Privacy by Design: Big Privacy for Big Data

2013 Digital Odyssey: Big Data, Small WorldOntario Library IT Association

Toronto, CanadaJune 7, 2013

Overview• Introduction to IPC• Privacy 101• Challenges to Privacy in the Age

of Big Data• Privacy by Design• Big Privacy for Big Data

Ann Cavoukian, PhDOntario’s Information and Privacy Commissioner

• Ensure that government organizations (provincial and municipal) comply with freedom of information and privacy laws in Ontario

• Investigate privacy complaints and resolve appeals when the government refuses to grant access to government-held information

• Conduct research on and raise awareness of emerging privacy & access to information issues

IPC Philosophy: 3 C’s

• Consultation: by keeping open lines of communication

• Co-operation: rather than confrontation in resolving complaints

• Collaboration: through working together to find solutions

• Information privacy refers to the right or ability of individuals to exercise control over the collection, use and disclosure by others of their personal information

• Personally-identifiable information (“PII”) can be biographical, biological, genealogical, historical, transactional, locational, relational, computational, vocational or reputational, and is the stuff that makes up our modern identity

Personal information must be managed responsibly. When it is not, accountability is undermined and confidence in our evolving information society is eroded.

Privacy 101

From PC to Web 4.0: Challenges to Privacy in the Age of Big Data

Radar Networks & Nova Spivack, 2007

Wireless and Mobile: Beware of Unintended Consequences

Source: www.sciencedaily.com/releases/2013/03/130327132547.htm

“We need to be more deliberate (about privacy). A lot of information-age architecture is about data: what is collected, who controls it, and how it is used. Data is the lifeblood of the information age, but much of it is very personal. We need to design systems that limit unnecessary data collection, give individuals control over their data, and limit the ability of those in power to use that data for mass surveillance.”

(Bruce Schneier, IEEE Security & Privacy January/February 2009 )

Data Assets = Data Risks and Liabilities

Threats to Privacy

Data Privacy requires Good Data Security

but

Good Data Security ≠ Privacy

Why We Need Privacy by DesignMost privacy breaches remain undetected – as regulators, we only see the tip of the iceberg

The majority of privacy breaches remain unchallenged, unregulated ... unknown

Regulatory compliance alone, is unsustainable as the sole model for ensuring the future of

privacy

Privacy by Design:The 7 Foundational Principles

1. Proactive not Reactive: Preventative, not Remedial

2. Privacy as the Default3. Privacy Embedded into

Design

4. Full Functionality: Positive-Sum, not Zero-Sum

5. End-to-End Security: Full Lifecycle Protection

6. Visibility and Transparency: Keep it Open

7. Respect for User Privacy: Keep it User-Centric

Security End to End Lifecycle Protection

Purpose SpecificationData Minimization

Privacy as the Default (Setting)

Consent, Accuracy, Access Respect for User Privacy

Accountability, Openness, Compliance

Openness & Transparency

Proactive Not Reaction; Preventative Not Remedial

Privacy Embedded into Design

Full Functionality – Positive-Sum, not Zero-Sum

Privacy by Design

FIPPs

Privacy by Design

InformationTechnology

AccountableBusinessPractices

PhysicalDesign &

Infrastructure

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De-identification – Data Minimization

• Restoring the value of de-identification;

• Challenges in re-identifying de-identified information;

• The implications of including de-identified information under privacy legislation;

• Rejecting the zero-sum paradigm;

• Conducting re-identification risk assessment.

Data Co-management

• Data accountability• Data minimization• Data security• Data access

In the Web 2.0 era, information may very well “want to be free” but not necessarily personal information!

The Big Idea: Data co-management – Citizen participation in the care and management of his/her own personal data held by others throughout the data life cycle

PERSONAL DATA ECOSYSTEM (PERSONAL DATA VAULT/PERSONAL DATA PLATFORM)

UI Design Concepts: Transparency & Trust

• Context – think of the device as well as the context for how the information will be treated

• Awareness – does the user know that privacy policies exist and that they can exercise choice

• Discoverability – ease of finding relevant privacy policies & ease of acting on available privacy settings

• Comprehension - consider if users can understand the privacy policies & privacy settings to be able to make an informed decision

Privacy by Design in the Age of Big Data and Sensemaking Systems

• Ability of analytical tools to process & make sense of extremely large sets of structured and unstructured data

• New class of analytic capability where the data finds the data and the relevance finds the user– Increase in accuracy of data – context

reduces ambiguity– Accumulation of bad data = smarter

system– As data store increases, context is

enhanced = faster results• Requires Big Privacy!

PbD Features for Next-generation Sensemaking Systems

1. Full attribution: preserve record metadata; do not allow merge/purge processing

2. Data tethering: any changes to records must apply across the information sharing ecosystem in real-time

3. Analytics on anonymized data: anonymize data at source prior to transfer; utilize homomorphic encryption

4. Tamper-resistant audit logs: every user search logged, even database administrator

5. False negative favoring methods: trust but verify

6. Self-correcting false positives: reverse earlier assertions real-time and scaled

7. Information transfer accounting: capture data flows for discovery by individual

“Your identity is your most valuable possession.

Protect it. And if anything goes wrong, use your

powers.”

Helen (aka Elastigirl)The IncrediblesDisney/Pixar 2004

Patience, Persistence and Faith: The Chronicles of a Crusader

Privacy by Design NOT Privacy by Disaster!

How to Contact Us

Michelle Chibba, Director, Policy and Special ProjectsMichelle Chibba, Director, Policy and Special ProjectsInformation and Privacy Commissioner’s Office of Ontario2 Bloor Street East, Suite 1400Toronto, Ontario, CanadaM4W 1A8

Phone: (416) 326-3333 / 1-800-387-0073Web: www.ipc.on.caE-mail: info@ipc.on.ca