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.
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 upfront.
- 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 legal overlays for this core overlay to Create an OCA test schema framework.
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 Lizar
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 Controller Credential
Unified Notice Control Language for Semantic (inputs)
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)
Privacy Controller Credential
Legal Semantic Element
|controller address registered|
|controller address (mailing)|
|controller contact||extend consent termination for a control point|
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]
OPN Privacy Profile URI
Link to the controller's profile in the OPN registry.
Type of Notice Receipt
Label Notice Receipt
A unique number for each Notice Receipt. SHOULD use UUID-4 [RFC 4122].
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).
The Controller’s profile public key. Used to sign notice icons, receipts and policies for higher assurance.
Language in which the consent was obtained. MUST use ISO 639-1:2002 [ISO 639] if this field is used. Default is 'EN'.
The identity (legal name) of the controller.
The jurisdiction(s) applicable to this notice
Contact name of the Controller. Contact could be a telephone number or an email address or a twitter handle.
Link to Notice
Link to the notice the receipt is for
Link to Policy
Method of notice presentation, sign, website pop-up etc
|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
ISO 29100 Actors
(Note: In progress - consulting with Steven on auto filling)
Gov ToiP Role
Legal Receipt Type for action or event
Delegated Role :
References for use for creating a Unified (generic) Data Control Vocabulary for OCA
Information technology — Security techniques — Privacy framework
ISO/IEC 29100:2011 provides a privacy framework which
|Status - Is publicly available - https://www.freestandardsdownload.com/iso-iec-29100-2011.html|
|ISO/IEC 29184:2020||Online privacy notice and consent||(just published - not available to public - we are working on publishing a report/appendix for use with this group )|
|W3C DPV 0.01||Data Privacy Vocabulary|
|Mapping Governance||Matching with ToiP Governance|
|Risks||Identity and Verifiable Credential Risks|