Re: Data Purposes

Hi Dave, thanks for the expansive comments. Replies are inline.

On 11/12/18 12:56 PM, Dave Lewis wrote:
> 1) Will you be aiming to provide definitions of these purposes in the 
> table? This will be critical to making reasoned decisions about 
> taxonomical relationship and in spotting non-taxonomical overlaps. A lot 
> of these terms would already have definitions out there that you may be 
> able to select from. Would it be worth considering the EU terminology 
> database for some of these, you can search that easily enough via 
> https://iate.europa.eu ? It would give the definitions an external 
> reference which may help acceptance, though often IATA has multiple 
> definition from different domains, so you need to be selective. Many 
> references here also have PURLs which helps with maintenance of the 
> purpose taxonomy
The terms/concepts were collected from existing vocabularies. So we 
would like to collect definitions from their documentation, yes.
IATE would be a good place to see how these terms are also defined, but 
I envision that they would not match because a lot of the terms are 
defined within the scope of their particular use-cases.
Regardless, for our taxonomy, we can take a look at IATE for definitions.

> 2) for taxonomy relationships, while clear definitions will help, you 
> might also consult the EU thesaurus (EURVoc) which would give you 
> perhaps a way of testing your reasoning against existing taxonomies: see 
> https://publications.europa.eu/en/web/eu-vocabularies/
> 
> I wouldn't say this is authoritative (its certainly not compelte), but 
> it might provide some useful perspectives, especially as it is grounded 
> in EU legal docs.
As far as I'm aware, EuroVoc provides hierarchical/structured taxonomy 
of concepts which cover a broad area. So it could be that a subset may 
be applicable. But I don't think these fall under any of the categories 
we are currently looking at. Then again, I may be wrong about this since 
I only looked at Eurovoc for EU legislations in the Datathon project.

> 3) a few specific comments on the table:
> 
>   * "Telemarketing" seems the same as: "Marketing by Phone"
>   * is there a difference between "OtherContact" and "AnyContact" -
>     either way it good to have these catch-all purposes, because they
>     are use a lot and should come in for special attention by future
>     tools using the taxonomy. Should "AuxPurpose" be in this branch
>     also? Perhaps also "Custom". Perhaps these should be under an
>     "InsufficientlyDefined" branch.
>   * I don't see how "Scientific Purpose" is a subclass of "marketing",
>     though perhaps it a subclass of "Research". The latter could also
>     cover 'market research' which might get complicated - I recall that
>     distinction wasn't enturiely clear in the text of GDPR perhaps.
>     Also, as my colleagues in the humanties often remind me, there are
>     many forms of academic research that are not scientific.
>   * is "Humanitarian" a subclass of "Charity"
>   * I'm not sure what the distinction of "Solo" analysis is compared to
>     analysis in general. Is it intended to be part of "profiling" or
>     "tailoring".
The classification clearly needs more work, and sometimes the depicted 
hierarchy reflects those specified by the source ontology.
Regardless, moving forward, we would be looking to resolve both these 
issues.

> 4) Several are stated in a way that I find difficult to equate to a 
> clear purpose:  "Current", "Downloads"
Agreed, same as above.

> 5) There are others that perhaps need to be rephrased to better evoke 
> the purpose as they are sort of dangling predicates. You've done a good 
> job of addressing this for the concepts as phrased in the high level 
> taxonomy already. So similar detailing is needed here, especially in 
> relation to the role of data subject, controller and third parties - as 
> the purpose is often different depending on the role configuration:
> 
> "Arts" performed by who, for the appreciation of whom?
> 
> "Browsing" by whom?
> 
> "Communication" between who?
> 
> "Delivery" by who to whom?
> 
> "Develop" of what, by who, for whom?
> 
> "Feedback" between who?
Agreed, purpose text/title needs to be declarative of what it is aiming 
towards. Something to keep in mind for our taxonomy.

> 6) There are another set of purposes that seem to be sectional in 
> nature, i.e. "Charity", "Education", Gaming"/"Gambling", "Government", 
> "Health", "Historical", "Journalistic", "Judicial", "Public Interest", 
> "Research", "State", "Statistics". Is the intention here to have 
> specific branches of the taxonomy that fall neatly into purposes 
> identified in GDPR for specific purposes? In which case should they be 
> taxonomised as such? I see similar issues in the high level taxonomy 
> where "non-commercial" and "academic" research and grouped under 
> "research and development" with "commercial research", which could 
> presumably include market research.
> 
> However in GDPR, these are significant distinctions, so the design 
> question arises whether these distinctions should be branched nearer the 
> root of the taxonomy, where it may be more immediately obvious for 
> answering GDPR related competence questions.
There's another set of terms at the bottom of the page in a different 
section resulting from the discussion yesterday (there's an email about 
that in the thread) which reflects the more top-level distinction and I 
think answers this as well.

P.S. Rushed replies since it is time for DPVCG meeting call.

Regards,

-- 
-- 
---
Harshvardhan J. Pandit
PhD Researcher
ADAPT Centre, Trinity College Dublin
https://harshp.com/

Received on Tuesday, 11 December 2018 14:58:12 UTC