This document provides additional details and examples for technical and organisational measures in the Data Privacy Vocabulary [[DPV]], and is a companion to the [[DPV]] specification.
Contributing: The DPVCG welcomes participation to improve the DPV and associated resources, including expansion or refinement of concepts, requesting information and applications, and addressing open issues. See contributing guide for further information.
DPV and Related Resources
[[[DPV]]]: is the base/core specification for the 'Data Privacy Vocabulary', which is extended for Personal Data [[PD]], Locations [[LOC]], Risk Management [[RISK]], Technology [[TECH]], and [[AI]]. Specific [[LEGAL]] extensions are also provided which model jurisdiction specific regulations and concepts - see the complete list of extensions. To support understanding and applications of [[DPV]], various guides and resources [[GUIDES]] are provided, including a [[PRIMER]]. A Search Index of all concepts from DPV and extensions is available.
[[DPV]] and related resources are published on GitHub. For a general overview of the Data Protection Vocabularies and Controls Community Group [[DPVCG]], its history, deliverables, and activities - refer to DPVCG Website. For meetings, see the DPVCG calendar.
The peer-reviewed article “Creating A Vocabulary for Data Privacy” presents a historical overview of the DPVCG, and describes the methodology and structure of the DPV along with describing its creation. An open-access version can be accessed here, here, and here. The article Data Privacy Vocabulary (DPV) - Version 2, accepted for presentation at the 23rd International Semantic Web Conference (ISWC 2024), describes the changes made in DPV v2.
Introduction
Overview of Technical & Organisational Measures taxonomy in DPV (click to open in new window)
DPV's taxonomy of tech/org measures are structured into four groups representing [=TechnicalMeasure=] such as encryption or deidentification which operate at a technical level, [=OrganisationalMeasure=] such as policies and training which operate at an organisational level, [=LegalMeasure=] which are organisational measures with legal enforcement such as contracts and NDAs, and [=PhysicalMeasure=] which are associated with physical aspects such as environmental protection and physical security. Each of these is provided with a taxonomy that expands upon the core idea to provide a rich list of measures that are intended to protect personal data and technologies (and its associated entities and consequences).
To indicate applicability of measures, the relations [=hasTechnicalMeasure=], [=hasOrganisationalMeasure=], [=hasLegalMeasure=], and [=hasPhysicalMeasure=] are provided. In addition to these, specific relations are also provided for concepts commonly used or which are important for legal considerations - such as [=hasNotice=] and [=hasPolicy=].
dpv:TechnicalOrganisationalMeasure: Technical and Organisational measures used to safeguard and ensure good practices in connection with data and technologies
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dpv:LegalMeasure: Legal measures used to safeguard and ensure good practices in connection with data and technologies
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dpv:OrganisationalMeasure: Organisational measures used to safeguard and ensure good practices in connection with data and technologies
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dpv:PhysicalMeasure: Physical measures used to safeguard and ensure good practices in connection with data and technologies
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dpv:TechnicalMeasure: Technical measures used to safeguard and ensure good practices in connection with data and technologies
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Technical Measures
Overview of Technical Measures taxonomy in DPV (click to open in new window)
Technical measures refer to measures that are implemented at a technical level. They are represented by the concept [=TechnicalMeasure=] and are indicated using the relation [=hasTechnicalMeasure=]. Concepts provided to represent commonly used technical measures include [=AccessControlMethod=], [=AuthenticationProtocols=], [=AuthorisationProtocols=], [=CryptographicMethods=], [=DataBackupProtocols=], [=DigitalRightsManagement=], [=Encryption=], and [=SecurityMethod=].
To express information about the technology implementing the technical measure, the concept `Technology` can be associated by using the relation `isImplementedUsingTechnology`. The [[TECH]] extension provides further concepts to represent technologies and their development and provision.
dpv:AccessControlMethod: Methods which restrict access to a place or resource
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dpv:UsageControl: Management of usage, which is intended to be broader than access control and may cover trust, digital rights, or other relevant controls
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dpv:ActivityMonitoring: Monitoring of activities including assessing whether they have been successfully initiated and completed
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dpv:AuthenticationProtocols: Protocols involving validation of identity i.e. authentication of a person or information
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dpv:BiometricAuthentication: Use of biometric data for authentication
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dpv:CryptographicAuthentication: Use of cryptography for authentication
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dpv:Authentication-ABC: Use of Attribute Based Credentials (ABC) to perform and manage authentication
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dpv:Authentication-PABC: Use of Privacy-enhancing Attribute Based Credentials (ABC) to perform and manage authentication
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dpv:HashMessageAuthenticationCode: Use of HMAC where message authentication code (MAC) utilise a cryptographic hash function and a secret cryptographic key
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dpv:MessageAuthenticationCodes: Use of cryptographic methods to authenticate messages
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dpv:MultiFactorAuthentication: An authentication system that uses two or more methods to authenticate
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dpv:PasswordAuthentication: Use of passwords to perform authentication
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dpv:SingleSignOn: Use of credentials or processes that enable using one set of credentials to authenticate multiple contexts.
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dpv:ZeroKnowledgeAuthentication: Authentication using Zero-Knowledge proofs
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dpv:AuthorisationProtocols: Protocols involving authorisation of roles or profiles to determine permission, rights, or privileges
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dpv:CryptographicMethods: Use of cryptographic methods to perform tasks
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dpv:AsymmetricCryptography: Use of public-key cryptography or asymmetric cryptography involving a public and private pair of keys
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dpv:CryptographicAuthentication: Use of cryptography for authentication
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dpv:Authentication-ABC: Use of Attribute Based Credentials (ABC) to perform and manage authentication
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dpv:Authentication-PABC: Use of Privacy-enhancing Attribute Based Credentials (ABC) to perform and manage authentication
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dpv:HashMessageAuthenticationCode: Use of HMAC where message authentication code (MAC) utilise a cryptographic hash function and a secret cryptographic key
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dpv:MessageAuthenticationCodes: Use of cryptographic methods to authenticate messages
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dpv:CryptographicKeyManagement: Management of cryptographic keys, including their generation, storage, assessment, and safekeeping
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dpv:DifferentialPrivacy: Utilisation of differential privacy where information is shared as patterns or groups to withhold individual elements
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dpv:DigitalSignatures: Expression and authentication of identity through digital information containing cryptographic signatures
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dpv:HashFunctions: Use of hash functions to map information or to retrieve a prior categorisation
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dpv:HomomorphicEncryption: Use of Homomorphic encryption that permits computations on encrypted data without decrypting it
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dpv:PostQuantumCryptography: Use of algorithms that are intended to be secure against cryptanalytic attack by a quantum computer
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dpv:PrivacyPreservingProtocol: Use of protocols designed with the intention of provided additional guarantees regarding privacy
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dpv:PrivateInformationRetrieval: Use of cryptographic methods to retrieve a record from a system without revealing which record is retrieved
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dpv:QuantumCryptography: Cryptographic methods that utilise quantum mechanical properties to perform cryptographic tasks
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dpv:SecretSharingSchemes: Use of secret sharing schemes where the secret can only be reconstructed through combination of sufficient number of individuals
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dpv:SecureMultiPartyComputation: Use of cryptographic methods for entities to jointly compute functions without revealing inputs
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dpv:SymmetricCryptography: Use of cryptography where the same keys are utilised for encryption and decryption of information
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dpv:TrustedComputing: Use of cryptographic methods to restrict access and execution to trusted parties and code
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dpv:TrustedExecutionEnvironment: Use of cryptographic methods to restrict access and execution to trusted parties and code within a dedicated execution environment
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dpv:ZeroKnowledgeAuthentication: Authentication using Zero-Knowledge proofs
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dpv:DataBackupProtocols: Protocols or plans for backing up of data
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dpv:DataSanitisationTechnique: Cleaning or any removal or re-organisation of elements in data based on selective criteria
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dpv:DataRedaction: Removal of sensitive information from a data or document
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dpv:Deidentification: Removal of identity or information to reduce identifiability
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dpv:Anonymisation: Anonymisation is the process by which data is irreversibly altered in such a way that a data subject can no longer be identified directly or indirectly, either by the entity holding the data alone or in collaboration with other entities and information sources
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dpv:Pseudonymisation: Pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;
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dpv:DeterministicPseudonymisation: Pseudonymisation achieved through a deterministic function
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dpv:DocumentRandomisedPseudonymisation: Use of randomised pseudonymisation where the same elements are assigned different values in the same document or database
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dpv:FullyRandomisedPseudonymisation: Use of randomised pseudonymisation where the same elements are assigned different values each time they occur
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dpv:MonotonicCounterPseudonymisation: A simple pseudonymisation method where identifiers are substituted by a number chosen by a monotonic counter
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dpv:RNGPseudonymisation: A pseudonymisation method where identifiers are substituted by a number chosen by a Random Number Generator (RNG)
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dpv:DigitalRightsManagement: Management of access, use, and other operations associated with digital content
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dpv:AsymmetricEncryption: Use of asymmetric cryptography to encrypt data
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dpv:EncryptionAtRest: Encryption of data when being stored (persistent encryption)
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dpv:EncryptionInTransfer: Encryption of data in transit e.g. when being transferred from one location to another, including sharing
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dpv:EndToEndEncryption: Encrypted communications where data is encrypted by the sender and decrypted by the intended receiver to prevent access to any third party
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dpv:SymmetricEncryption: Use of symmetric cryptography to encrypt data
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dpv:InformationFlowControl: Use of measures to control information flows
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dpv:SecurityMethod: Methods that relate to creating and providing security
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dpv:DistributedSystemSecurity: Security implementations provided using or over a distributed system
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dpv:DocumentSecurity: Security measures enacted over documents to protect against tampering or restrict access
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dpv:FileSystemSecurity: Security implemented over a file system
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dpv:HardwareSecurityProtocols: Security protocols implemented at or within hardware
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dpv:IntrusionDetectionSystem: Use of measures to detect intrusions and other unauthorised attempts to gain access to a system
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dpv:MobilePlatformSecurity: Security implemented over a mobile platform
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dpv:NetworkSecurityProtocols: Security implemented at or over networks protocols
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dpv:OperatingSystemSecurity: Security implemented at or through operating systems
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dpv:PenetrationTestingMethods: Use of penetration testing to identify weaknesses and vulnerabilities through simulations
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dpv:UseSyntheticData: Use of synthetic data to preserve privacy, security, or other effects and side-effects
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dpv:VirtualisationSecurity: Security implemented at or through virtualised environments
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dpv:VulnerabilityTestingMethods: Methods that assess or discover vulnerabilities in a system
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dpv:WebBrowserSecurity: Security implemented at or over web browsers
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dpv:WebSecurityProtocols: Security implemented at or over web-based protocols
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dpv:WirelessSecurityProtocols: Security implemented at or over wireless communication protocols
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Organisational Measures
Overview of Organisational Measures taxonomy in DPV (click to open in new window)
Organisational Measures, represented by the concept [=OrganisationalMeasure=], are measures that are undertaken at an organisational level i.e. by the human involved within the organisation. They involve aspects such as performing assessments, consultations, establishing governance procedures, providing notices, contracts, policies, record keeping, and other similar activities. Though such activities can utilise technologies to support their implementations, the measure is still primary categorised as being associated with 'organisational activities'. Organisational measure are indicated by using the relation [=hasOrganisationalMeasure=].
dpv:Assessment: The document, plan, or process for assessment or determination towards a purpose e.g. assessment of legality or impact assessments
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dpv:ComplianceAssessment: Assessment regarding compliance (e.g. internal policy, regulations)
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dpv:LegalComplianceAssessment: Assessment regarding legal compliance
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dpv:ConformanceAssessment: Assessment regarding conformance with standards or norms or guidelines or similar instruments
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dpv:DataInteroperabilityAssessment: Measures associated with assessment of data interoperability
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dpv:DataQualityAssessment: Measures associated with assessment of data quality
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dpv:EffectivenessDeterminationProcedures: Procedures intended to determine effectiveness of other measures
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dpv:LegitimateInterestAssessment: Indicates an assessment regarding the use of legitimate interest as a lawful basis by the data controller
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dpv:Audit: An audit is a systematic examination or evaluation of records, processes, or systems towards a specific objective such as to assess accuracy, compliance, effectiveness, or performance
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dpv:InformationAudit: An audit that systematically examines the existence and use of information along with its associated resources (e.g. where it is stored) and flows (e.g. where it originates and with whom it is being shared)
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dpv:PersonalDataAudit: An audit that systematically examines the existence and use of personal data along with its associated resources (e.g. where it is stored) and flows (e.g. where it originates and with whom it is being shared)
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dpv:LegalComplianceAudit: An audit that systematically examines the state of legal compliance by reviewing policies and procedures related to obligations and compliance requirements for specific laws and regulations
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dpv:SecurityAudit: An audit that systematically examines the existence and use of security risks and measures within information systems, networks, and security policies to identify vulnerabilities, risks, and gaps
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dpv:CertificationSeal: Certifications, seals, and marks indicating compliance to regulations or practices
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dpv:Certification: Certification mechanisms, seals, and marks for the purpose of demonstrating compliance
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dpv:Seal: A seal or a mark indicating proof of certification to some certification or standard
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dpv:Consultation: Consultation is a process of receiving feedback, advice, or opinion from an external agency
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dpv:ConsultationWithAuthority: Consultation with an authority or authoritative entity
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dpv:ConsultationWithDataSubject: Consultation with data subject(s) or their representative(s)
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dpv:ConsultationWithDataSubjectRepresentative: Consultation with representative of data subject(s)
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dpv:ConsultationWithDPO: Consultation with Data Protection Officer(s)
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dpv:DataGovernance: Measures associated with topics typically considered to be part of 'Data Governance'
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dpv:DataInteroperabilityManagement: Measures associated with management of data interoperability
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dpv:DataInteroperabilityAssessment: Measures associated with assessment of data interoperability
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dpv:DataInteroperabilityImprovement: Measures associated with improvement of data interoperability
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dpv:DataInventoryManagement: Measures associated with management of data inventory or a data asset list
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dpv:DataQualityManagement: Measures associated with management of data quality
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dpv:DataQualityAssessment: Measures associated with assessment of data quality
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dpv:DataQualityImprovement: Measures associated with improvement of data quality
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dpv:DataSecurityManagement: Measures associated with management of data security
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dpv:MetadataManagement: Measures associated with management of metadata
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dpv:DigitalLiteracy: Providing skills, knowledge, and understanding to enable reading, writing, analysing, reasoning, and communicating regarding digital technologies and their implications
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dpv:AILiteracy: Providing skills, knowledge, and understanding to enable reading, writing, analysing, reasoning, and communicating regarding AI
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dpv:DataLiteracy: Providing skills, knowledge, and understanding to enable reading, writing, analysing, reasoning, and communicating regarding data
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dpv:GovernanceProcedures: Procedures related to governance (e.g. organisation, unit, team, process, system)
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dpv:ApprovalProcedure: A procedure or process for determining and managing approvals for activities as part of governance
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dpv:AssetManagementProcedures: Procedures related to management of assets
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dpv:ComplianceMonitoring: Monitoring of compliance (e.g. internal policy, regulations)
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dpv:DisasterRecoveryProcedures: Procedures related to management of disasters and recovery
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dpv:IncidentManagementProcedures: Procedures related to management of incidents
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dpv:IncidentReportingCommunication: Procedures related to management of incident reporting
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dpv:Policy: A guidance document outlining any of: procedures, plans, principles, decisions, intent, or protocols.
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dpv:DataProcessingPolicy: Policy regarding data processing activities
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dpv:MonitoringPolicy: Policy for monitoring (e.g. progress, performance)
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dpv:RecertificationPolicy: Policy regarding repetition or renewal of existing certification(s)
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dpv:ReviewProcedure: A procedure or process that reviews the correctness and validity of other procedures and policies e.g. to ensure continued validity, adequacy for intended purposes, and conformance of processes with findings
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dpv:ReviewImpactAssessment: Procedures to review impact assessments in terms of continued validity, adequacy for intended purposes, and conformance of processes with findings
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dpv:StandardsConformance: Purposes associated with activities undertaken to ensure or achieve conformance with standards
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dpv:GuidelinesPrinciple: Guidelines or Principles regarding processing and operational measures
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dpv:CodeOfConduct: A set of rules or procedures outlining the norms and practices for conducting activities
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dpv:Guideline: Practices that specify how activities must be conducted
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dpv:Principle: A representation of values or norms that must be taken into consideration when conducting activities
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dpv:PrivacyByDefault: Practices regarding setting the default configurations of information and services to implement data protection and privacy (synonymous with Data Protection by Default)
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dpv:PrivacyByDesign: Practices regarding incorporating data protection and privacy in the design of information and services (synonymous with Data Protection by Design)
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dpv:Notice: A notice is an artefact for providing information, choices, or controls
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dpv:AINotice: A notice providing information regarding the particulars of an AI system such as its intended purpose and proper use
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dpv:DataTransferNotice: Notice for the legal entity for the transfer of its data
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dpv:PrivacyNotice: Represents a notice or document outlining information regarding privacy
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dpv:ConsentNotice: A Notice for information provision associated with Consent
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dpv:SecurityIncidentNotice: A notice providing information about security incident(s)
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dpv:DataBreachNotice: A notice providing information about data breach(es) i.e. unauthorised transfer, access, use, or modification of data
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dpv:Notification: Notification represents the provision of a notice i.e. notifying
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dpv:SecurityIncidentNotification: Notification of information about security incident(s)
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dpv:DataBreachNotification: Notification of information about data breach(es) i.e. unauthorised transfer, access, use, or modification of data
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dpv:RecordsOfActivities: Records of activities within some context such as maintenance tasks or governance functions
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dpv:RightsManagement: Methods associated with rights management where 'rights' refer to controlling who can do what with a resource
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dpv:DataSubjectRightsManagement: Methods to provide, implement, and exercise data subjects' rights
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dpv:IPRManagement: Management of Intellectual Property Rights with a view to identify and safeguard and enforce them
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dpv:PermissionManagement: Methods to obtain, provide, modify, and withdraw permissions along with maintaining a record of permissions, retrieving records, and processing changes in permission states
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dpv:ConsentManagement: Methods to obtain, provide, modify, and withdraw consent along with maintaining a record of consent, retrieving records, and processing changes in consent states
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dpv:Safeguard: A safeguard is a precautionary measure for the protection against or mitigation of negative effects
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dpv:RegulatorySandbox: Mechanism used by regulators and businesses for gauging the compatibility of regulations and innovative products, particularly in the context of digitalisation, in a controlled real-world environment with appropriate safeguards in place
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dpv:SafeguardForDataTransfer: Represents a safeguard used for data transfer. Can include technical or organisational measures.
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dpv:SecurityProcedure: Procedures associated with assessing, implementing, and evaluating security
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dpv:AuthorisationProcedure: Procedures for determining authorisation through permission or authority
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dpv:CredentialManagement: Management of credentials and their use in authorisations
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dpv:IdentityManagementMethod: Management of identity and identity-based processes
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dpv:BackgroundChecks: Procedure where the background of an entity is assessed to identity vulnerabilities and threats due to their current or intended role
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dpv:DataSecurityManagement: Measures associated with management of data security
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dpv:SecureProcessingEnvironment: A physical or virtual environment supported by organisational means that integrates security and compliance requirements and allows supervising data processing actions
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dpv:SecurityRoleProcedures: Procedures related to security roles
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dpv:ThirdPartySecurityProcedures: Procedures related to security associated with Third Parties
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dpv:StaffTraining: Practices and policies regarding training of staff members
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dpv:CybersecurityTraining: Training methods related to cybersecurity
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dpv:DataProtectionTraining: Training intended to increase knowledge regarding data protection
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dpv:EducationalTraining: Training methods that are intended to provide education on topic(s)
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dpv:ProfessionalTraining: Training methods that are intended to provide professional knowledge and expertise
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dpv:SecurityKnowledgeTraining: Training intended to increase knowledge regarding security
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dpv:SupportEntityDecisionMaking: Supporting entities, including individuals, in making decisions
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dpv:SupportContractNegotiation: Supporting entities, including individuals, with negotiating a contract and its terms and conditions
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dpv:SupportExchangeOfViews: Supporting individuals and entities in exchanging views e.g. regarding data processing purposes for their best interests
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dpv:SupportInformedConsentDecision: Supporting individuals with making a decision regarding their informed consent
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Assessments
[=Assessment=] refers to a document, plan, or process for assessment or determination towards a purpose. For example, legal compliance assessment establishes compliance with the law and lawfulness. Similarly, privacy assessments concern privacy, risk assessments concern risks, and impact assessments concern impacts of operations and technologies. To represent such commonly utilised assessments, DPV provides the following concepts:
[=ComplianceAssessment=] and its extended concept [=LegalComplianceAssessment=] for compliance and legal compliance related assessments e.g. with a particular law
[=ConformanceAssessment=] for assessment of conformance e.g. towards a standard or guideline
[=DataInteroperabilityAssessment=] to assess the interoperability of data, such as that required by regulations like [[DGA]]
[=DataQualityAssessment=] for assessment of data quality
[=EffectivenessDeterminationProcedures=] for assessment of the effectiveness of other measures or activities
[=LegitimateInterestAssessment=] to assess the legitimate interests used (as a legal basis) to justify the activity
Assessments which refer to risks and/or impacts, such as risk assessment, privacy impact assessment, data protection impact assessment, and data breach impact assessment are defined in the 'risk' module within DPV due to their role within the risk management processes.
Notices
The concept [=Notice=] represents a 'notice' which provides information and can be used to offer choices and make decisions - such as for privacy and consent. The relation [=hasNotice=] is used to indicate the inclusion or association of a notice within a context.
The contents of a notice can be represented through other DPV concepts, for example a privacy notice can represent specific services and processes along with their purposes, personal data, and involved entities by utilising the relevant concepts and relations for these. Notices can also contain metadata, such as for their creation date, titles and descriptions, versions, and publisher information by utilising a common standard such as [[DCTERMS]].
Notice Types
DPV provides a taxonomy to represent the different notices commonly utilised in the context of data and technology use-cases. These include notices categorised by their role in providing information, such as [=PrivacyNotice=] and [=ConsentNotice=], and notices categorised by their UI/UX aspects, such as [=GraphicalNotice=], [=DashboardNotice=], and [=LayeredNotice=].
dpv:DashboardNotice: A notice that is provided within a dashboard also used for other purposes
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dpv:DataTransferNotice: Notice for the legal entity for the transfer of its data
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dpv:DeviceNotice: A notice provided using the functionality provided by a device e.g. using the popup or alert feature
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dpv:GraphicalNotice: A notice that uses graphical elements such as visualisations and icons
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dpv:JITNotice: A notice that is provided "just in time" when collecting information or performing an activity
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dpv:PrintedNotice: A notice that is provided in a printed form on or along with a device
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dpv:PrivacyNotice: Represents a notice or document outlining information regarding privacy
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dpv:ConsentNotice: A Notice for information provision associated with Consent
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dpv:SecurityIncidentNotice: A notice providing information about security incident(s)
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dpv:DataBreachNotice: A notice providing information about data breach(es) i.e. unauthorised transfer, access, use, or modification of data
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Notice Layer and Icons
For graphical notices that are composites of multiple 'layers' or utilise visual elements, the concepts [=NoticeLayer=] and [=NoticeIcon=] along with their corresponding relations [=hasNoticeLayer=] and [=hasNoticeIcon=] are useful to express to represent notices in terms of modular components.
Notice Statuses
[=NoticeStatus=] represents a status about a [=Notice=], and is associated using the relation [=hasNoticeStatus=]. The DPV provides specific statuses modelling the lifecycle associated with notice provision and usage, such as [=NoticeCommunicated=] to indicate a notice has been provided, [=NoticeUpdated=] to indicate a notice has been updated, and [=NoticeLatest=] to indicate a notice is at its 'latest' iteration.
dpv:NoticeCommunicated: Status indicating the notice has been communicated
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dpv:NoticeGenerated: Status indicating the notice has been generated
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dpv:NoticeLatest: Status indicating the notice is currently at its latest iteration
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dpv:NoticeStale: Status indicating the notice is stale or not up to date or not the latest version
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dpv:NoticeUnused: Status indicating the notice has been communicated but has not yet been used e.g. the recipient has not acknowledged it or has not taken the intended action
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dpv:NoticeUpdated: Status indicating the notice has been updated and its contents or implications have changed
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dpv:NoticeUsed: Status indicating the notice has been communicated and has been used e.g. the recipient has acknowledged it or taken the intended action
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Consent Notice
Requirements for informed consent require provision of information before the consent is obtained so as to inform the individual. This information is typically provided through a notice, which can be specified using the concept ConsentNotice and the relation hasNotice. As with the previous notice example, a consent notice can be a link to the actual notice document or web-page, or contain description of the notice contents regarding processing of personal data.
Policies
[=Policy=] represents a guidance document outlining procedures, plans, principles, decisions, intent, or protocols. It is associated using the relation [=hasPolicy=]. DPV provides concepts to represent policies regarding:
[=DataProcessingPolicy=] for specifying how data processing takes place - including [=DataDeletionPolicy=], [=DataErasurePolicy=], [=DataRestorationPolicy=], and [=DataStoragePolicy=].
In addition to the above data related policies, DPV also defines [=DataJurisdictionPolicy=] to specify jurisdictional requirements, and [=DataReusePolicy=] for specifying how data can be further used for purposes other than its initial purpose.
[=InformationSecurityPolicy=] regarding information security
[=LoggingPolicy=] regarding logging of information (i.e. maintaining logs and records as a technical concept).
[=MonitoringPolicy=] for how something should be monitored e.g. other policies and activities.
[=RecertificationPolicy=] for how often or when certification should be renewed or checked for conformance.
DPV does not provide the concept PrivacyPolicy, but instead suggests to use the better expressed and less ambiguous term - PrivacyNotice. This is to explicitly denote that the role of what is considered common as a "privacy policy" is actually a "notice" intended for end users and other individuals, instead of being an internal policy document for how the company should approach 'privacy'. More information about notices is provided in the next section.
Record Keeping
Records, or storing of information with the intention to use it in the future, are an important obligation for several legal as well as other obligations related to data protection and privacy. To support record keeping, the concept [=RecordsOfActivities=] is provided. Specific records are represented with the concepts:
[=DataBreachRecord=] for data breach records
[=DataProcessingRecord=] for records about data processing activities, including [=ConsentRecord=], [=DataTransferRecord=], [=SecurityIncidentRecord=], and [=ROPA=] (Records of Processing Activities) - which is a specific document required by regulations such as GDPR.
DPV also contains the Record concept as a type of Processing operation, and RecordManagement as a type of Purpose. The former refers to recording of personal data as a means to obtain it (e.g. record a conversation), while the latter relates to the use of personal data towards creating records and managing them as a purpose (e.g. record consent was given). These are distinct, though relevant to the organisational measures related to record keeping.
Record keeping may require further vocabularies to represent details such as various temporal annotations, provenance, statuses, or other contextual information that is not possible or provided for by DPV's concepts. In such cases, we suggest utilising other standardised vocabularies where applicable.
Legal Measures
[=LegalMeasure=] represents organisational measures which have a legal enforcement mechanism or are legally defined/interpreted. For example, through contracts, NDAs, agreements. They are associated by using [=hasLegalMeasure=].
dpv:ContractualTerms: Contractual terms governing data handling within or with an entity
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dpv:DataHandlingClause: Conctractual clauses governing handling of data within or by an entity
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dpv:LegalAgreement: A legally binding agreement
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dpv:ConfidentialityAgreement: Agreements that enforce confidentiality for e.g. to protect business, professional, or company secrets
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dpv:NDA: Non-disclosure Agreements e.g. preserving confidentiality of information
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dpv:StatisticalConfidentialityAgreement: An agreement outlining conditions, criteria, obligations, responsibilities, and specifics for classification and management of 'confidential data' based on a statistical framework
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Physical Measures
[=PhysicalMeasure=] represents measures that have a physical implementation - such as physical access control or environment controls for floods, power outages, etc. They are associated by using [=hasPhysicalMeasure=].
dpv:EnvironmentalProtection: Physical protection against environmental threats such as fire, floods, storms, etc.
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dpv:PhysicalAccessControlMethod: Access control applied for physical access e.g. premises or equipment
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dpv:PhysicalAuthentication: Physical implementation of authentication e.g. by matching the person to their ID card
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dpv:PhysicalAuthorisation: Physical implementation of authorisation e.g. by stamping a visitor pass
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dpv:PhysicalDeviceSecurity: Physical protection for devices and equipment
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dpv:PhysicalInterceptionProtection: Physical protection against interception e.g. by posting a guard
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dpv:PhysicalInterruptionProtection: Physical protection against interruptions e.g. electrical supply interruption
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dpv:PhysicalNetworkSecurity: Physical protection for networks and networking related infrastructure e.g. by isolating networking equipments
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dpv:PhysicalSecureStorage: Physical protection for storage of information or equipment e.g. secure storage for files
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dpv:PhysicalSupplySecurity: Physically securing the supply of resources
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dpv:PhysicalSurveillance: Physically monitoring areas via surveillance
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Security
All technical and organisational measures are intended, by definition, to provide better security and handling of personal data and its associated processing and other activities. In DPV's taxonomy, some measures directly and specifically relate to security as their topic, whilst others provide their intended benefit indirectly. For example, the concept SecurityAssessments is an organisational measure relating to how security is assessed (and thus ultimately improved) - and is directly associated with security as a topic. Whereas a concept such as ProfessionalTraining relates to measures that are not directly tied to security, but can be associated in cases where the training is related to security or specific security measures or risks (e.g. cybersecurity data breach mitigations). The purpose EnforceSecurity provides a common umbrella term for personal data that is utilised for enacting and enforcing security measures, such as for authorisation and authentication.
Technical measures that relate specifically to security include SecurityMethod for providing security, and its subtypes for DocumentSecurity, FileSystemSecurity, HardwareSecurityProtocols, IntrusionDetectionSystem, MobilePlatformSecurity, NetworkSecurityProtocols, OperatingSystemSecurity, WebBrowserSecurity, WebSecurityProtocols, and more. Organisational measures that relate specifically to security include SecurityProcedure, and its subtypes for BackgroundChecks, CybersecurityAssessments, CybersecurityTraining, SecurityAssessments, and more.
Data Processing Agreements
The term Data Processing Agreement refers to a broad concept related to contracts or agreements between entities representing conditions regarding the processing of (personal-)data. This can include ad-hoc 'data handling' policies such as NDAs, embargoes, and enforcement of practices, as well as more formal and legal binding contractual obligations such as those between a Controller and a Processor.
To represent such concepts, DPV provides LegalAgreement, along with subtypes for NDA (Non-disclosure agreements), ContractualTerms, and DataProcessingAgreement. In these, it is important to remember that while contract can also be as a form of legal basis, the concept represented here is not necessarily the same contract as that is used to justify the processing of personal data with a data subject. Instead, contracts are a broad category representing contractual terms governing data handling within or with an entity.
For representing specific agreements between entities (other than those with data subjects - which are covered in Legal Basis taxonomy), DPV provides the following types of agreements:
ControllerProcessorAgreement: An agreement between a Controller and a Processor, where the Controller instructs the Processor(s) to carry out processing on its behalf.
JointControllersAgreement: An agreement between two or more Controllers to act as a 'Joint Controller'.
SubProcessorAgreement: An agreement between two or more Processors where one Processor instructs another to carry out processing on its behalf.
ThirdPartyAgreement: An agreement between a Data Controller or a Data Processor, and a Third Party. Note that this is a loosely defined concept, as depending on the jurisdiction, this relationship may result in the Third Party being a Data Controller or a Joint Data Controller.
To indicate the entities involved in an agreement, the relation hasEntity can be used, or relations associated with specific roles to indicate contextuality. For example, using hasDataController with a ControllerProcessorAgreement denotes the Data Controller for that agreement.
Data Transfer Safeguards
While all technical and organisational measures are intended to safeguard personal data and its associated activities, there may be contextual or use-case requirements to explicitly indicate safeguards against or for specific criteria. To enable such use, DPV provides the concept Safeguard and its subtype SafeguardForDataTransfer for indicating application when data is being transferred. Through these, it is possible to represent aspects such as policies for data transfers, specific measures such as encryption being applied, and other pertinent information in combination with DPV's concepts from technical and organisational measures.
Anonymisation is the process by which data is irreversibly altered in such a way that a data subject can no longer be identified directly or indirectly, either by the entity holding the data alone or in collaboration with other entities and information sources
An audit is a systematic examination or evaluation of records, processes, or systems towards a specific objective such as to assess accuracy, compliance, effectiveness, or performance
Methods to obtain, provide, modify, and withdraw consent along with maintaining a record of consent, retrieving records, and processing changes in consent states
Source
Date Created
2024-04-14
Contributors
Beatriz Esteves, Harshvardhan J. Pandit, Georg P. Krog
Deletion and Erasure are distinct activities where deletion refers to logical removal of data with the possibility of retrieval whereas erasure refers to destruction of data such that it cannot be retrieved. See dpv:DataErasurePolicy
Erasure or data destruction or secure removal of data refers to irreversible erasure of data. See dpv:DataDeletion for reversible or logical deletion of data
Policy specifying jurisdictional requirements for data processing
Usage Note
Jurisdictional requirements can refer to data being stored within specific jurisdictions, or that data must be in line with jurisdictional laws and norms
This only refers to the policy or plan or procedure describing how the data processing should be conducted. To represent the granular details, see further concepts e.g. dpv:DataStoragePolicy to describe policy regarding storage, or dpv:DataStorageCondition to represent information within the policy for how information should be stored
Policy regarding reuse of data i.e. using data for purposes other than its initial purpose
Usage Note
This policy can be used to describe the procedures associated with undertaking such reuse of data, for example to assess its legality and the compatibility of the initial and subsequent purposes
Measures associated with management of data security
Usage Note
Examples of data security management are assessing the appropriate security controls such as encryption, testing the implemented security controls, and ensuring it is protected and safeguarded from unintended actions
Methods to provide, implement, and exercise data subjects' rights
Usage Note
This concept only concerns the organisational management of rights, and does not represent the rights themselves - especially where such 'rights' are legally recognised or defined for the data subject or individual. The concept dpv:DataSubjectRight is provided to represent such legal rights.
Source
Date Created
2024-04-14
Contributors
Beatriz Esteves, Harshvardhan J. Pandit, Georg P. Krog
Providing skills, knowledge, and understanding to enable reading, writing, analysing, reasoning, and communicating regarding digital technologies and their implications
An audit that systematically examines the existence and use of information along with its associated resources (e.g. where it is stored) and flows (e.g. where it originates and with whom it is being shared)
An audit that systematically examines the state of legal compliance by reviewing policies and procedures related to obligations and compliance requirements for specific laws and regulations
Examples of metadata management include assessing which metadata are required or being used by technology, assessing their potential inclusion as personal data, and implementing a metadata based solution to manage data
A notice is an artefact for providing information, choices, or controls
Usage Note
Notice refers to the information whereas Notification refers to the provision of that notice. In several cases, they are used interchangeably - for example Privacy Notice as a measure or control refers to both the information as well as the act of making it available. For 'active' contexts where this distinction is important, e.g. data breach notifications, see Notification concept.
Status indicating the notice has been communicated but has not yet been used e.g. the recipient has not acknowledged it or has not taken the intended action
Notification represents the provision of a notice i.e. notifying
Usage Note
Notice refers to the information whereas Notification refers to the provision of that notice. The distinction is important as there are specific obligations associated with notice and notifications. For example, a data breach notice refers to the information about the breach intended to be provided to another entity, whereas notification refers to the act of providing the entity with the notice
Methods to obtain, provide, modify, and withdraw permissions along with maintaining a record of permissions, retrieving records, and processing changes in permission states
Usage Note
Permission is a broader concept than '(Informed) Consent' as consent when used as a legal basis has specific requirements to be valid. For management of consent, see the concept dpv:ConsentManagement
Source
Date Created
2024-04-14
Contributors
Beatriz Esteves, Harshvardhan J. Pandit, Georg P. Krog
An audit that systematically examines the existence and use of personal data along with its associated resources (e.g. where it is stored) and flows (e.g. where it originates and with whom it is being shared)
Usage Note
This concept is the same as "Data Mapping" and "Data Flow Mapping Exercise" used by the Information Comissioner's Office as "to document the data that flows in, around, and out of information processing systems or services"
Practices regarding setting the default configurations of information and services to implement data protection and privacy (synonymous with Data Protection by Default)
Date Created
2019-04-05
Date Modified
2024-04-14
Contributors
Axel Polleres, Rob Brennan, Harshvardhan J. Pandit, Mark Lizar
Pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;
Mechanism used by regulators and businesses for gauging the compatibility of regulations and innovative products, particularly in the context of digitalisation, in a controlled real-world environment with appropriate safeguards in place
A procedure or process that reviews the correctness and validity of other procedures and policies e.g. to ensure continued validity, adequacy for intended purposes, and conformance of processes with findings
A Record of Processing Activities (ROPA) is a document detailing processing activities
Usage Note
ROPA under GDPR Art.30 has specific requirements regarding the information to be maintained. Additionally, Data Protection Authorities also provide additional information guidelines for information to be maintained in a ROPA. For more information see https://w3id.org/dpcat
A physical or virtual environment supported by organisational means that integrates security and compliance requirements and allows supervising data processing actions
An audit that systematically examines the existence and use of security risks and measures within information systems, networks, and security policies to identify vulnerabilities, risks, and gaps
An agreement outlining conditions, criteria, obligations, responsibilities, and specifics for classification and management of 'confidential data' based on a statistical framework
DPV uses the following terms from [[RDF]] and [[RDFS]] with their defined meanings:
rdf:type to denote a concept is an instance of another concept
rdfs:Class to denote a concept is a Class or a category
rdfs:subClassOf to specify the concept is a subclass (subtype, sub-category, subset) of another concept
rdf:Property to denote a concept is a property or a relation
The following external concepts are re-used within DPV:
External
Contributors
The following people have contributed to this vocabulary. The names are ordered alphabetically. The affiliations are informative do not represent formal endorsements. Affiliations may be outdated. The list is generated automatically from the contributors listed for defined concepts.
Arthit Suriyawongkul (ADAPT Centre, Trinity College Dublin)
Axel Polleres (Vienna University of Economics and Business)
Beatriz Esteves (IDLab, IMEC, Ghent University)
Bud Bruegger (Unabhängige Landeszentrum für Datenschutz Schleswig-Holstein)
Damien Desfontaines ()
David Hickey (Dublin City University)
Delaram Golpayegani (ADAPT Centre, Trinity College Dublin)
Elmar Kiesling (Vienna University of Technology)
Fajar Ekaputra (Vienna University of Technology)
Georg P. Krog (Signatu AS)
Harshvardhan J. Pandit (ADAPT Centre, Dublin City University)
Iain Henderson ()
Javier Fernández (Vienna University of Economics and Business)
Julian Flake (University of Koblenz)
Mark Lizar (OpenConsent/Kantara Initiative)
Maya Borges ()
Paul Ryan (Uniphar PLC)
Piero Bonatti (Università di Napoli Federico II)
Rana Saniei (Universidad Politécnica de Madrid)
Rob Brennan (University College Dublin)
Rudy Jacob (Proximus)
Simon Steyskal (Siemens)
Steve Hickman ()
Funding Acknowledgements
Funding Sponsors
The DPVCG was established as part of the SPECIAL H2020 Project, which received funding from the European Union’s Horizon 2020 research and innovation programme under grant agreement No. 731601 from 2017 to 2019.
Harshvardhan J. Pandit was funded to work on DPV from 2020 to 2022 by the Irish Research Council's Government of Ireland Postdoctoral Fellowship Grant#GOIPD/2020/790.
The ADAPT SFI Centre for Digital Media Technology is funded by Science Foundation Ireland through the SFI Research Centres Programme and is co-funded under the European Regional Development Fund (ERDF) through Grant#13/RC/2106 (2018 to 2020) and Grant#13/RC/2106_P2 (2021 onwards).
Funding Acknowledgements for Contributors
The contributions of Harshvardhan J. Pandit have been made with the financial support of Science Foundation Ireland under Grant Agreement No. 13/RC/2106_P2 at the ADAPT SFI Research Centre.
