readers of this blog know, this is essentially impossible to do in a foolproof way without losing the utility of the data. Our paper elaborates on this and explains why “PII” has no technical meaning, given that virtually any non-trivial information can potentially be used for re-identification.
What we are gunning after is the get-out-of-jail-free card, a.k.a. “safe harbor,” particularly in the HIPAA (health information privacy) context. In current practice, data owners can absolve themselves of responsibility by performing a syntactic “de-identification” of the data (although this isn’t the spirit of the law). Even your genome is not considered identifying!
Meaningful privacy protection is possible if account is taken of the specific types of computations that will be performed on the data (e.g., collaborative filtering, fraud detection, etc.). It is virtually impossible to guarantee privacy by considering the data alone, without carefully defining and analyzing its desired uses.
We are well aware of the burden that this imposes on data trustees, many of whom find even the current compliance requirements onerous. Often there is no one available who understands computer science or programming, and there is no budget to hire someone who does. That is certainly a conundrum, and it isn’t going to be fixed overnight. However, the current situation is a farce and needs to change.
Given that technologically sophisticated privacy protection mechanisms require a fair bit of expertise (although we hope that they will become commoditized in a few years), one possible way forward is by introducing stronger acceptable-use agreements. Such agreements would dictate what the collector or recipient of the data can and cannot do with it. They should be combined with some form of informed consent, where users (or, in the health care context, patients) acknowledge their understanding that there is a re-identification risk. But the law needs to change to pave the way for this more enlightened approach.
Thanks to Vitaly Shmatikov for comments on a draft of this post.
Some people claim that re-identification attacks don’t matter, the reasoning being: “I’m not important enough for anyone to want to invest time on learning private facts about me.” At first sight that seems like a reasonable argument, at least in the context of the re-identification algorithms I have worked on, which require considerable human and machine effort to implement.
The argument is nonetheless fallacious, because re-identification typically doesn’t happen at the level of the individual. Rather, the investment of effort yields results over the entire database of millions of people (hence the emphasis on “large-scale” or “en masse”.) On the other hand, the harm that occurs from re-identification affects individuals. This asymmetry exists because the party interested in re-identifying you and the party carrying out the re-identification are not the same.
In today’s world, the entities most interested in acquiring and de-anonymizing large databases might be data aggregation companies like ChoicePoint that sell intelligence on individuals, whereas the party interested in using the re-identified information about you would be their clients/customers: law enforcement, an employer, an insurance company, or even a former friend out to slander you.
Data passes through multiple companies or entities before reaching its destination, making it hard to prove or even detect that it originated from a de-anonymized database. There are lots of companies known to sell “anonymized” customer data: for example Practice Fusion “subsidizes its free EMRs by selling de-identified data to insurance groups, clinical researchers and pharmaceutical companies.” On the other hand, companies carrying out data aggregation/de-anonymization are a lot more secretive about it.
Another piece of the puzzle is what happens when a company goes bankrupt. Decode genetics recently did, which is particularly interesting because they are sitting on a ton of genetic data. There are privacy assurances in place in their original Terms of Service with their customers, but will that bind the new owner of the assets? These are legal gray areas, and are frequently exploited by companies looking to acquire data.
At the recent FTC privacy roundtable, Scott Taylor of Hewlett Packard said his company regularly had the problem of not being able to determine where data is being shared downstream after the first point of contact. I’m sure the same is true of other companies as well. (How then could we possibly expect third-party oversight of this process?) Since data fuels the modern Web economy, I suspect that the process of moving data around will continue to become more common as well as more complex, with more steps in the chain. We could use a good name for it — “data laundering,” perhaps?
The State of Oklahoma just passed legislation requiring that detailed information about every abortion performed in the state be submitted to the State Department of Health. Reports based on this data are to be made publicly available. The controversy around the law gained steam rapidly after bloggers revealed that even though names and addresses of mothers obtaining abortions were not collected, the women could nevertheless be re-identified from the published data based on a variety of other required attributes such as the date of abortion, age and race, county, etc.
As a computer scientist studying re-identification, this was brought to my attention. I was as indignant on hearing about it as the next smug Californian, and I promptly wrote up a blog post analyzing the serious risk of re-identification based on the answers to the 37 questions that each mother must anonymously report. Just before posting it, however, I decided to give the text of the law a more careful reading, and realized that the bloggers have been misinterpreting the law all along.
While it is true that the law requires submitting a detailed form to the Department of Health, the only information that is made public are annual reports with statistical tallies of the number of abortions performed under very broad categories, which presents a negligible to non-existent re-identification risk.
I’m not defending the law; that is outside my sphere of competence. There do appear to be other serious problems with it, outlined in a lawsuit aimed at stopping the law from going into effect. The text of this complaint, as Paul Ohm notes, does not raise the “public posting” claim. Besides, the wording of the law is very ambiguous, and I can certainly see why it might have been misinterpreted.
But I do want to lament the fact that bloggers and special interest groups can start a controversy based on a careless (or less often, deliberate) misunderstanding, and have it amplified by an emerging category of news outlets like the Huffington post, which have the credibility of blogs but a readership approaching traditional media. At this point the outrage becomes self-sustaining, and the factual inaccuracies become impossible to combat. I’m reminded of the affair of the gay sheep.
Philippe Golle and Kurt Partridge of PARC have a cute paper (pdf) on the anonymity of geo-location data. They analyze data from the U.S. Census and show that for the average person, knowing their approximate home and work locations — to a block level — identifies them uniquely.
Even if we look at the much coarser granularity of a census tract — tracts correspond roughly to ZIP codes; there are on average 1,500 people per census tract — for the average person, there are only around 20 other people who share the same home and work location. There’s more: 5% of people are uniquely identified by their home and work locations even if it is known only at the census tract level. One reason for this is that people who live and work in very different areas (say, different counties) are much more easily identifiable, as one might expect.
The paper is timely, because Location Based Services are proliferating rapidly. To understand the privacy threats, we need to ask the two usual questions:
- who has access to anonymized location data?
- how can they get access to auxiliary data linking people to location pairs, which they can then use to carry out re-identification?
The authors don’t say much about these questions, but that’s probably because there are too many possibilities to list! In this post I will examine a few.
GPS navigation. This is the most obvious application that comes to mind, and probably the most privacy-sensitive: there have been many controversies around tracking of vehicle movements, such as NYC cab drivers threatening to strike. The privacy goal is to keep the location trail of the user/vehicle unknown even to the service provider — unlike in the context of social networks, people often don’t even trust the service provider. There are several papers on anonymizing GPS-related queries, but there doesn’t seem to be much you can do to hide the origin and destination except via charmingly unrealistic cryptographic protocols.
The accuracy of GPS is a few tens or few hundreds of feet, which is the same order of magnitude as a city block. So your daily commute is pretty much unique. If you took a (GPS-enabled) cab home from work at a certain time, there’s a good chance the trip can be tied to you. If you made a detour to stop somewhere, the location of your stop can probably be determined. This is true even if there is no record tying you to a specific vehicle.
Location based social networking. Pretty soon, every smartphone will be capable of running applications that transmit location data to web services. Google Latitude and Loopt are two of the major players in this space, providing some very nifty social networking functionality on top of location awareness. It is quite tempting for service providers to outsource research/data-mining by sharing de-identified data. I don’t know if anything of the sort is being done yet, but I think it is clear that de-identification would offer very little privacy protection in this context. If a pair of locations is uniquely identifying, a trail is emphatically so.
The same threat also applies to data being subpoena’d, so data retention policies need to take into consideration the uselessness of anonymizing location data.
I don’t know if cellular carriers themselves collect a location trail from phones as a matter of course. Any idea?
Plain old web browsing. Every website worth the name identifies you with a cookie, whether you log in or not. So if you browse the web from a laptop or mobile phone from both home and work, your home and work IP addresses can be tied together based on the cookie. There are a number of free or paid databases for turning IP addresses into geographical locations. These are generally accurate up to the city level, but beyond that the accuracy is shaky.
A more accurate location fix can be obtained by IDing WiFi access points. This is a curious technological marvel that is not widely known. Skyhook, Inc. has spent years wardriving the country (and abroad) to map out the MAC addresses of wireless routers. Given the MAC address of an access point, their database can tell you where it is located. There are browser add-ons that query Skyhook’s database and determine the user’s current location. Note that you don’t have to be browsing wirelessly — all you need is at least one WiFi access point within range. This information can then be transmitted to websites which can provide location-based functionality; Opera, in particular, has teamed up with Skyhook and is “looking forward to a future where geolocation data is as assumed part of the browsing experience.” The protocol by which the browser communicates geolocation to the website is being standardized by the W3C.
The good news from the privacy standpoint is that the accurate geolocation technologies like the Skyhook plug-in (and a competing offering that is part of Google Gears) require user consent. However, I anticipate that once the plug-ins become common, websites will entice users to enable access by (correctly) pointing out that their location can only be determined to within a few hundred meters, and users will leave themselves vulnerable to inference attacks that make use of location pairs rather than individual locations.
Image metadata. An increasing number of cameras these days have (GPS-based) geotagging built-in and enabled by default. Even more awesome is the Eye-Fi card, which automatically uploads pictures you snap to Flickr (or any of dozens of other image sharing websites you can pick from) by connecting to available WiFi access points nearby. Some versions of the card do automatic geotagging in addition.
If you regularly post pseudonymously to (say) Flickr, then the geolocations of your pictures will probably reveal prominent clusters around the places you frequent, including your home and work. This can be combined with auxiliary data to tie the pictures to your identity.
Now let us turn to the other major question: what are the sources of auxiliary data that might link location pairs to identities? The easiest approach is probably to buy data from Acxiom, or another provider of direct-marketing address lists. Knowing approximate home and work locations, all that the attacker needs to do is to obtain data corresponding to both neighborhoods and do a “join,” i.e, find the (hopefully) unique common individual. This should be easy with Axciom, which lets you filter the list by “DMA code, census tract, state, MSA code, congressional district, census block group, county, ZIP code, ZIP range, radius, multi-location radius, carrier route, CBSA (whatever that is), area code, and phone prefix.”
Google and Facebook also know my home and work addresses, because I gave them that information. I expect that other major social networking sites also have such information on tens of millions of users. When one of these sites is the adversary — such as when you’re trying to browse anonymously — the adversary already has access to the auxiliary data. Google’s power in this context is amplified by the fact that they own DoubleClick, which lets them tie together your browsing activity on any number of different websites that are tracked by DoubleClick cookies.
Finally, while I’ve talked about image data being the target of de-anonymization, it may equally well be used as the auxiliary information that links a location pair to an identity — a non-anonymous Flickr account with sufficiently many geotagged photos probably reveals an identifiable user’s home and work locations. (Some attack techniques that I describe on this blog, such as crawling image metadata from Flickr to reveal people’s home and work locations, are computationally expensive to carry out on a large scale but not algorithmically hard; such attacks, as can be expected, will rapidly become more feasible with time.)
Summary. A number of devices in our daily lives transmit our physical location to service providers whom we don’t necessarily trust, and who keep might keep this data around or transmit it to third parties we don’t know about. The average user simply doesn’t have the patience to analyze and understand the privacy implications, making anonymity a misleadingly simple way to assuage their concerns. Unfortunately, anonymity breaks down very quickly when more than one location is associated with a person, as is usually the case.
Recently, the Alex Rodriguez steroid controversy has been in the news. The aspect that interests me is the manner in which it came to attention: A-Rod provided a urine sample as part of a supposedly anonymous survey of Major League Baseball players in 2003, the goal of which was to determine if more than 5% of players were using banned substances. When Federal agents came calling, the sample turned out to be not so anonymous after all.
The failure of anonymity here was total–the testing lab simply failed to destroy the samples or even take the labels off them, and the Players’ Union, which conducted the survey, failed to call the lab and ask them to do so during the more than one-week window that they had before the subpoena was issued.
However, there are a number of ways in which things could have gone wrong even if one or more of the parties had followed proper procedure. None of the scenarios below result in as straightforward an association between player and steroid use as we have seen. On the other hand, they can be just as damaging in the court of public opinion.
- If the samples were not destroyed, but simply de-identified, DNA can be recovered even after years, and the DNA can be used to match the player to the sample. You might argue the feds can’t easily get hold of players’ DNA to run such a matching, but once the association between drug test result and DNA has been made, it is a sword of Damocles hanging over the player’s head (note that A-Rod’s drug test happened six years ago.) The trend in recent years has been toward increased DNA profiling and bigger and bigger databases, and unlabeled samples therefore pose a clear danger.
- If the samples are destroyed, and the test results are stored in de-identified form, anonymity could still be compromised. A drug test measures the concentrations of a bunch of different chemicals in the urine. It is likely that this results in a “profile” that is characteristic of a person–just like a variety of other biometric characteristics. If the same player, having stopped the use of banned substances, provides another urine sample, it is possible that this profile can be matched to the old one based on the fact that most of the urine chemicals have not changed in concentration. It is an interesting research question to see how stable the “profiles” are, and what their discriminatory power is.
- Even more sophisticated attacks are possible. Let’s say that participant names are known, but other than that the only thing that’s released is a single statistic: the percentage of players that tested positive. Now, if the survey is performed on a regular basis, and a certain player (who happens to use steroids) participates only some of the time, the overall statistic is going to be slightly higher whenever that player participates. In spite of confounding factors, such as the fact that other players might also drop in and out, statistical techniques can be used to tease out this correlation.
This might sound like a tall order at first, but it is a proven attack strategy. The technique was used recently in a PLoS Genetics paper to identify if an individual had contributed DNA to an aggregate sample of hundreds of individuals.
I performed a quick experiment, assuming that there are 1,000 players in the sample, of which 100 participate half the time (the rest participate all the time). 5% of the players dope, and each player either dopes throughout the study period or not at all. Testing is done every 3 months; the list of participants in each wave of the survey is known, as well as the percentage of players who tested positive in each wave. I found that after 3 years, there is enough information to identify 80% of the cheating players who participate irregularly. (Players who participate regularly are clearly safe.)
[Technical note: that's an equal error rate of 20%; i.e, 20% of the cheating players are not accused, and 20% of the accused are innocent. There is a trade-off between the two numbers, as always; if a higher accuracy is required, say only 10% of accused players are innocent, then 65% of the cheating players can be identified.]
- When applicable, a combination of the above techniques such as matching de-identified profiles across different time-periods of a survey (or different surveys) can greatly increase the attacker’s potential.
The point of the above scenarios is to convince you that you can never, ever be certain that the connection between a person and their data has been definitively severed. Regular readers of this blog will know that this is a recurring theme of my research. The quantity of data being collected today and the computational power available have destroyed the traditional and ingrained assumptions about anonymity. Well-established procedures have been shown to be completely inadequate, and it is far from clear that things can be fixed. Anyone who cares about their privacy must be vigilant against giving up their data under false promises of anonymity.