Submission to the OPC’s Consultation on Consent under PIPEDA (Anonos)
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):Official Languages Act, the full document is only available in the language provided.
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