- From: Dave Lewis <dave.lewis@adaptcentre.ie>
- Date: Tue, 11 Dec 2018 11:56:33 +0000
- To: public-dpvcg@w3.org
- Message-ID: <9e132caf-272b-1628-edc2-370b414b0c8d@adaptcentre.ie>
Hi Harsh, Guys This is a good start, a few initial questions and comments : 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 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. 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". 4) Several are stated in a way that I find difficult to equate to a clear purpose: "Current", "Downloads" 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? 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. Hope that's helpful, Dave On 10/12/2018 17:46, Harshvardhan J. Pandit wrote: > Dear All, > We (Axel, Javier, Elmar, Fajar, and Simon;) had a discussion today in > Vienna regarding Purpose Categories, and came up with some high-level > which are now in the wiki for discussion. > https://www.w3.org/community/dpvcg/wiki/Purposes_for_handling_Personal_Data#High-level_categories_.28to-be-discussed.29 > > > On 09/12/18 9:51 PM, Harshvardhan J. Pandit wrote: >> Hello all, >> We discussed in the Vienna F2F about high-level purposes or >> dimensions using examples from MyData. >> Following that, on the 4th, we looked at Purposes as defined in >> Consent Receipt >> https://kantarainitiative.org/confluence/display/infosharing/Appendix+CR+-+V.9.3+-+Example+Purpose+Categories >> >> TIt discusses things such as core functions (legitimate interest???), >> contracted service (contract???), contact requested (communication), >> personalisation, marketing, marketing by third parties. However, the >> last few purposes are very abstract as to their use and application. >> >> I like the distinction of categorising purposes at a high-level based >> on how they relate to the controller and the data subject (a point >> which Bud raised in the F2F) i.e. which of them are essential, which >> are legal, and which are complimentary, or which does the user have >> control over. >> This would be separate from any other categorisation, such as basaed >> on domain or service. >> There are examples of this being used in some privacy policies (in >> the wild, so to speak) as well. >> >> Regards, >
Received on Tuesday, 11 December 2018 14:05:05 UTC