"The missing link between Human Trust and Digital Trust Assurance"

 digital trustworthiness - is about notice semantics so that people can trust and "see" who (if not oneself) is in control and accountable for personal information.

Overview  

Decentralized Data Governance for Data subject’s (data) rights

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 provide the International data governance framework as an open resource for master data control of personal information.
4. The objectives:
   1. Define the attributes needed for a privacy controller credential to extend ISO standards to SSI, 
   2. Use ANCR to specify notice semantics for specifying  Representatives of the controller
5. Develop a unifying approach for the notice semantics internationally with OCA
   1. Provide a common and simple contribution to a unified notice control language, putting together the semantics to include, legal schema, html schema, Jan-ld schema, for the governance and identity management technology,
   2.  Focus this on the use case to use OCA  for semantic harmonization and Notice and Consent receipts to determine which Data Subjects rights apply to any data processing context, linked to the  data controls as authorized by the Data Subject. 
   3. what's involved:
      1. 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) 
      2. start a generic - unified data control notice schema - mapped to the ISO 29100 framework - 
      3. map/generate a single international baseline overlay - ANCR WG-  ISO 27560 - Notice & Consent Receipt - Record Structure. (click the link for join info)
         

6. Key Points to consider:

   1.  sovereign identity, a data processing activity is based on a data subject’s explicit  or otherwise (human) consent (not internet service /cookie consent),

   2. 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 a unified notice control as the language for people to see, understand and control personal data

7. Gaps to cover 
   1. DGA - Architecture
   2. core schema base
   3. what missing in this base? 
      1. Verified Privacy Controller Credential 

   4. Digital Rights usage Challenge

      1. 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 - 

      2.  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)

      3. the right to withdraw consent may provide a different outcomes - - 

      4. 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.

8. Use Cases 
   1. Digital Immunisation Passport
      1. Holder, Verifier & Issuer
   2. Call for use cases.

Unified Notice Control Language for Semantic 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

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 - is self asserted controller (not a verified privacy controller) even in the ICO Controller Registry 

Tier 1 -  Privacy Controller - with low risk services - (employee privacy ) 

Tier 2 - High Risk Privacy - identity management, any special/sensitive personal data category - (see personal data categories)

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

Objective - for a credential  to provide a single identifier for a Privacy Controller, which links to all LEI's for beneficial ownership. 

• Privacy - Transparency over legal entities, accountable people and beneficial - 
• Legal Entity Identifier 
  • to identify the legal entity of the privacy controller 
  • beneficial owner of the legal entity 

• Accuntable Person
  • 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 Actors

(Note: In progress - consulting with Steven on auto filling) 

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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

 Privacy Controller Receipt Credential (Control Provenance Credential) 

This credential is essential for generating digital notice and consent, it contains the legal entity name, which is bound as a credential by the accountable person as defined by their role in the organization.

The challenges:

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, where this binding is public and legally required (benefit in this case, challenge where absent)
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.
6. Identify in context of service for any user the controller and accountable person.
7. The privacy law in some jurisdictions, can itself break privacy law in other jurisdictions by requiring the accountable person information to be published publicly, 
8. Extend a privacy assurance profile by binding a VC (in this case the Privacy Controller Credential) for trust assurance.
9. Developing a Unified Notice Control Language that is interoperable.

The proposed solution: 

Develop this controller credential specification with a set of rules for the use, maintenance, and lifecycle of a privacy controller credential. 

To illustrate: 

A record format to capture the bound controller information, which can be used to present a notice of control according to context, and a notice of who the accountable person is according to purpose of credential use.

The specification should 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, so as to 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.

Details for Risk and Liability Management 

• Provenance  of control starts with the person who is accountable and bound to a legal entity (who is liable). 

Overview  

Supporting Decentralized Data Controls with Identity Governance for Data subject’s (data) rights. This task force mission is to enhance identity and data governance interoperability  with standardized notice of Control and accountability for processing personal data (with the  ToiP layered governance model.)

The key challenge this initial specification is aimed to address is systemic  (and broadcasted) transparency over the controller of personal information, so that data controls can be used automatically to enable dynamic data control.

Unlike in physical world, the processors of your personal data are invisible. This is why the identity of the data controller is required in all legal privacy frameworks and is the most common and similar legal component for processing personal data.  This makes the notice of control an ideal focus for ToiP governance interoperability. 

Online, there can be many processors, personal identifiers can be shared and aggregated without any transparency, personal data may continuously be processed and people are completely unaware and at risk of this surveillance.  This is why the promise of SSI is so attractive and why profiling and aggregation using identifiers is specifically called out in privacy legislation as  high risk to privacy in which processing is required to be more (proportionally transparent).  What's more, even the Controller, might contain multiple legal entities. This challenges identity management technologies for privacy compliance and human trust. 

To address a key part of this challenge a specification for listing the Control Provenance, focusing on the legal entities and accountable people in control of processing personal data as the  first spec to providing the needed transparency (or Notice) for the control of processing, required for trustworthy processing. 

This specification will provide a nested schema to record a privacy controller credential for transparency over the control of processing.  This privacy controller credential is intended to use a stack of standards and specifications to provide a standard set of identity control semantics, that can then be used in notice and notification by people to control personal data directly to provide Privacy assurance. 

Decentralized Semantic Governance Stack

The Identity and Data Governance semantic based line is the international ISO/IEC 29100 security and privacy techniques framework, this is mapped to Legal jurisdiction notice schema and the differnces and risks (in terms of rights and the performance of data controls) is provided as a component of the notice of control.

The risks are used to provided a progressive framework for people to self-mitigate the risks and themselves drive the development of dynamic digital identity governance interoperability.  Translating a local governance schema to the internationalized schema base for governance controls and privacy rights comparison.  Then, to overlay the next schema for localized identity and data governance controls, which utilized the same surveillance and privacy semantic governance framework in order to indicate the level of  data governance interoperability. 

In this process the OCA utilizes this  stack of standards and specifications to syncratically harmonize data portability and control with purpose driven interoperability for data and identity governance.  

This is accomplished with the standard for specifying a purpose for notice and consent. 

The Trustworthy Transparency Specification Stack

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 .  

Interoperable semantic standards and specification stack:

1. For privacy and security notifications of  decentralized identifiers, VC's and the ISO 27710 series,Security Techniques - Information Security Management Systems - in particular,
   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
   4. Kantara Advanced  Notice & Consent Receipt specifications for 
      1. Decentralized Proof of Notice for orgs 
      2. Decentralized Proof of Processing (aka consent) for people
2. W3C  Data Control Vocabulary ( maps  legal semantics to ontology) to harmonize decentralized legal semantics with machine readable semantics for linking identifiers and personal data. 
3.  OCA Specification for Operational Semantic Notice 
   1. conformity assessment vectors for OCA schema's 
      1. legal schema overlay from localized privacy law schema 
      2. legal schema conformity assessment to ISO baseline 
      3. legal schema overlay conformity assessment to a privacy law schema 
      4. conformity assessment report on legal adequacy for privacy rigxzhts and associated infrormation controls

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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? 

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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

Topic List

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Topic Title 

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References

Reference Implementations

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Implementer

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Reference: OPN-Notice Schema

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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OCA schema specification: https://docs.google.com/spreadsheets/d/1KOdq8Yy3OXmuELyh7tpHMlhyMZPSZ3Ib/edit#gid=68769926

Background of this Stack

1. A key challenge to interoperability is addressed with the International ISO/IEC standards framework 29100 and 29184. This provides a semantic control framework to address 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 first presented the W3C DoNotTrack Conference in Berkeley California. 'Opening Up the Online Infrastructure' . 
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 identity control transparency over personal information (with standardized notification for the PII Principle)