DATA PROTECTION IMPACT ASSESSMENT

Transcription

1 DATA PROTECTION IMPACT ASSESSMENT Tool to support implementation of DPIA Ewa Piatkowska Centre for Digital Safety and Security AIT Austrian Institute of Technology

2 PRIVACY AND SMART GRID Large quantities of sensing data collected, processed and retained by smart grid stakeholders Demand response and flexibility services require high frequency data readings for profiling and forecasting Applications for energy consumption monitoring and analysis Smart Grid data reveal personal details about one s behaviour at home M. Weiss, A. Helfenstein, F. Mattern and T. Staake, "Leveraging smart 2 meter data to recognize home appliances," 2012 IEEE International Conference on Pervasive Computing and Communications, Lugano, 2012, pp

3 POTENTIAL PRIVACY IMPACTS Identity Theft Determine Personal Behavior Patterns Determine Specific Appliances Used Perform Real- Time Surveillance Fraud Profiling Targeted advertisement Law enforcement access Targeted home invasions Tracking Behavior Of Renters/Leasers 3

4 GENERAL DATA PROTECTION REGULATION (GDPR) In April 2016, the General Data Protection Regulation (GDPR) was adopted by the Council of the European Union and European Parliament, replacing Directive 95/46/EC The regulation ensures that personal data can be gathered under strict conditions, with data subject consent and only for legitimate purposes It is mandated that new services that collect or process personal data are subjected to a Data Protection Impact Assessment (DPIA) GDPR provisions will be directly applicable in all Member States from 25 May

5 DATA PROTECTION IMPACT ASSESSMENT (DPIA) TEMPLATE Template proposed by Smart Grid Task Force , Expert Group 2, in consultation with Article 29 Working Party Risk driven approach to privacy impact assessment Considered as complementary or included in a risk management process Most recent available version from March 2014 Final version, addressing the feedback from review process expected to be released March/April

6 DATA PROTECTION IMPACT ASSESSMENT PROCESS What data is being collected and how is it processed? What are the risks to rights and freedom of data subjects? What are the measures, privacy targets and controls to ensure privacy? Step 1 Pre-assessment Step 2 Initiation Step 3 Smart Grid system description Step 4 Identification of relevant risks Step 5 Data protection risk assessment Step 6 Controls and residual risks Step 7 Documentation and reporting Step 8 Review and maintenance 6

7 TOOL SUPPORTING DPIA IMPLEMENTATION 7

8 SYSTEM DESCRIPTION 8

9 LIKELIHOOD ASSESSMENT 9

10 IMPACT ASSESSMENT 10

11 RISK TREATMENT 11

12 PRIVACY TARGETS IMPLEMENTATION 12

13 FEATURES OF THE DPIA TOOL Direct support for distributed team working Guidance about how to implement each step embedded directly in the tool Hints about the nature of the required input (catalogues, tooltips) Pre-selected relevant content to support analyses The automatic generation of documentation 13

14 CONCLUSIONS Tool provides user-friendly interface and makes the implementation of the DPIA more straightforward, and therefore requiring less effort. Our future work include further improvements of the tool and process as well, addressing feedback received during a series of DPIA workshops that we have conducted. Moreover, we are also planning to align the tool with the newest version of the DPIA template expected to be released by the end of March

15 THANK YOU! Ewa Piatkowska