Implementations Introduction This section describes how the normative elements of the COEL Specification can be configured to achieve a privacy-by-design implementation within an Ecosystem managed by a single IDA. It sets out principles of operation, controls the roles that actors can perform and gives detailed requirements of the responsibilities of actors. Principles Data Separation Principle (P1) The COEL Specification implements a separation of data types for specific roles and this principle extend this to the actors. Data Engines keep data on what Consumers do (COEL Behavioural Atoms) and the Operator keeps data on who Consumers are (DIPI). No single organisation holds both sets of data together. This means that it would need a double accidental or malicious disclosure for connected information to be released. Data Atomisation Principle (P2) Data is deliberately broken down into small chunks of information by the Operator and coded with the Consumer’s ConsumerID, thus each separate COEL Behavioural Atom has a very low privacy risk. Atomised Consent Principle (P3) Consumers give informed consent to the Operator or are provided appropriate notice the requirements set out in this section. This allows the Operator to sign up the Consumer with a ConsumerID. This ConsumerID is the indicator to Identity Authority and other Ecosystem actors that appropriate consent or notice is in place. The requirement for every COEL Behavioural Atom to have a ConsumerID (or associated DeviceID) in combination with the detailed consent fields, ensures each Atom has that Consumer’s consent / notice written into the structure of the data. The time stamp uniquely associated with each COEL Behavioural Atom allows full auditing of this principle. Separation of Competence Principle (P4) Data Engines are expert data handlers. They know how to run robust, secure and always on cloud based data services; they handle COEL Behavioural Atoms not Consumers. Service Providers are expert at manipulating behavioural data to deliver services and service content; they handle COEL Behavioural Atoms not Consumers. Operators are experts at Consumer facing services and handling DIPI; they handle Consumers not COEL Behavioural Atoms. The Identity Authority is expert at overseeing the Ecosystem. No Conflict of Interest Principle (P5) Consumers need to see that there are no conflicts around their data. To ensure this, the Identity Authority acts on behalf of the Consumer in partnership with Operator, Service Provider, Data Engine and regulators. Active Support Principle (P6) All actors will actively promote these principles, safeguard the structure of the Ecosystem and support good data practice for both individuals and enterprises.
Implementations Introduction This section describes how the normative elements of the COEL Specification can be configured to achieve a privacy-by-design implementation within an Ecosystem managed by a single IDA. It sets out principles of operation, controls the roles that actors can perform and gives detailed requirements of the responsibilities of actors. Principles Data Separation Principle (P1) The COEL Specification implements a separation of data types for specific roles and this principle extend this to the actors. Data Engines keep data on what Consumers do (COEL Behavioural Atoms) and the Operator keeps data on who Consumers are (DIPI). No single organisation holds both sets of data together. This means that it would need a double accidental or malicious disclosure for connected information to be released. Data Atomisation Principle (P2) Data is deliberately broken down into small chunks of information by the Operator and coded with the Consumer’s ConsumerID, thus each separate COEL Behavioural Atom has a very low privacy risk. Atomised Consent Principle (P3) Consumers give informed consent to the Operator or are provided appropriate notice the requirements set out in this section. This allows the Operator to sign up the Consumer with a ConsumerID. This ConsumerID is the indicator to Identity Authority and other Ecosystem actors that appropriate consent or notice is in place. The requirement for every COEL Behavioural Atom to have a ConsumerID (or associated DeviceID) in combination with the detailed consent fields, ensures each Atom has that Consumer’s consent / notice written into the structure of the data. The time stamp uniquely associated with each COEL Behavioural Atom allows full auditing of this principle. Separation of Competence Principle (P4) Data Engines are expert data handlers. They know how to run robust, secure and always on cloud based data services; they handle COEL Behavioural Atoms not Consumers. Service Providers are expert at manipulating behavioural data to deliver services and service content; they handle COEL Behavioural Atoms not Consumers. Operators are experts at Consumer facing services and handling DIPI; they handle Consumers not COEL Behavioural Atoms. The Identity Authority is expert at overseeing the Ecosystem. No Conflict of Interest Principle (P5) Consumers need to see that there are no conflicts around their data. To ensure this, the Identity Authority acts on behalf of the Consumer in partnership with Operator, Service Provider, Data Engine and regulators. Active Support Principle (P6) All actors will actively promote these principles, safeguard the structure of the Ecosystem and support good data practice for both individuals and enterprises.
COEL-v1.0-cs02.docx