3,501 Matching Annotations
  1. May 2020
    1. If you’re switching from another cookie management solution to ours, you may want to migrate the consents you’ve already collected. This is useful for ensuring that users who have already given their consent under the previous solution are not presented with the cookie banner, and the related request for consent, again.
    1. “If you are a non-college graduate man you have a less than 50/50 shot of ever being married in your life” – Andrew YangIn the 1970s and ‘80s, there were about 17 million manufacturing jobs in the USToday, there are about 12 million of those jobsMore women are graduating from college than men58% of college graduates in the US are women
    1. Hartman, T. K., Stocks, T. V. A., McKay, R., Gibson Miller, J., Levita, L., Martinez, A. P., Mason, L., McBride, O., Murphy, J., Shevlin, M., bennett, kate m, & Bentall, R. (2020). The Authoritarian Dynamic During the COVID-19 Pandemic: Effects on Nationalism and Anti-Immigrant Sentiment [Preprint]. PsyArXiv. https://doi.org/10.31234/osf.io/4tcv5

    1. Sure, anti-spam measures such as a CAPTCHA would certainly fall under "legitimate interests". But would targeting cookies? The gotcha with reCAPTCHA is that this legitimate-interest, quite-necessary-in-today's-world feature is inextricably bundled with unwanted and unrelated Google targeting (cookiepedia.co.uk/cookies/NID) cookies (_ga, _gid for v2; NID for v3).
    1. Google encouraging site admins to put reCaptcha all over their sites, and then sharing the resulting risk scores with those admins is great for security, Perona thinks, because he says it “gives site owners more control and visibility over what’s going on” with potential scammer and bot attacks, and the system will give admins more accurate scores than if reCaptcha is only using data from a single webpage to analyze user behavior. But there’s the trade-off. “It makes sense and makes it more user-friendly, but it also gives Google more data,”
    1. there’s no need to send consent request emails — provided that this basis of processing was stated in your privacy policy and that users had easy access to the notice prior to you processing their data. If this information was not available to users at the time, but one of these legal bases can currently legitimately apply to your situation, then your best bet would be to ensure that your current privacy notice meets requirements, so that you can continue to process your user data in a legally compliant way.
    1. In the absence of an adequacy decision pursuant to Article 45(3), or of appropriate safeguards pursuant to Article 46, including binding corporate rules, a transfer or a set of transfers of personal data to a third country or an international organisation shall take place only on one of the following conditions:

      These conditions are individually sufficient and jointly necessary (https://hyp.is/e0RRFJCfEeqwuR_MillmPA/en.wikipedia.org/wiki/Necessity_and_sufficiency).

      Each of the conditions listed is a sufficient (but, by itself, not necessary) condition for legal transfer (T) of personal data to a third country or an international organisation. In other words, if any of those conditions is true, then legal transfer is also true.

      On the other hand, the list of conditions (C; let C be the disjunction of the conditions a-g: a or b or c ...) are jointly necessary for legal transfer (T) to be true. That is:

      • T cannot be true unless C (one of a or b or c ...) is true
      • if C is false (there is not one of a or b or c ... that is true), then T is false
      • T ⇒ C
      • C ⇐ T
    1. With that guidance in mind, and from a practical standpoint, consider keeping records of the following: The name or other identifier of the data subject that consented; The dated document, a timestamp, or note of when an oral consent was made; The version of the consent request and privacy policy existing at the time of the consent; and, The document or data capture form by which the data subject submitted his or her data.
    1. “Until CR 1.0 there was no effective privacy standard or requirement for recording consent in a common format and providing people with a receipt they can reuse for data rights.  Individuals could not track their consents or monitor how their information was processed or know who to hold accountable in the event of a breach of their privacy,” said Colin Wallis, executive director, Kantara Initiative.  “CR 1.0 changes the game.  A consent receipt promises to put the power back into the hands of the individual and, together with its supporting API — the consent receipt generator — is an innovative mechanism for businesses to comply with upcoming GDPR requirements.  For the first time individuals and organizations will be able to maintain and manage permissions for personal data.”
    1. generic-sounding term may be interpreted as something more specific than intended: I want to be able to use "data interchange" in the most general sense. But if people interpret it to mean this specific standard/protocol/whatever, I may be misunderstood.

      The definition given here

      is the concept of businesses electronically communicating information that was traditionally communicated on paper, such as purchase orders and invoices.

      limits it to things that were previously communicated on paper. But what about things for which paper was never used, like the interchange of consent and consent receipts for GDPR/privacy law compliance, etc.?

      The term should be allowed to be used just as well for newer technologies/processes that had no previous roots in paper technologies.

    1. It’s useful to remember that under GDPR regulations consent is not the ONLY reason that an organization can process user data; it is only one of the “Lawful Bases”, therefore companies can apply other lawful (within the scope of GDPR) bases for data processing activity. However, there will always be data processing activities where consent is the only or best option.
    1. If you’re a controller based outside of the EU, you’re transferring personal data outside of the EU each time you collect data of users based within the EU. Please make sure you do so according to one of the legal bases for transfer.

      Here they equate collection of personal data with transfer of personal data. But this is not very intuitive: I usually think of collection of data and transfer of data as rather different activities. It would be if we collected the data on a server in EU and then transferred all that data (via some internal process) to a server in US.

      But I guess when you collect the data over the Internet from a user in a different country, the data is technically being transferred directly to your server in the US. But who is doing the transfer? I would argue that it is not me who is transferring it; it is the user who transmitted/sent the data to my app. I'm collecting it from them, but not transferring it. Collecting seems like more of a passive activity, while transfer seems like a more active activity (maybe not if it's all automated).

      So if these terms are equivalent, then they should replace all instances of "transfer" with "collect". That would make it much clearer and harder to mistakenly assume this doesn't apply to oneself. Or if there is a nuanced difference between the two activities, then the differences should be explained, such as examples of when collection may occur without transfer occurring.

    1. Full and extensive records of processing are expressly required in cases where your data processing activities are not occasional, where they could result in a risk to the rights and freedoms of others, where they involve the handling of “special categories of data” or where your organization has more than 250 employees — this effectively covers almost all data controllers and processors.
    1. it buys, receives, sells, or shares the personal information of 50,000 or more consumers annually for the business’ commercial purposes. Since IP addresses fall under what is considered personal data — and “commercial purposes” simply means to advance commercial or economic interests — it is likely that any website with at least 50k unique visits per year from California falls within this scope.
    1. You must disclose how the add-on collects, uses, stores and shares user data in the privacy policy field on AMO. Mozilla expects that the add-on limits data collection whenever possible, in keeping with Mozilla’s Lean Data Practices and Mozilla’s Data Privacy Principles, and uses the data only for the purpose for which it was originally collected.
  2. Apr 2020
    1. Finally, from a practical point of view, we suggest the adoption of "privacy label," food-like notices, that provide the required information in an easily understandable manner, making the privacy policies easier to read. Through standard symbols, colors and feedbacks — including yes/no statements, where applicable — critical and specific scenarios are identified. For example, whether or not the organization actually shares the information, under what specific circumstances this occurs, and whether individuals can oppose the share of their personal data. This would allow some kind of standardized information. Some of the key points could include the information collected and the purposes of its collection, such as marketing, international transfers or profiling, contact details of the data controller, and distinct differences between organizations’ privacy practices, and to identify privacy-invasive practices.
    2. organizations may require consent from individuals where the processing of personal data is likely to result in a risk or high risk to the rights and freedoms of individuals or in the case of automated individual decision-making and profiling. Formal consent could as well be justified where the processing requires sharing of personal data with third parties, international data transfers, or where the organization processes special categories of personal data or personal data from minors.
    1. RPO limits how far to roll back in time, and defines the maximum allowable amount of lost data measured in time from a failure occurrence to the last valid backup. RTO is related to downtime and represents how long it takes to restore from the incident until normal operations are available to users

      RPO RTO

    1. Before we get to passwords, surely you already have in mind that Google knows everything about you. It knows what websites you’ve visited, it knows where you’ve been in the real world thanks to Android and Google Maps, it knows who your friends are thanks to Google Photos. All of that information is readily available if you log in to your Google account. You already have good reason to treat the password for your Google account as if it’s a state secret.
    1. Alas, you'll have to manually visit each site in turn and figure out how to actually delete your account. For help, turn to JustDelete.me, which provides direct links to the cancellation pages of hundreds of services.
    1. When you visit a website, you are allowing that site to access a lot of information about your computer's configuration. Combined, this information can create a kind of fingerprint — a signature that could be used to identify you and your computer. Some companies use this technology to try to identify individual computers.
    1. Our approach strikes a balance between privacy, computation overhead, and network latency. While single-party private information retrieval (PIR) and 1-out-of-N oblivious transfer solve some of our requirements, the communication overhead involved for a database of over 4 billion records is presently intractable. Alternatively, k-party PIR and hardware enclaves present efficient alternatives, but they require user trust in schemes that are not widely deployed yet in practice. For k-party PIR, there is a risk of collusion; for enclaves, there is a risk of hardware vulnerabilities and side-channels.
    2. Privacy is at the heart of our design: Your usernames and passwords are incredibly sensitive. We designed Password Checkup with privacy-preserving technologies to never reveal this personal information to Google. We also designed Password Checkup to prevent an attacker from abusing Password Checkup to reveal unsafe usernames and passwords. Finally, all statistics reported by the extension are anonymous. These metrics include the number of lookups that surface an unsafe credential, whether an alert leads to a password change, and the web domain involved for improving site compatibility.
    1. About InfluenceMap InfluenceMap empowers investors, corporations, the media and campaigners with data-driven and clearly communicated analysis on critical issues associated with climate change and the energy transition. Our flagship platform is the world's leading analysis of how companies and trade associations impact climate-motivated policy globally.
    1. Verity, R., Okell, L. C., Dorigatti, I., Winskill, P., Whittaker, C., Imai, N., Cuomo-Dannenburg, G., Thompson, H., Walker, P. G. T., Fu, H., Dighe, A., Griffin, J. T., Baguelin, M., Bhatia, S., Boonyasiri, A., Cori, A., Cucunubá, Z., FitzJohn, R., Gaythorpe, K., … Ferguson, N. M. (2020). Estimates of the severity of coronavirus disease 2019: A model-based analysis. The Lancet Infectious Diseases, S1473309920302437. https://doi.org/10.1016/S1473-3099(20)30243-7