Some links I thought worth reading the past few days

To celebrate the launch of the GDPR last week Friday, Jaap-Henk Hoekman released his ‘little blue book’ (pdf)’ on Privacy Design Strategies (with a CC-BY-NC license). Hoekman is an associate professor with the Digital Security group of the ICS department at the Radboud University.

I heard him speak a few months ago at a Tech Solidarity meet-up, and enjoyed his insights and pragmatic approaches (PDF slides here).

Data protection by design (together with a ‘state of the art’ requirement) forms the forward looking part of the GDPR where the minimum requirements are always evolving. The GDPR is designed to have a rising floor that way.
The little blue book has an easy to understand outline, which cuts up doing privacy by design into 8 strategies, each accompanied by a number of tactics, that can all be used in parallel.

Those 8 strategies (shown in the image above) are divided into 2 groups, data oriented strategies and process oriented strategies.

Data oriented strategies:
Minimise (tactics: Select, Exclude, Strip, Destroy)
Separate (tactics: Isolate, Distribute)
Abstract (tactics: Summarise, Group, Perturb)
Hide (tactics: Restrict, Obfuscate, Dissociate, Mix)

Process oriented strategies:
Inform (tactics: Supply, Explain, Notify)
Control (tactics: Consent, Choose, Update, Retract)
Enforce (tactics: Create, Maintain, Uphold)
Demonstrate (tactics: Record, Audit, Report)

All come with examples and the final chapters provide suggestions how to apply them in an organisation.

At least I think it is…. Personal blogs don’t need to comply with the new European personal data protection regulations (already in force but enforceable from next week May 25th), says Article 2.2.c. However my blog does have a link with my professional activities, as I blog here about professional interests. One of those interests is data protection (the more you’re active in transparency and open data, the more you also start caring about data protection).

In the past few weeks Frank Meeuwsen has been writing about how to get his blog GDPR compliant (GDPR and the IndieWeb 1, 2 and 3, all in Dutch), and Peter Rukavina has been following suit. Like yours, my e-mail inbox is overflowing with GDPR related messages and requests from all the various web services and mailing lists I’m using. I had been thinking about adding a GDPR statement to this blog, but clearly needed a final nudge.

That nudge came this morning as I updated the Jetpack plugin of my WordPress blog. WordPress is the software I use to create this website, and Jetpack is a module for it, made by the same company that makes WordPress itself, Automattic. After the update, I got a pop-up stating that in my settings a new option now exists called “Privacy Policy”, which comes with a guide and suggested texts to be GDPR compliant. I was pleasantly surprised by this step by Automattic.

So I used that to write a data protection policy for this site. It is rather trivial in the sense that this website doesn’t do much, yet it is also surprisingly complicated as there are many different potential rabbit holes to go down. As it concerns not just comments or webmentions but also server logs my web hoster makes, statistics tools (some of which I don’t use but cannot switch off either), third party plugins for WordPress, embedded material from data hungry platforms like Youtube etc. I have a relatively bare bones blog (over the years I made it ever more minimalistic, stripping out things like sharing buttons most recently), and still as I’m asking myself questions that normally only legal departments would ask themselves, there are many aspects to consider. That is of course the whole point, that we ask these types of questions more often, not just of ourselves, but of every service provider we engage with.

The resulting Data Protection Policy is now available from the menu above.

Funny how #datagovernance companies publishing #gdpr compliance guides aren’t compliant themselves when asking personal data for downloads: no explicit opt-ins, hidden opt-ins (such as hitting download also subscribes you to their newsletter), no specific explanations on what data will be used how, asking more personal information than necessary.

Yesterday my colleague Paul and I visited the annual conference organized by the Flemish government’s information management / IT office. We were there to speak about the open data experiences of the Netherlands.

The upcoming GDPR, Europe’s new privacy regulations, was mentioned and discussed a lot. Such pan-European laws suggest that there is a generic way to approach a topic like privacy, or even an objective one. Nonetheless the actual perception of privacy is strongly culturally determined as well, Toon van Agt remarked during his presentation, and pointing to us Dutchies sitting on the front row. He gave the example of how in the Netherlands real estate transaction prices and mortgages on a house are publicly available (if not yet as open data I must add. Transaction prices are available as open data in the UK, afaik). Where in the Netherlands this is regarded as necessary to be able to determine who you’re dealing with if you buy or sell a house, in Belgium it would be unthinkable. In my own presentation I showed how open data from the license plate register is used in the Netherlands to prevent theft of petrol at gas stations. Again unthinkable in Belgium, mostly because of the fundamental difference that license plates in the Netherlands are connected to a car (and the car to an owner), and in Belgium to the car owner (and the owner to a car). Calvinism was put forward as a determining difference, resulting in Dutch window curtains being open, so everyone can see a) we have nothing to hide and/or b) we have the coolest stuff in the street :). Similarly the tax amounts and incomes of Norwegians are famously public, whereas in the Netherlands asking how much someone earns or even worse touting how much you earn yourself, is frowned upon and not suitable for polite conversation.

It would be interesting to create an overview of socially acceptable and unacceptable forms of transparency across Europe. To learn where further opportunities for open data are to be found, as well as to see where social barriers can be expected.

The wonderful windows open houses on the Dutch( Volendam) 4 2017-09-23_15-15-25_ILCE-6500_DSC03304
The quintessential difference between Belgium (r) and the Netherlands (l): curtains open or closed. Photos by Miguel Discart and magalibobois