- From: Harshvardhan J. Pandit <me@harshp.com>
- Date: Fri, 24 Sep 2021 07:15:32 +0100
- To: public-dpvcg@w3.org
- Cc: David Hickey <david.hickey26@mail.dcu.ie>, Georg Philip Krog <georg@signatu.com>, Paul Ryan <paul.ryan76@mail.dcu.ie>
Hi. While wrapping up the DPV-GDPR concepts, I realised that we did not consider David's proposal for representing "Data Transfer Tool" in the vocabulary. Outlined here is my proposal on how we can do this. If you agree, I will include it and publish DPV-GDPR v0.3 over the weekend. If not, it goes on the agenda for the next meeting. DataTransferTool subclass of TechOrg Measure ; and containing the following subclasses: - AdHocContractualClauses (subclass of dpv:Contract) - BindingCorporateRules - CertificationMechanismsForDataTransfers (subclass of dpv:Certification) - CodesOfConductForDataTransfers (subclass of dpv:CodeOfConduct) - StandardContractualClauses (subclass of dpv:Contract) I've taken this list from EDPB recommendations on supplementary measures & data transfers 01/2020 https://edpb.europa.eu/sites/default/files/consultation/edpb_recommendations_202001_supplementarymeasurestransferstools_en.pdf If accepted, I propose these be included in a separate section within DPV-GDPR titled "Data Transfers". --- Additional Thoughts --- Tangentially, there is a strict relation between these concepts and A46 sub-clauses by design. For example, BCRs can only be used with dpv-gdpr:A46-2b as the legal basis. Is there interest and/or value in indicating this relation within DPV-GDPR? For example, as: BCR dpv:hasLegalBasis dpv-gdpr:A46-2b. This denotes an instance of BCR should be used with A46-2b as the legal basis (and does NOT intend to say that BCRs existence is justified in A46, which is actually in A47). In my head, I can envision different ways this can be useful. Such as ensuring the correct legal bases are used for a processing instance (via constraints), or helping suggest the correct legal bases (via discovering the relation between concepts and legal bases). Semantically, this can mess things up, because we're attaching a property to a class instead of an instance here, and we don't specify strictly how they are to be used - so another option is to have an additonal property to indicate suitable legal bases or to declare something like SHACL shapes to specify applicable legal bases. This shouldn't be done hastily, and we'd need to write examples/use-cases to make sure this is correct. So we will revisit how to add this at a later time. But meanwhile it'd be good to have people's opinions on this and start a conversation. --- end --- Regards, -- --- Harshvardhan J. Pandit, Ph.D Research Fellow ADAPT Centre, Trinity College Dublin https://harshp.com/
Received on Friday, 24 September 2021 06:15:48 UTC