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Notice & Consent for people relies on clear communication.Decentralised identity relies on legal semantics to express technical semantics that mirror the same clarity. As there are no standardised semantics this presents a challenge. This work is a call to action for a Unified Notice Control Language, that utilizes the W3C Data Control Vocabulary ( mapped legal ontology) with decentralised legal semantics. | StatusACTIVE |
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Ovierview
Data Governance: Data subject’s (data) rights
- A key challenge is found in the lack of semantic harmonization for personal data control which provides security for the portability of private information is required as a precondition to data control and portability.
- to address this issue a unified notice control language which can be used to address harmonisation of the notice to indicate which Data Subjects rights apply to which context, and which data controls are authorized to be used by the Data Subject.
- whats involved
- use/finish the latest Operational Notice & Consent Receipt Specification -Kantara V1.2 that combines the ISO 29100 & 29184 and 27560 -standards comprised of the International privacy security framework (for Soverign data transfer)
- start a generic - unified data control notice schema - mapped to the ISO 29100 framework -
- map/generate a single international baseline overlay - ANCR WG- ISO 27560 - Notice & Consent Receipt - Record Structure.
Key Points to consider:
sovereign identity, a data processing activity is based on a data subject’s explicit or otherwise (human) consent (not internet service /cookie consent),
an individual’s privacy rights need to be extended to proportional digital privacy rights, so an overlay extends the analogue privacy law with a standard digital control semantics with the unified data control. This requires a legal (computational law) use case to illustrate (action for Mark Lizara unified notice control as the language for people to see, understand and control personal data
Digital Rights usage Challenge
different legal justifications have different rights associated with them. This makes it very difficult for people and orgs to know what rights apply in any given data control context - a problem that the can be solved with the use of these standards -
e.g. a notice for explicit consent - or legitimate interest? when does a Data subjects have the right to data portability (Article 20) when is processing is based on consent. When not used on consent- people have the right to object (Article 21)
the right to withdraw consent may provide a different outcomes - -
Articles 16 to 20 of the GDPR indicate that (when data processing is based on consent), data subjects have the right to erasure when consent has been withdrawn and the rights to restriction, rectification and access.
- Gaps to cover
- core schema base
- what missing in this base?
- Verified Privacy Controller Credential
- Use Cases
- Digital Immunisation Passport
- Holder, Verifier & Issuer
- Digital Immunisation Passport
Unified Notice Control Language for Semantic
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Harmonization
For UNCL - the aim is to start a specification with the key roles specified for data control, transparency and accountability as the starting point. And to start with the Privacy Controller, the key authorizing stakeholder for data processing, and to represent this in the. standards and references for legal governance, and to currate a list of proposed (new terms/elements to explore)
Requirements Privacy Controller Credential Specification
chain Providence chain starts with the person who is accountabilityaccountable bound to a legal entity.
Legal Entity Accountability Accountability Levels according to Tiers of Privacy Risk
Tier 0 - is self asserted controller (not a verified privacy controller) even in the ICO Controller Registry
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Tier 3 - Very High Risk - Beneficial owners - UNCL - starting with HTML tags ? for schema ?
Objective - is to have a single identifier for a Privacy Controller, which includes all LEI's for beneficial ownership.
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(Note: In progress - consulting with Steven on auto filling)
Data Governance Authority / | |||
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Certification Providers on Regulator Approved Codes of Conduct - very limited PII - data controller personal information and a linked reference to a data subjects identifier - |
Privacy Stakeholders | ISO Definition | |
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Regulator / | ||
PII Principal | ||
PII Controller | ||
PII Processor | ||
3rd Party |
Roles for Credentials | Description | |
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Issuer | ||
Holder | ||
Verifier |
Gov ToiP Role | UseCase Example | Roles | Actors Privacy Stakeholders
| |
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Provides the schema - hospital | issuer | Privacy Controller | ||
Person - Requesting Information from - patient/traveller | holder | Data Subject | ||
3rd Party - border control | Verifier | Data Processor / 3rd Party |
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- looking to make a process for what Legal Privacy Stakeholder has the Credential Role
- Steps to assign Stakeholder Roles
- Test for checking if its a processors or a 3rd party?
- Steps to assign Stakeholder Roles
Legal Semantic Element | semantic description | functional usage | fields Required | |
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controller | ||||
controller_identity | ||||
controller address registered | ||||
controller address (mailing) | ||||
controller contact | extend consent termination for a control point |
Delegated Role :
Delegated | |||
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Regulator | Ombudsman | ||
PII Principal | Guardian | ||
PII Controller | Joint-Controller | ||
PII Processor | Sub-Processor | ||
3rd Party | turtles |
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Lizar, M. & Pandit, H.J., OPN: Open Notice Receipt Schema, 14th International Conference on Semantic Systems (SEMANTiCS 2019), Karlsruhe, Germany, 2019 [Published http://www.tara.tcd.ie/handle/2262/91576 [accessed July 1, 2020]
Field Name | Field Label | Format | Description | Required/Optional |
Schema Version | version | string | Required | |
OPN Privacy Profile URI | profile | string | Link to the controller's profile in the OPN registry. | Required |
Type of Notice Receipt | Notice Receipt | string | Label Notice Receipt | Required |
Receipt ID | id | string | A unique number for each Notice Receipt. SHOULD use UUID-4 [RFC 4122]. | Required |
Timestamp | timestamp | integer | Date and time of when the notice was generated and provided. The JSON value MUST be expressed as the number of seconds since 1970-01-01 00:00:00 GMT (Unix epoch). | Required |
Signing Key | key | string | The Controller’s profile public key. Used to sign notice icons, receipts and policies for higher assurance. | Optional |
Language | language | string | Language in which the consent was obtained. MUST use ISO 639-1:2002 [ISO 639] if this field is used. Default is 'EN'. | Optional |
Controller Identity | controllerID | string | The identity (legal name) of the controller. | Required |
Legal Jurisdiction | jurisdiction | string | The jurisdiction(s) applicable to this notice | Required |
Controller Contact | controllerContact | string | Contact name of the Controller. Contact could be a telephone number or an email address or a twitter handle. | Required |
Link to Notice | notice | string | Link to the notice the receipt is for | Optional |
Link to Policy | policy | string | Link to the policies relevant to this notice e.g. privacy policy active at the time notice was provided | Required |
Context | context | string | Method of notice presentation, sign, website pop-up etc | Optional |
Receipt Type | The human understandable label for a record or receipt for data processing. This is used to extend the schema with profile for the type of legal processing - and is Used to identify data privacy rights and controls |
OCA schema specification: https://docs.google.com/spreadsheets/d/1KOdq8Yy3OXmuELyh7tpHMlhyMZPSZ3Ib/edit#gid=68769926