Notice & Consent Task Force
Mark Lizar Salvatore D'Agostino
Notice & Consent for people relies on clear communication.
Decentralized identity relies on legal semantics and notices by implementors to be compliant with sovereign data rights. These semantics need to be standardized to be used by decentralized identifier based technologies for human interoperable data governance.
The more unified across ecosystems the notice and risk semantics, the more human centric the service becomes.
Specification proposal: to extend Decentralized Semantic Governance for dynamic data control architecture for active control transparency that people can use. ( DDC)
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:
- For privacy and security notifications of decentralized identifiers, VC's and the ISO 27710 series,Security Techniques - Information Security Management Systems - in particular,
- ISO/ IEC 29100 Security Techniques - Privacy Framework (for identifier governance)
- ISO/IEC 29184 Online Privacy Notice & Consent
- ISO/IEC 27560 Consent Record Structure
- Kantara Advanced Notice & Consent Receipt specifications for
- Decentralized Proof of Notice for orgs
- Decentralized Proof of Processing (aka consent) for people
- W3C Data Control Vocabulary ( maps legal semantics to ontology) to harmonize decentralized legal semantics with machine readable semantics for linking identifiers and personal data.
- OCA Specification for Operational Semantic Notice
- conformity assessment vectors for OCA schema's
- legal schema overlay from localized privacy law schema
- legal schema conformity assessment to ISO baseline
- legal schema overlay conformity assessment to a privacy law schema
- conformity assessment report on legal adequacy for privacy rigxzhts and associated infrormation controls
- conformity assessment vectors for OCA schema's
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 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, where this binding is public and legally required
- some jurisdictions, like the EU require an accountable data controller representative in the jurisdiction they are operating in, to address data privacy and security issues that may arise.
- 2 or more Controllers might be accountable for processing of personal data
- The privacy law in some jurisdictions, can itself break privacy law in other jurisdictions by requiring the accountable person information to be published publicly,
The proposed solution:
Develop this controller credential specification with a set of rules for the use, maintenance, and lifecycle of a privacy controller credential.
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).
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|
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]
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.
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
Background of this Stack
- 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' .
- 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 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)