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Submission to the OPC’s Consultation on Consent under PIPEDA (Anonos)


October 2016

Note: This submission was contributed by the author to the Office of the Privacy Commissioner of Canada’s Consultation on Consent under PIPEDA.

Disclaimer: The opinions expressed in this document are those of the author(s) and do not necessarily reflect those of the Office of the Privacy Commissioner of Canada.


We propose that next-generation Dynamic Data Obscurity (DDO)Footnote 1 principles (as elaborated upon in this Discussion Paper) be endorsed by the OPC as best practices for ensuring information accountability because these principles:

  • Maximize authorized and minimize unauthorized uses of data by dynamically minimizing re-identification risks.
  • Facilitate compliance with and auditability against data protection policies by enabling the mathematical, statistical and/or actuarial measurement and monitoring of data use.
  • Enable common data store(s) to programmatically support data protection and rights management policies applicable to different companies, industries, states, countries, regions, etc. – and to do so simultaneously.
  • Adjust in real-time to the changing requirements of policies by dynamically modifying the intelligible form of data into which dynamically obscured data are transformed.
  • Do not suffer from the disadvantages of broadly revealing or broadly concealing data, while providing significant advantages that neither broad revelation nor concealment offers with regard to precision and long-term (i.e., longitudinal) data value.

The full submission is available in the following language(s):

English (PDF document)

Note: As this submission was provided by an entity not subject to the Official Languages Act, the full document is only available in the language provided.
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