Re: Adding categories of data subjects

> On 2 Oct 2023, at 09:08, Delaram Golpayegani <delaram.golpayegani@adaptcentre.ie> wrote:
> 
> Active Data Subject: The data subjects who are aware of and have given consent to collection and processing of their data, e.g. an examinee sitting on an online exam proctored by an AI-based system.
> 
> Passive Data Subject: The data subjects who are not aware of collection and processing of their data, e.g. a passenger, passing the border control check, whose data is being processed for migration monitoring.

Support the addition. Going to be very useful.

"Not awareā€¯ may not fully cover the passiveness here. A passenger who has some knowledge about the border control (previous knowledge or reading a sign at the port) is aware of the collection.

From the example of online exam proctor and border control, one of the possible Active / Passive cutting points is probably whether during the data collection the data subject involve in the collection process directly. In the first example, the data subject can see the camera and knowingly that the camera is part of the exam process. They may also enter some personal data by themselves as well. Compare to the second example, where the data could be process well before the passenger enter the port (in case of an arranged travel that such the data is required by the regulation like air flight).

So I think the examples here will be more for Informed Data Subject and Uninformed Data Subject, as Harsh discussed the sense of #1 earlier.

Which would make us having six categories here? :
- Intended / Unintended
- Active / Passive
- Informed / Uninformed


Cheers,
Art

Received on Monday, 2 October 2023 11:35:26 UTC