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Privacy Technology

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Team 7 Summer 2014

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Privacy Technology Executive Summary Introduction System Architectural
Case1: Create a privacy policy. Case2: Save an unfinished privacy policy form Case3: Upload Json file and continue finishing questionnaire Why Struts?

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Functionality
Start. Modification. Submission.

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Design Rationale
Web-based. Easy to use. Model form regulation satisfied. Hyperlinks to relevant opt-out mechanisms. Logical consistency. Computer-readable version. Preview generated policy. HTML and CSS outputs.

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Executive Summary
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The objective of this project is to develop a web-based tool, Interactive Form Builder (IFB), required by United States Federal Trade Commission (FTC). The tool is designed and developed for financial institutions to generate web-based, interactive privacy notices that comply with the model form regulation published by eight federal regulators on December 1, 2009, under the Gramm-Leach-Bliley Act. The report discusses the system architecture for this project. It also covers how we address each requirement specifically for the Interactive Form Builder.


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Introduction
The current in use Online Form Builder enables the financial institutions to produce a PDF version of notice. However, the created PDF notice is reported containing errors and lack of consistency. Furthermore, while converting the PDF to HTML, the static one doesn’t facilitate hyperlinks to allow users to opt out directly. In order to address those problems, the Interactive Form Builder we have designed and developed enables the financial institutions to output HTML format page which is suitable for them to post on the website. Along with the HTML file, there will be a CSS file created. Users can change the style of the page using the CSS file. The Interactive Form Builder also provides the functionality to produce computer-readable output. By using the computer-readable output, display and comparison financial privacy notices becomes more easily. 


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System Architectural

Overall we use Struts 2 framework based on MVC pattern. More specifically we choose HTML/JavaScript/JQuery as front-end technology, and use Struts as backend. In the view part, users finish questionnaire on the website. The website detects users input and decide incoming questions to be answered. The whole error checks are extremely user friendly.

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MVC framework diagram

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Case1: Create a privacy policy.
When users finish questionnaires, they can submit the form and to see the preview of draft of privacy policy the website generated. So far, there is a completed form submitted to the controller, Struts2, and a corresponding form bean generated. Since we will use this form bean many times, we put them into session. Then users may want to see drafts. So there will be a request to controller to get these results.
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First, controller will forwards the request to a class and get form bean in the session. Second, forwards the form bean to a JSP. Last, in the JSP form bean will be parsed via EL and a draft of privacy policy is created.

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Case2: Save an unfinished privacy policy form
To parse and export computer readable files, we use json format. Json is a “fat-free alternative of XML”, which means we can fulfill requirements as well as save space and accelerate export speed. Users can save unfinished form anytime during the process of creation. At this time, DownloadAction class is called to receive form bean as a java object. Another reason using json is that there are plenty handy tools to export or parse json file to java object. We use GSON lib to convert java objects to a String object with json format. With GSON we can handle collections and generic types. Also it is highly customizable, we can specify those null fields with null object and they are not present in the output.

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The DownloadAction extends ActionSupport class in Struts2. So after String with json formatted created, we assign it to fileInputStream. This is mechanism provided by Struts, which handle download request. About filename and format can be changed in struts.xml.

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Case3: Upload Json file and continue finishing questionnaire
UploadAction class will receive a json file from JSP’s form. Then parse it to form bean as a java object using GSON lib. Finally it puts the form bean into session and forwards to form JSP to let users continue to finish the questionnaire.

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Why Struts?
Struts provides a handy framework to dispatch request and response from front-end to backend and vice versa. Here is a framework diagram to show how Struts2 being helpful in this case.

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Struts2 Architecture http://struts.apache.org/release/2.0.x/docs/architecture.html

First of all, HttpServletRequest will go through Filter chain to reach Dispatcher. Then the dispatcher will decide whether it needs any action and which action via ActionMapper. If ActionMapper needs to call an Action, Dispatcher will forwards request to ActionProxy. An ActionProxy reads struts.xml and find the specific Action class. Behind the scene, AcitonInvocation is the one who really invoke the Action and return result. In this case, the a result is a JSP or HTML, with HttpServletResponse to them.

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Other error checks are handled by backend as well as front-end. For example, some parts are missing from questionnaire, then the website will give users notice about those parts.

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Within the dispatch mechanism, available form bean tool makes getting and setting java bean from front-end to backend easy.


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Functionality
The whole process of creating privacy form is indicated as the picture above. Generally, it can be separated into three parts: Start, Modify and Submit.

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Start.
At the beginning, users have two choices: Import computer-readable file or Start new form. By importing existing computer-readable file, which is in Json format, users are able to continue editing after last input. In this way, they don’t need to start over again. If users choose to start new form, they are able to create a completely new form from the beginning.

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Modification.
There is a questionnaire consisting of totally 18 questions to guide users to create privacy form. Each question may have some logical relations with others. Different answers to certain questions will result in hiding or displaying other questions. An input validation mechanism is also implemented. It will check whether those required filling areas are missing. It will also check whether the inputs are valid as required. If something goes wrong, relevant alert message will appear right beside the error area. In this way, users can make some adjustment immediately after the input instead of being informed invalid input after clicking on submit button. Moreover, since all the questions are listed in one page, a floating progress bar on the left will indicate in which section the user is editing and how much the user has finished.

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Submission.
If users can’t finish the form at this time, they can choose to export the incomplete file as Json format. The “Save” button will float on the page as the scrolling bar goes up or down, which enables users to export the file more conveniently. After

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submitting the form successfully, it will jump to another page. In the success page, there are three buttons.

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“Preview” enables users to preview the generated HTML page directly on the site. “Download HTML + CSS” enables users to download generated HTML file along with the CSS file. “Download Computer-Readable File” enables users to download computer-readable file in Json format.

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Design Rationale
Web-based.
Our Interactive Form Builder is designed and developed based on web. When generating the privacy notice, financial institutions don’t need to download or install additional applications. We implement the project in struts 2 framework based on J2EE MVC architecture. For the front end, we adopt jQuery to support the dynamic functions.

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Easy to use.
In order to guide financial institutions to create their specific notices in an easy way, we have designed a questionnaire asking for relevant information. The questionnaire consists of 18 questions. Users only need to click on radio buttons, checkboxes or type into text areas to create their customized privacy forms. All the questions are displayed in one page so that users are able to review and edit their privacy form choices and contents more conveniently instead of jumping between different pages. Furthermore, for some questions which users may feel confused, there will be definitions and links to relevant information next to the questions to illustrate in detail.

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Model form regulation satisfied.
The notices which financial institutions use our Interactive Form Builder to produce are all complied with the disclosure requirements of the model form regulation published by eight federal regulators on December 1, 2009 under the Gramm-Leach-Bliley Act.

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Hyperlinks to relevant opt-out mechanisms.
When many financial institutions convert the PDF produced by the current tool Online Form Builder to HTML format, there are no hyperlinks to allow consumers to opt-out directly. In the Interactive Form Builder version we developed, if the
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financial institutions offer opt-out choice for customers, the produced notice will include the hyperlinks to guide customers to related opt-out mechanisms. The optout mechanisms include three ways: phone call contact, online website setting and mail-in form choice. Customers can make the choice according to different situations. Specifically, for the choice of mailing the form, there is also a hyperlink directing customers to the mail-in form section.

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Logical consistency.
The design of the questionnaire and form fields is consistent in logic avoiding contradictory or non-compliant fields. The questions in questionnaire are listed in a sequence where a question may influence other questions. For example, the subsequent input requirement will be different according to the different answers to the question “Q2: Do you have Affiliated Institutions?” If users choose “Yes," there will be an input area appearing right below the “Yes” to require users to input the affiliates. Users can also remove or add the affiliates list. If users choose “No," nothing will appear right below the choice to ask for affiliates information. For the question “Q6: Please fill in the Information Disclosure table:”, the content of the Information Disclosure Table is dynamically created by the choice users have made in previous questions 1 to 5. For different financial institutions, the content of table they need to fill in will be different. For example, if the user select “No” to “Q2: Do you have Affiliated Institutions?” there will be no affiliates related questions asked in the Information Disclosure Table when the user select “Yes” such as “For your affiliates’ everyday business purposes -- Information about customers’ transaction and experiences”. Moreover, in the Information Disclosure Table, there are totally three columns. The first column is “Reasons you can share customers information”. The second and third are “Do you share?” and “Can customers limit sharing?” that users need to answer correspondingly. If users select “No” to “Do you share?”, “You do not share.” will directly appear in the “Can customers limit sharing?” so that users don’t need to provide useless and repetitive answers in that column. While users select “Yes” to “Do you share?”, then they can continue to choose “Yes” or “No” to the column “Can customers limit sharing?” If there is any “Yes” in the column “Can customers limit sharing?”

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users need to indicate the ways of limit sharing in the subsequent question “Q7: Please provide methods of limiting sharing”.

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Computer-readable version.
The Interactive Form Builder is able to produce a computer-readable version of the content of the notice. We implement it in Json format. Compared to XML format, Json cannot only meet the requirements but also save space therefore facilitating the export process. By using the Json format file, users can modify and re-generate the privacy notices more conveniently instead of starting over again. Users are able to stop in the middle when creating the notice and save the incomplete form in a Json format file. By exporting the existing Json file, they can continue to create or edit the notices.The Json format file also helps to facilitate the comparison and display different financial privacy notices. To parse and export Json format file, there are many alternatives. The tool we adopt is GSON. It provides simple methods to convert between Java objects and Json. It also extensively supports collections and generics. Furthermore, GSON allows user to customize the representations of objects.

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Preview generated policy.
After finish the questionnaire and submit, users can preview the generated policy directly on the Interactive Form Builder site by clicking on the “Preview” button. In this way, they don’t bother to download or install anything before they can view the generated policy.

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HTML and CSS outputs.
After finish creating the notice, financial institutions are able to export relevant HTML file along with a corresponding Cascading Style Sheets(CSS) file. The HTML file is suitable to be posted on the financial institution's website. To be more customized, users can adjust the HTML by making some relevant changes in CSS file.

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