W3C

– DRAFT –
DPVCG Meeting Call

23 MAR 2022

Attendees

Present
:, beatriz, fajar, georg, harsh, julian
Regrets
paul
Chair
harsh
Scribe
harsh

Meeting minutes

Previous Meeting Minutes

Proposed concepts

hasResponsibleEntity to indicate which entity is responsible for something e.g. controller in joint-controllers, or department in organisation

Concept accepted `hasResponsibleEntity` under Entities module

Concept `InternationalOrganisation` as defined in GDPR A.4-26

Also define elsewhere (outside-EU) e.g. https://en.wikipedia.org/wiki/International_organization

Concept accepted `InternationalOrganisation` as type of Organisation in Entities module

Consequences and Impacts

Prior discussion recorded in previous minutes

Also see email https://lists.w3.org/Archives/Public/public-dpvcg/2022Mar/0006.html

Discussion on conceptual differences between _consequence_ and _impact_

Consequence and Impact are relevant for PIA, DPIA, ROPA, Transfer impact assessment, Tech/Org measure effectiveness, Privacy Notice, Risk assessment

Discussion conclusions and summaries recorded as below.

Consequence is a general concept, represents outcome of something (e.g. event, process, action)

Impact is a specific type of consequence (so subset or subcategory of Consequence) that has a stronger notion used to identify consequence to some entity or thing.

For example, Consequence when used can have 'weak' impact that is not explicitly acknowledged as such e.g. slower processing, inability to log in.

Impact, as a stronger concept of consequence, is used to explicitly identify effects on entity e.g. to a person using a service

We need clear descriptions and examples that state this.

Where to use what concept depends on the context e.g. impact assessments (by name) talk about impacts, risk assessments talk about both impact and consequence

An entity (e.g. data controller or individual) may distinguish between consequence and impact as well e.g. impact on me vs consequence on others or vice-versa

GDPR mentions both consequence (e.g. A.13) and impacts (e.g. A.35) - however in both cases the implication could be on negative consequences and impacts

At the same time, there are also positive concepts e.g. benefit of a service

To conclude - concept `Impact` as a category of `Consequence`, with property `hasImpact` linking it to a concept causing the impact, and property `hasImpactOn` linking it to what is impacted.

The property `hasConsequenceOn` is put on hold as proposed until we have clarity in terms of how it is differentiated from `hasImpactOn`, and what consequences have effect that are not impacts (not philosophically, but in the sense that they are not documented as such)

`Impact` has further categories `Benefit`, and `Detriment` with further categories `Harm` (needs discussion on how it relates to Damage)

Path for DPV v1

Relevant sets of concepts deemed necessary for v1 - DPIA, data breach, risk, ROPA, consent, privacy policy/notice (contents), relation of ISO/IEC standards to tech/org measures

In this, privacy notice concepts are in DPV except the notion of app, service, product, etc. - which should be provided by the tech extension

DPIA concepts will be proposed by Harsh, Rana, Georg in April

Data Breach concepts include breach types (e.g. hacking), notifications, records, etc. - proposals welcome

Risk concepts - e.g. likelihood, qualitative risk levels, etc. - Harsh will propose based on existing work e.g. https://github.com/coolharsh55/riskonto

ROPA - all concepts present, some additionally proposed by Harsh, Paul, Rob in April

Consent - proposal by Harsh in April based on state in ISO/IEC 27560 (to avoid conflict/mismatch). See https://doi.org/10.5281/zenodo.5076603 for prior proposal.

For rest, proposals welcome

Next Meeting

We will meet next WED MAR-30 14:00 CEST (note daylight saving changes)

Discussion to include comments on consenquence & impact (if any)

Other concepts include tech extension (data storage, apps, services, etc.) and data subject categories

Minutes manually created (not a transcript), formatted by scribe.perl version 185 (Thu Dec 2 18:51:55 2021 UTC).