"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.
Process in progress:
| Salvatore D'Agostino | StatusACTIVE |
Overview
Decentralized Data Governance for Data subject’s (data) rights
- 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.
- 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.
- 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.
- The objectives:
- Define the attributes needed for a privacy controller credential to extend ISO standards to SSI,
- Use ANCR to specify notice semantics for specifying Representatives of the controller
- Develop a unifying approach for the notice semantics internationally with OCA
- 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,
- 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.
- what's 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. (click the link for join info)
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 a unified notice control as the language for people to see, understand and control personal data
- Gaps to cover
- DGA - Architecture
- core schema base
- what missing in this base?
- Verified Privacy Controller Credential
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.
- Use Cases
- Digital Immunisation Passport
- Holder, Verifier & Issuer
- Call for use cases.
- Digital Immunisation Passport
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
- to identify the accountable person / role that is bound to the legal entity identifier (aka) organization.
- 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
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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
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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
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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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Specification proposal: Define the assurance required to extend decentralized semantic governance for dynamic data controls to support privacy and trustworthy/regulated/surveillance a:
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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.
- The accountable person may or may not be an employee of the organization.
- Different jurisdictions name/define and reference this role differently
- 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)
- 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.
- 2 or more Controllers might be accountable for processing of personal data.
- Identify in context of service for any user the controller and accountable person.
- The privacy law in some jurisdictions, can itself break privacy law in other jurisdictions by requiring the accountable person information to be published publicly,
- Specifies how to axquire a VC (in this case the Privacy Controller Credential) for trust assurance for privacy assurance
- Gap of an international notice & control protocol and semantics for governance interoperability between domains and jurisdictions.
Specification Objective
- 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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- 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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- active -
- additional information
- Background: EU Funded Project Special
- Creating a Vocabulary
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
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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
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Required
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OPN Privacy Profile URI
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profile
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string
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Link to the controller's profile in the OPN registry.
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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
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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
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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
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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
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string
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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
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string
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Method of notice presentation, sign, website pop-up etc
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Optional
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OCA schema specification: https://docs.google.com/spreadsheets/d/1KOdq8Yy3OXmuELyh7tpHMlhyMZPSZ3Ib/edit#gid=68769926