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. | StatusACTIVE |
Data Governance: Data subject’s (data) rights
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
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indicate that (when data processing is based on consent), data subjects have the right to erasure when consent has been withdrawn and the rights to restriction, rectification and access.
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)
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.
(Note: In progress - consulting with Steven on auto filling)
Data Governance Authority / | |||
---|---|---|---|
Certification Providers on Regulator Approved Codes of Conduct - very limited PII - data controller personal information and a linked reference to a data subjects identifier - |
Privacy Stakeholders | ISO Definition | |
---|---|---|
Regulator / | ||
PII Principal | ||
PII Controller | ||
PII Processor | ||
3rd Party |
Roles for Credentials | Description | |
---|---|---|
Issuer | ||
Holder | ||
Verifier |
Gov ToiP Role | UseCase Example | Roles | Actors Privacy Stakeholders
| |
---|---|---|---|---|
Provides the schema - hospital | issuer | Privacy Controller | ||
Person - Requesting Information from - patient/traveller | holder | Data Subject | ||
3rd Party - border control | Verifier | Data Processor / 3rd Party |
Legal Semantic Element | semantic description | functional usage | fields Required | |
---|---|---|---|---|
controller | ||||
controller_identity | ||||
controller address registered | ||||
controller address (mailing) | ||||
controller contact | extend consent termination for a control point |
Delegated Role :
Delegated | |||
---|---|---|---|
Regulator | Ombudsman | ||
PII Principal | Guardian | ||
PII Controller | Joint-Controller | ||
PII Processor | Sub-Processor | ||
3rd Party | turtles |
Standard/Specifications | Title | Description | Resource Status |
---|---|---|---|
ISO 29100 | 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 |
|
|
Topic Title | ||
---|---|---|
Risks | ||
Mapping Governance | Matching with ToiP Governance | |
Topic | Link | |
---|---|---|
Risks | Identity and Verifiable Credential Risks | |
Implementer | |||
---|---|---|---|
Human Colossus | |||
OpenConsent | |||
I_Grant |
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]
Field Name | Field Label | Format | Description | Required/Optional |
Schema Version | version | string | Required | |
OPN Privacy Profile URI | profile | string | Link to the controller's profile in the OPN registry. | Required |
Type of Notice Receipt | Notice Receipt | string | Label Notice Receipt | Required |
Receipt ID | id | string | A unique number for each Notice Receipt. SHOULD use UUID-4 [RFC 4122]. | Required |
Timestamp | timestamp | 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). | Required |
Signing Key | key | string | The Controller’s profile public key. Used to sign notice icons, receipts and policies for higher assurance. | Optional |
Language | language | string | Language in which the consent was obtained. MUST use ISO 639-1:2002 [ISO 639] if this field is used. Default is 'EN'. | Optional |
Controller Identity | controllerID | string | The identity (legal name) of the controller. | Required |
Legal Jurisdiction | jurisdiction | string | The jurisdiction(s) applicable to this notice | Required |
Controller Contact | controllerContact | string | Contact name of the Controller. Contact could be a telephone number or an email address or a twitter handle. | Required |
Link to Notice | notice | string | Link to the notice the receipt is for | Optional |
Link to Policy | policy | string | Link to the policies relevant to this notice e.g. privacy policy active at the time notice was provided | Required |
Context | context | string | Method of notice presentation, sign, website pop-up etc | Optional |
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