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 
> ? 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 
> 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 

> 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.


Harshvardhan J. Pandit
PhD Researcher
ADAPT Centre, Trinity College Dublin

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