IoT Guildford Meetup#26: GDPR, IoT and Transparency
1. Personal Data Receipts
Making Consent Work
August 31th
Mydata 2017, Helsinki
Michele Nati
Lead Technologist Personal Data and Trust
Digital Catapult, London
@michelenati
https://www.linkedin.com/in/michelenati/
2. The Personal Data Economy:
The opportunity
ā¢āÆ Personal Data is driving organizations digital
transformation (Source: DCMS)
241Ā£ (66Ā£ UK) billion growth between 2015-2020
11% increase in customers, 10% new opportuniAes
ā¢āÆ ā¦ with main sectors being digital health and digital
manufacturing
and beneļ¬ts for both businesses and consumers (due to more personalizaAon, prevenAon,
automaAon)
(Source: BCG) Digital Health esAmated growth: $54Bn -> $213Bn, $8Bn -> $112Bn
(Source: BCG) Digital Manufacturing esAmated growth: $1Bn -> $6Bn, $11Bn -> $52Bn
3. The Personal Data Economy:
The risks
ā¢āÆ But hidden business models and lack of
transparency are hindering this growth
(Source: MEF) 53% of consumers report lack of control on how their data are
used
(Source: Data ProtecAon Eurobarometer) Only 1 in 5 Consumers read privacy
statement: 2000 words long, 10 minutes avg reading Ame
(Source: MEF) 40% of mobile app users idenAfy lack of trust as cause to
abandon a service
ā¢āÆ Savvy consumers demands for
trustworthy apps (33%), with simple
privacy statements
5. GDPR:
Innovation opportunities
Trustworthiness
ReputaAon Trust
-āÆ Transparency
(Article 12-14,
Information notice)
-āÆ Accountability
(Article 4 and 7,
Consent)
-āÆ Level of Control
(Article 17-19, Data
erasure and
portability)
First step:
Transparency
Savvy consumers
demand
ā¢āÆ Simple privacy
statements
ā¢āÆ Clarity on collected
data and access to
them
ā¢āÆ Be6er user
experience
6. The Challenge
Problem Statement: How to increase consumersā trust and
businessesā transparency by developing a GDPR compliant soluAon
that takes into account the user experience and help to reduce
consumers pain points and organizaAons compliance burden related
to the provisioning of digital services using personal data?
Personal Data Receipts (PDRs), a human-readable record
summarizing in a simple and clear way what personal data an
organizaAon is collecAng about an individual, for what purpose, how
they are stored and for how long and if any third party sharing is
allowed.
7. Testing our hypothesis
ā¢āÆ Understanding consumers barriers and what transparency means for them (TaCs
pain points)
ā¢āÆ Mocking up of a receipt, interviews, user-centric design, prototyping, measuring
ā¢āÆ Findings: transparent, clear and concise summary of collected data, build trust
hdps://pdtn.org/designing-consent-receipts-future-personal-data-sharing/
8. ā¢āÆ PDRs are a super-set of consent receipt
ā¢āÆ First full transparency, then control
Digital Catapult PDRs
MulA-disciplinary team:
-āÆ UX Lead
-āÆ MarkeAng experts
-āÆ Lawyer
-āÆ Lead Tech
Beyond Consent:
According to DPA, consent is not
required for:
a)āÆ the ālegiAmate interestsā of the
data controller so long as they do
not override the fundamental
rights of the data subject;
b)āÆ data that it is necessary to collect
or process to fulļ¬ll a contract the
data subject asked to enter
Is there any privacy risk?
-āÆ For individuals?
-āÆ For businesses?
PIA and Privacy by Design performed
ā¢āÆ 4 weeks development/integraAon
ā¢āÆ Including data discovery phase
9. Digital Catapult PDRs
implementation
Some note about privacy:
ā¢āÆ No new personal informaAon is
created; nor passed and stored
across diļ¬erent systems
ā¢āÆ Secure meta-data communicaAon
ā¢āÆ Pseudonyms to link PDRs and users
ā¢āÆ PDRs only sent the ļ¬rst Ame, with
random delay, to avoid traceability
ā¢āÆ Audit trail: including PDR version
for maintain consistency (in case
of Privacy Policy change)
10. PDRs: the benefits
Individuals (Savvy consumers):
ā¢āÆ Privacy policies become human and simpliļ¬ed
ā¢āÆ Track and control on personal data sharing is simpliļ¬ed (and possible!!)
ā¢āÆ Reassurance that data will not end in the wrong hands is possible (3rd
party sharing highlighted)
Services and apps become more trustworthy and
more data are shared
Organizations:
ā¢āÆ Antude to personal data become user-centric
ā¢āÆ Open new personal comm channel with their uses
Consumers trust increases and churn is avoided,
while more data are accessed
11. GDPR compliance
ā¢āÆ Article 12-14, Information notice
ā¢āÆ Use of icons and simple text to explain: what, how and for what purpose
ā¢āÆ (could be extended to target diļ¬erent demographic groups)
ā¢āÆ Article 4 and 7, Consent
ā¢āÆ Provides a record for both individual and organizaAon
ā¢āÆ Includes data collected under consent
ā¢āÆ (currently only in human-readable format; could be extended with link to
consent management plaQorms)
ā¢āÆ Article 17-19, Data erasure and
portability
ā¢āÆ Provides link to contact Data Controller or to data management plaoorm
ā¢āÆ (could be extended with link to automaAcally trigger data erasure or
portability; but needs strong idenAty and idenAļ¬caAon, ArAcle 29 WP)
13. Implementing your PDR
ā¢āÆ Step 1 ā IdenAfy the target service
ā¢āÆ Step 2 ā Understand your service
ā¢āÆ Step 3 ā Make your process ready
ā¢āÆ Step 4 āthe User channel
ā¢āÆ Step 5 āthe PDRs generator
Final RecommendaAon (the PDR Team):
mulAdisciplinary, including UX experts
15. Use case:
patient data collection
BMS Backend
PDR
Hospital/Imaging
Centres
Visitor
BMS
website
Data Collected ā
ā Response
PostgreSQL
Booking Confirmation
NEW PDR
Application
Data Points for
PDR:
Email, Full Name,
DoB, Phone
Number, Address,
Post Code
Added possibility
to manage
individual rights
16. Future work
Future work:
ā¢āÆ AddiAonal use case: In store data collecAon ā DIY (discussion on going)
ā¢āÆ Machine readable format ā JSON and LD to standardize categories
ā¢āÆ More integraAon opAons, using our standard template
ā¢āÆ PDRs Trusted infrastructure
How to engage:
ā¢āÆ Adopt and integrate PDRs
ā¢āÆ Help to develop more implementaAon friendly tech