From 894f5ef836aba610585b1ed803c99e276a6de51d Mon Sep 17 00:00:00 2001 From: Joseph Abhayaratna Date: Mon, 26 Oct 2020 21:14:37 +1100 Subject: [PATCH] Making notes consistent with other notes sections in doc --- responsible-use/index.html | 42 ++++++++++++++++++++++++++++---------- 1 file changed, 31 insertions(+), 11 deletions(-) diff --git a/responsible-use/index.html b/responsible-use/index.html index eb8de7d3..10b1397b 100644 --- a/responsible-use/index.html +++ b/responsible-use/index.html @@ -356,7 +356,9 @@

Efficacy of Mobility Data

should be undertaken to prove the efficacy of the application before the application is introduced and geospatial data captured as a result.

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+ Extensive User testing required to prove underlying technology. +

There is context to efficacy of course, you might want to try a technique that is unproven if circumstances are severe, a global pandemic might be such an example? If so would it be acceptable to experiment first to @@ -372,7 +374,9 @@

Efficacy of Mobility Data

should only be collected for a particular use – so you would be prevented from using the data later for any other purpose.

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+ Data collection for specific purposes limited in coverage."> +

Related to the temporal aspect of such data collection of course is the spatial context, an application collecting information on the movements of a commuter in Paris should not collect data when the user is on @@ -396,7 +400,9 @@

Equibility

Access to services should not rely on access to expensive sophisticated devices, an alternative needs to be available for those without or unwilling to use smartphones for example.

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+ Solutions should be accessible to all members of society."> +

Access to technology may also vary for other societal or cultural differences and this may not be easily understood or unexpected, it there is an urgent need to build solutions based on ambient location, there @@ -427,7 +433,9 @@

Design Choices

These design principles are by no means comprehensive but a useful starting point.

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+ Location Data collection and or sharing should be voluntary. +

It should be clear the collection and sharing of location data are different things. There are many use cases that might require a user's location to be obtained, but that data does not need to be stored on @@ -439,8 +447,10 @@

Design Choices

purposes is not necessary for the operation of the service and you should be able to opt out of this form of collection if you wish.

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+ There should be an explicit mechanism to obtain user consent to the collect and then share Ambient Location + Information. +

Even if the collection and sharing of location data is not optional there should be an explicit notification and ongoing reaffirmation of the users agreement. This is important particularly if location sharing is a @@ -454,7 +464,9 @@

Design Choices

Again reinforcing the first principle collection and sharing are separate activities and should require separate user consent.

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+ The purpose of data collection and/or sharing must be explained. +

This is already a key foundation of most good data protection regulations, you need to explain clearly why you are collecting location information and how it will be used. @@ -465,7 +477,9 @@

Design Choices

you have visited before Apple, if they don’t state they will use the data for that purpose, they must not use it ! And to be clear they don’t !

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+ Data Collection/Sharing should be limited in scope. +

Again a key data protection principle is to only collect the minimum amount of data required, there is no allowable concept of “nice to have in case we need it”. @@ -483,7 +497,9 @@

Design Choices

injecting random noise into location data so that both the level of privacy and usefulness of the data is quantified and controlled.

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+ Data must be kept securely and by default anonymously. +

There needs to be a really, really good reason for Ambient Location information not to be anonymous. For most of the current popular applications where Ambient Location information is used to “sense” the world, @@ -507,7 +523,9 @@

Design Choices

Regardless of where Ambient Location data is stored it should be secure, encrypted both “At Rest” e.g. on the device or server but also “In transit” while moving across the network between device and server.

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+ Location data may be Personally Identifiable Information (PII)? +

The data that can be considered to be personally identifiable extends beyond the obvious name, address and telephone number and there are grey areas specifically with types of Geospatial Information. @@ -527,7 +545,9 @@

Design Choices

recognised, with metadata of when the image was acquired it is necessary for services such as Google Maps “Street View” and Apples “Look Around” to blur faces and car registration plates.

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+ Location data storage must be time & space limited. +

Is the collection of Ambient Location Information temporary and limited to a defined period of storage, and if not why not ? Again of course there may be applications where the user might want data to be stored