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Notice & Consent for people relies on clear communication. 

Decentralized identity relies on legal semantics to instruct the scope of technical semantics.  Legal semantics for data control (that people can see and expect in person) are mirrored to provide data governance that people expect with the use of identifiers  and claims online.   Identity and traditionally data governance referring explicitly to control the flow of data in between domains and borders.

Specification work Proposed for to extend international Decentralized Semantic Governance for the DDE. 

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"The missing link between Human Trust and Digital Trust Assurance" for Human Identity that is Soverign Self  (HISS)

Digital surveillance is inherently untrustworthy and transparency over surveillance is missing for people.  Surveillance transparency is necessary to achieve human trustworthiness, and control independent of technology.  There is no trust for human tech only trust frameworks for enterprises and tech itself.  In the work here privacy is understood as human/individual centric, not business, legal and technical centric. This design rule is critical for trustworthy (including digital identity) infrastructure.    For this purpose this task force is tasked with specifying a credential that can be used with and for any identity management technology, including SSI, using International ISO/IEC standards and related Kantara Specifications. 

This task force is tasked with the specification of the  Privacy Controller Credential for accountable (to the individual) surveillance transparency, providence and accountability.


Salvatore D'Agostino

Team members:

Ken Adler

Process in progress:

  1. Updated Jan 6
  2. [Proposed] Update to TF Objectives 
  3. Technical Discussion Points 
    1. Linking Records 
    2. Providence Fields
      1. Beneficial Owner
        1. Owner Agreement
  4. Discussion Papers
    1. Decentralized Data Governance 

Notice & Consent Task Force 

Project owner:

Mark Lizar

 

Editors

Surveillance Controller EditorSalvatore DAgostino

OCA Schema Editor: 


Status

ACTIVE 

Overview  

Decentralized Data Governance for Data subject’s (data) rights.  For people to find technology trustworthy, and to be able to use digital identity to control perosonal data in a way we trust, people need transparency over the security and privacy of the use of their identity and personal data after it is provided.  They need to be able to see the privacy and security risks. In fact as a parent, this is legally required, in order to consent for them collection, use and surveillance of children's data and identifiers. 

The lack of standardized legal semantics for Digital identity and personal (Transborder) data management presents a challenge for identity management technologies and protocols.  This task force mission is to extend international identity governance standards to the SSI space with this specification for a privacy controller credential and the Unified Notice Control Language.

Decentralized Semantic Governance Stack

The Identity and Data Governance Stack of Specifications used to create this specification are designed to utilize OCA to overlay legal notice and consent schema's on to the existing ISO/IEC 29100 framework for jurisdictional privacy/surveillance notice profiles.

Then to enable identity governance interoperability by translating a local governance schema to the internationalized schema base for governance controls and privacy rights.  Then, to overly the next schema for localized identity and data governance controls, which utilized the same surveillance and privacy semantic governance framework for identity and data control interoperability.  

In this process the OCA utilizes this  stack of standards and specifications to syncratically harmonize purpose driven interoperability for meta-data and identity governance (by extending International standards)

The Stack

  1. The use of international standards framework for security, privacy and identity management  is critical for interoperability of data and identity controls internationally.
  2.  management of data  decentralized identifiers, VC's and the ISO 27710 series,Security Techniques - Information Security Management Systems -
    1. ISO/ IEC 29100 Security Techniques - Privacy Framework  (for identifier governance) 
    2. ISO/IEC 29184 Online Privacy Notice & Consent
    3. ISO/IEC 27560 Consent Record Structure (Kantara Notice & Consent Receipt specifications) 
      1. Decentralized Proof of Notice for orgs 
      2. Decentralized Proof of Processing (aka consent) for people
  3. W3C  Data Control Vocabulary ( maps  legal semantics to ontology) to harmonize decentralized legal semantics with machine readable semantics for linking identifiers and personal data. 
  4. Privacy By Design an Default
    1. Used for high assurance, harmonized semantics

Background

  1. A key challenge, which is addressed with an International standards, is the lack of semantic harmonization for personal data control  which provides security for the portability and control of private information and is a required for people to be able to independently consent and control personal information.  This challenge, which was originally championed by  the Open Notice Initiative's Presentation and Paper @ the W3C DoNotTrack Conference in Berkeley California. 'Opening Up the Online Infrastructure' called for collaboration on the semantic standards to be developed. Ultimately realizing that intention data governance standards were needed, and international data governance policy was required to govern between jurisdictions, technical domains, and identity management systems.  It was also abundantly clear, the only legal, and human centric framework for this Internationally, is Notice & Consent.  Notice and Consent, after an exhaustive research campaign, Notice, and semantics are the only consistent legal, technical and socially required component, for all contexts dealing with personal information. 
  2.  This turned into a Kantara Specification effort in 2014 and now, last year, ISO voted to fast track this to a standard 27560, to be used with ISO 29184 to address what was know by the  phrased of the Biggest Lie on the Internet, was a focus of a movie Terms and Condition's May Apply. With an international governance rule set, people can use independently of Terms and Conditions. 
  3. With the success of this work as an international standard this Task Force aims to collaborate to support an International data governance authority framework as an open resource for master data control transparency over personal information (with standardized notice).

Specification Outline

  1. Overview of (OPN) Data Governance Authority Architecture:
    1. Intro
      1. This data governance authority architecture provides the international legal roles for  
    2. Identity & Data Governance Legally Specified Actors /Stakeholders
      1. Policy Controller, Privacy (Data) Controller, Registration Operator Governance Authority, DGA - Registrar 
    3. Privacy Risk Assurance Levels 1-4
      1. Policy Controller, Privacy Controller, Data/Identity Governance Authority Operator (DGAO)
        1. Controller: Tier  0 Risk Assurance - Not Registered 
        2. Policy Controller ( or just Controller) - Tier 1 Assurance - Self Asserted Binding  -No Privacy Risk Assurance - Discoverable
        3. Privacy Controller (or  Data Controller) - Tier 2 Assurance - Signed Binding for Legal Compliance - Mitigated Risk Assurance
        4. Data Governance Authority Operator - Tier 3 - Assurance - High Risk Assurance 
        5. Registrar - Tier 4 - Registrar Infrastructure - 
          1. Low Risk Personal Data Processing - 
            1. only personal information of Controller, and Company Operators
  2. Privacy Controller Credential Specification
    1. Overview:  a Privacy Controller Credential is comprised of a bound relationship identifiers for accountability and transparency: This enables data supply chain transparency
      1. Accountable Person + Legal Entity Identifier
        1. Legal Status of Accountable person and Legal Entity 
        2. Wether the Accountable person is employed by Legal Entity, or 3rd Party 
          1. if 3rd Party - Privacy Controller Credential of 3rd party is required
      2. Conditions of access and use:
        1. the accountable person info should be masked unless required (not published as is required in some jurisdictions) 
  3. Use Case(s) 
    1. Digital Immunisation Passport
    2. Legal Justifications for processing
      1. Surveillance of identifiers  
      2. Holder, Verifier & Issuer 

Unified Notice Control Language for Semantic Harmonization 

UNCL:

Uses the definitions and terms specified in the ISO 29100 framework, Consent Receipt v1.2, for specifying key roles for data control, transparency and accountability.  This international framework is the basis for extending semantic data governance to decentralized data economy.  In this economy, the Privacy Controller Credential extended the Privacy Controller Public Profile for verified claims, decentralized identifiers, and Self Soverign applications.  For this purpose, this specification is used to provide the best practices for the data controller to generate a verifiable credential, the considerations in using this as a  legal credential for standardized data processing.  

The Privacy Controller, the accountable, authorizing stakeholder for data processing is the key audience for this specification and language. 

Key Problem> 

At this time, a high risk, high sensitivity data processing activity, has the responsibility to be transparent over the legal entities responsible for processing personal data, the beneficiaries of the data processing activity, in addition to any othe processors.  This includes partners and data processing service providers, like Google or identity management service provider.  

This privacy controller profile, printed out in long form would  have multiple legal entities and Privacy Controller Credentials required, this would include all of their mailing addresses (by law) and , public contact point/addresses, and the details of any jurisdictional representative for privacy and data protection.

This specification, aims to tease out the language used for specifying  these elements, which are legally required to be Public so that they can be represented with a single distributed identifier to simplify each  DDE interaction. 

Privacy Risk Assurance ;

  • refers to trustworthy transparency 
    • e.g does this organization use of standardized legal semantics for notice and consent to ease understanding

Requirements Privacy Controller Credential Specification (in Open Consent Groups' OPN Architecture)

Providence  chain starts with the person who is accountable bound to a legal entity. 

Legal Entity Accountability Levels according to Tiers of Privacy Risk

Tier 0 - No-Risk Indicated :  Self Asserted Binding  with a privacy policy - providing minimum Privacy Risk Assurance (trustworthy Transparency)

  • A non registered Broadcast listing 

Tier 1 - Policy Controller - Low Risk - doesn't process personal data electronically, does not collect or process personal information, and for any personal identifier, this is minimized and secure, has internal security for data of employee's

Tier 2 -  Privacy (data) Controller - Does process personal data for commercial benefit and use

Tier 3 - Very High Risk - invisible public surveillance, surveillance of children /vulnerable people etc   Beneficial owners (required) 

Tier 4 - Controller Operator - Provides Registration services for Privacy Controller Credentials, Mitigates Privacy Risk with codes of conduct and certifications that accredit codes of practice.  Controller can then register to these codes of conduct and practice 

Use's of The PCC Credential  -  a single identifier for a Privacy Controller, which links to all LEI's for beneficial ownership. 

  • Simplify Transparency 
  • Improve performance 
  • Sign Receipts to create tokens
  • Provides 
    • Privacy - Transparency over legal entities, accountable people and beneficial - 
    • Legal Entity Identifier Purpose and Sources
      • to identify the legal entity of the privacy controller 
      • beneficial owner of the legal entity 
  • Accountable Person Role
    • to identify the accountable person / role that is bound to the legal entity identifier (aka) organization. 
      • could be an employee
      • owner / director / officer 
      • data proaction officer 
      • 3rd. Party Company Representative 
        • accountable role - (for another 3rd Party) acting representative 
  • Privacy Controller 
    • under what authority 
    • under what legal justification 

ISO 29100 Privacy Stakeholders

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Privacy Stakeholders

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ISO Definition

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Gov ToiP Role

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UseCase Example 

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Roles

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Actors Privacy Stakeholders 

  • controller, processor, subject, 3rd Parties

...

  • 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? 

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Legal Semantic Element 

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semantic description

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functional usage

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fields Required

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Delegated Role :

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Delegated 

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References for use for creating a Unified (generic) Data Control Vocabulary for OCA

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Standard/Specifications

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Title

...

Description 

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Resource Status

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Information technology — Security techniques — Privacy framework

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ISO/IEC 29100:2011 provides a privacy framework which

  • specifies a common privacy terminology;
  • defines the actors and their roles in processing personally identifiable information (PII);
  • describes privacy safeguarding considerations; and
  • provides references to known privacy principles for information technology.

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  • legal ontology for technically breaking down and mapping legal ontology to a data legal ontology - 
  • the Notice +  CR V1.2 and W3C DPV, also use a common set of purpose categories. and the Kantara CR v1.1 for purpose specification
  • (note shared by initial FIHR approach - now much more evolved) 

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Topic List

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Topic Title 

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References

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Topic

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Link

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Reference Implementations

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Implementer

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OPN: Open Notice  (+ Consent) Receipt Schema: Starters Guide to Unified Data Control Schema

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]

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Field Name

...

Field Label

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Format

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Description 

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Required/Optional

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Schema Version

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version

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string

...

The version of specification used to which the receipt conforms. To refer to this version of the specification, the string "v1" or the IRI "https://w3id.org/OPN/v1" should be used.

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Required

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OPN Privacy Profile URI

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profile

...

string

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Link to the controller's profile in the OPN registry. 

...

Required

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Type of Notice Receipt

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Notice Receipt

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string 

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Label Notice Receipt 

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Required

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Receipt ID

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id

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string

...

A unique number for each Notice Receipt. SHOULD use UUID-4 [RFC 4122].

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Required

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Timestamp

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timestamp

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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).

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Required

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Signing Key

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key

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string

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The Controller’s profile public key. Used to sign notice icons, receipts and policies for higher assurance.

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Optional

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Language

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language

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string

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Language in which the consent was obtained. MUST use ISO 639-1:2002 [ISO 639] if this field is used. Default is 'EN'.

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Optional

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Controller Identity

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controllerID

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string

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The identity (legal name) of the controller.

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Required

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Legal Jurisdiction

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jurisdiction

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string

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The jurisdiction(s) applicable to this notice

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Required

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Controller Contact

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controllerContact

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string

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Contact name of the Controller. Contact could be a telephone number or an email address or a twitter handle.

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Required

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Link to Notice

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notice

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string

...

Link to the notice the receipt is for 

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Optional

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Link to Policy

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policy

...

string

...

Link to the policies relevant to this notice e.g. privacy policy active at the time notice was provided

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Required

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Context

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context

...

string

...

Method of notice  presentation, sign, website pop-up etc

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Optional

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Spec Dev Link


Specification proposal: 

Define the assurance required to extend decentralized semantic governance for dynamic data controls to support privacy and trustworthy/regulated/surveillance a:

  • Privacy Controller Credential 

Privacy Controller Credential For Decentralized Human Data Surveillance Governance aka Notice and Consent  

This working effort specifies a regulatory controller from existing standards that apply and can be mapped to any legal authorization for data processing.

This credential is comprised of the legal entity name and accountability profile as specified by regulation utilizing ISO/IEC 29100 Privacy & Security Techniques.  An open (no-fee, no barrier) and international standard from ISO (the Internationational Organization for Standardization) and the IEC (International ElectroTechnical Commission).   The use of this standard for the creation of records and receipts is critical for scaleable and interoperable Decentralized Data Governance interoperability between technical domains and legal jurisdictions.

What is this for:

This specification is for the regulation and governance of surveillance and digital identity technology independently of any digital identifiers or trust frameworks.  The objective is for the this specification to work with and enhance digital surveillance assurances already provided by work in ToiP.  The credentialling process benchmarks the privacy, security and compliance of digital identity technologies with international standards.

The aim of this task force outputs is to create a specification and by so doing implement ISO/IEC international standards to enable regulatory interoperability with human controls and transparency that scale for any authorized surveillance context.  To do this, this effort builds upon standards, incorporating additional technical specifications in order to support ToiP community efforts.  

Challenges being addressed with the PCC specification have been raised in the Kantara ANCR WG, W3C DPV CG, ISO/IEC 27560 Technical Committee's, CIO Council, DIACC Special Interest Group, IETF GNAP,  and VC's with DiD's.  The overarching objective is therefore to provide a specification  that supports these community efforts.  

  1. The accountable person may or may not be an employee of the organization. 
  2. Different jurisdictions name/define and reference this role differently 
  3. Some jurisdictions, like the UK have a data controller registry (DCR), where this binding is public and legally required (benefit in this case, challenge where absent) and the name of the accountable person is publicly available in ICO DCR.  (using blinding identity taxonomy)
  4. Some jurisdictions, like the EU require an accountable data controller representative in the jurisdiction where a service is operating, in order to address legal data privacy and security issues that may arise. 
  5. 2 or more Controllers might be accountable for processing of personal data.
    1. Identify in context of service for any user the controller and accountable person.
  6. The privacy law in some jurisdictions, can itself break privacy law in other jurisdictions by requiring the accountable person information to be published publicly, 
  7. Specifies how to axquire a VC (in this case the Privacy Controller Credential) for trust assurance for privacy assurance
  8. Gap of an international notice & control protocol and semantics for governance interoperability between domains and jurisdictions.

Specification Objective

  1. Develop an extensible controller credential format.

The specification shall provide: 

  • a record format that MUST blind the identity of the accountable person,
  • be usable as a linked data in a notice of control receipt, which provides only the controller information required for the purpose of credential use. 
  • record and provide a profile of the bound controller credentials in a manner that can show the controlling person before, during and after the use of a decentralized digital identifier.
  • control providence that begins with the person making the assertion to the accountable role using laws and standards to bind privacy rights request to a legal entity.

Decentralized Data Governance 

Decentralized Data Governance is the focus of the first Discussion Paper, which aims to look at the overlaps of digital identity surveillance technology and regulator led (regulatory) data governance. This will present the overall architecture and the contribution of certain standards used in the credential, as well as how digital identity specifications and protocols can be deployed to implement decentralized data governance.

Used to make credential

Standards

ISO/IEC 29100 

  • interop / usable for applying 29184 (as a compliance tool) 
  • interop with 27560 - Kantara Consent Receipt Work 
  • future - to use 27560 to interop with 2750 - Privacy by Design 
    • pending open access and usability of ISO Spec, e.g. through a Kantara or National Standards body liaison

Specifications

  • Kantara ANCR WG, AuthC protocol and V2 Notice Record and Consent Receipt Specification (for implementing the AuthC protocol) (parallel work)
  • W3C DPV CG Specification for notice record and receipt semantics 

 baseline is the international ISO/IEC 29100 security and privacy techniques framework, this is mapped to Legal jurisdiction notice schema and the differences and risks (in terms of rights and the performance of data controls) is provided as a component of the notice of control.

Using the Credential 

The use of an international standards framework for providing standarized notice semantics is critical to harmonize or highlight different security, privacy and identity management governance requirements.   Standardized semantics, usable for any data governance is also  critical for human interoperability/usability across domains which is the key driver of this work and effort at ToiP .

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