Contributors: (ordered alphabetically) Beatriz Esteves(IDLab, IMEC, Ghent University),
Harshvardhan J. Pandit(ADAPT Centre, Dublin City University).
NOTE: The affiliations are informative, do not represent formal endorsements, and may be outdated as this list is generated automatically from existing data.
The Justification extension provides a taxonomy extending the [[[DPV]]] concept Justification to enable representing specific justifications associated with non-fulfilment, non-requirement, delays, and exercising reasons involved in processes. The namespace for terms in justifications is https://www.w3id.org/dpv/justifications#, the suggested prefix is justifications, and the justifications vocabulary and its documentation is available on GitHub.
DPV v2.1-RC feedback/review period until FEB-16 The DPVCG welcomes feedback and review on the v2.1 Release Candidate containing DPV and related specifications until FEB-16, after which, these documents will be published unless unresolved major issues have been identified. Feedback/review can be e.g., suggestions for improvements, fixing grammar/typos, additional information and references, and technical changes to files. The DPVCG shall discuss all submitted feedback and will resolve in through the weekly meetings. To see what is included in v2.1 and a changelog, refer to this link.
DPV Specifications: The [[DPV]] is the core specification within the DPV family, with the following extensions: Personal Data [[PD]], Locations [[LOC]], Risk Management [[RISK]], Technology [[TECH]] and [[AI]], [[JUSTIFICATIONS]], [[SECTOR]] specific extensions, and [[LEGAL]] extensions modelling specific jurisdictions and regulations. A [[PRIMER]] introduces the concepts and modelling of DPV specifications, and [[GUIDES]] describe application of DPV for specific applications and use-cases. The Search Index page provides a searchable hierarchy of all concepts. The Data Privacy Vocabularies and Controls Community Group (DPVCG) develops and manages these specifications through GitHub. For meetings, see the DPVCG calendar.
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.
Introduction
DPV provides the concept Justification and relation hasJustification to provide reasons or explanations in specific contexts. For example, where a right could not be fulfilled due to the identity of the individual not being established or where a request was deemed as being too excessive and burdensome to undertake. Justifications also represent reasons why a process must be undertaken, for example why a particular objection is being made or why a specific activity is asked to be undertaken. To support the expression of such specific justifications, this extension provides concepts extending dpv:Justification.
Justifications can be found in regulations as exceptions to obligations - for example in GDPR Article 12-5 the justification "requests ... are manifestly unfounded or excessive" is mentioned. Justifications can also be identified through practical applications and use-cases, such as where organisations and data subjects commonly need to state reasons or explanations. As such, the DPVCG strives to provide a rich and comprehensive taxonomy of justifications and welcomes contributions for the same.
Justification Types
Justifications are broadly categorised as:
NotRequiredJustification: Justification to reject or not complete a process as it is not required or is not applicable
NonFulfilmentJustification: Justification for not fulfilling a process or requirement or obligation
DelayJustification: Justification to delay a process
ExerciseJustification: Justification for why the process should be carried out
This categorisation is not exact and mutually exclusive, but is provided as a convenience to organise the concepts in a comprehensible hierarchy. For example, a justification concept declared as DelayJustification can still be used as a NonFulfilmentJustification within a use-case.
Not-Required
Situations where a particular process is not-required or applicable have justifications of type NotRequiredJustification.
justifications:NotRequiredJustification: Justification to reject or not complete a process as it is not required or isn't applicable
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justifications:ProcessSafeguarded: Justification that the process is not required as it is safeguarded by appropriate technical and organisational measures
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justifications:RightsFreedomsImpactUnlikely: Justification that the process is not required as it is considered to be an unlikely impact on rights and freedoms
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justifications:RiskMitigated: Justification that the process is not required as the risks have been effectively mitigated by technical and organisational measures
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Non-Fulfilment
Where a particular process cannot be fulfilled, the relevant justification or reason is expressed using the concept NonFulfilmentJustification.
justifications:NonFulfilmentJustification: Justification for not fulfilling a process or requirement or obligation
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justifications:ConsentProvided: Justification that the process could not be fulfilled or was not successful because it is based on (a previously given) consent
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justifications:DisproportionateEffortRequired: Justification that the process could not be fulfilled or was not successful because it requires a disproportionate effort
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justifications:EntityAlreadyInformed: Justification that the process could not be fulfilled or was not successful because the entity already has the information
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justifications:EthicsProcedureImpaired: Justification that the process could not be fulfilled or was not successful because it would compromise ethics or ethics procedures
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justifications:EthicsBreachDetectionImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with the detection of breaches of ethics for regulated professions
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justifications:EthicsBreachInvestigationImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with the investigation of breaches of ethics for regulated professions
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justifications:EthicsBreachPreventionImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with the prevention of breaches of ethics for regulated professions
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justifications:EthicsBreachProsecutionImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with the prosecution of breaches of ethics for regulated professions
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justifications:FulfilmentImpossible: Justification that the process could not be fulfilled or was not successful because it is impossible to fulfil
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justifications:LackOfIntent: Justification that the process could not be fulfilled as the requestor or initiator did not have a sufficient intent to complete it
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justifications:LegalProcessImpaired: Justification that the process could not be fulfilled as it impairs or interferes with a legal or official process or procedure
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justifications:CivilLawEnforcementImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with the enforcement of civil laws, including civil claims
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justifications:ConfidentialityObligationCompromised: Justification that the process could not be fulfilled or was not successful because it would compromise a confidentiality obligation
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justifications:ContractEstablishmentNecessity: Justification that the process could not be fulfilled or was not successful because it is necessary for entering into a contract
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justifications:ContractPerformanceNecessity: Justification that the process could not be fulfilled or was not successful because it is necessary for the performance of a contract
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justifications:CrimeDetectionImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with the detection of criminal offences
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justifications:CrimeInvestigationImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with the investigation of criminal offences
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justifications:CrimePenaltyExecutionImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with the execution of criminal penalties
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justifications:CrimePreventionImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with the prevention of criminal offences
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justifications:CrimeProsecutionImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with the prosecution of criminal offences
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justifications:DataSubjectProtectionImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with the protection of the data subject
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justifications:DefenceImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with necessary tasks to safeguard defence
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justifications:FreedomOfExpressionImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with the right of freedom of expression and information of others
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justifications:IdentityVerificationFailure: Justification that the process could not be fulfilled or was not successful because identity verification failed
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justifications:JudicialProceedingsImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with the protection of judicial independence and proceedings
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justifications:LegalClaimImpaired: Justification that the process could not be fulfilled or was not successful because it would impair the establishment, exercise, or defence of a legal claim
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justifications:LegalClaimDefenceImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with the defence of legal claims
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justifications:LegalClaimEstablishmentImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with the establishment of legal claims
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justifications:LegalClaimExerciseImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with the exercise of legal claims
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justifications:LegallyExempted: Justification that the process could not be fulfilled or was not successful because it falls under legal exemption i.e. a law allows the non-fulfilment
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justifications:LegalObligationImpaired: Justification that the process could not be fulfilled as it would impair or conflict with a legal obligation
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justifications:NationalSecurityImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with necessary tasks to safeguard national security
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justifications:OfficialAuthorityExerciseImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with the exercise of official authorities
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justifications:OfficialStatisticsImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with official statistics
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justifications:PublicHealthCompromised: Justification that the process could not be fulfilled or was not successful because it would interfere with necessary tasks carried out for public health reasons
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justifications:PublicInterestArchivingImpaired: Justification that the process could not be fulfilled or was not successful because it impairs archiving for public interest
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justifications:PublicInterestCompromised: Justification that the process could not be fulfilled or was not successful because it would interfere with necessary tasks carried out for public interest
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justifications:PublicSecurityImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with necessary tasks to safeguard public security
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justifications:ThirdPartyRightsImpaired: Justification that the process could not be fulfilled or was not successful because it would affect the rights and freedoms of others
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justifications:LegitimateInterestOverride: Justification that the process could not be fulfilled or was not successful because the legitimate interest of the controller overrides the interests or rights of the data subject
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justifications:ObjectivesImpaired: Justification that the process could not be fulfilled or was not successful because it impairs the objectives of associated context
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justifications:ProcessRejected: Justification that the process could not be fulfilled because of one of more reasons associated with the process itself e.g. it was excessive, malicious, etc.
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justifications:ProcessExcessive: Justification that the process could not be fulfilled or was not successful because it was found to be excessive in nature
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justifications:ProcessFrivolous: Justification that the process could not be fulfilled or was not successful because it was found to be based on frivolous reasons
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justifications:ProcessMalicious: Justification that the process could not be fulfilled or was not successful because it was found to be malicious e.g. with intent to cause disruption or harassment
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justifications:ProcessUnfounded: Justification that the process could not be fulfilled or was not successful because it was found to be based on manifestly unfounded reasons
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justifications:ScientificHistoricalResearchImpaired: Justification that the process could not be fulfilled or was not successful because it impairs scientific or historical research
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justifications:SecurityImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with tasks required for maintaining security
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justifications:CrimeDetectionImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with the detection of criminal offences
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justifications:CrimeInvestigationImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with the investigation of criminal offences
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justifications:CrimePenaltyExecutionImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with the execution of criminal penalties
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justifications:CrimePreventionImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with the prevention of criminal offences
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justifications:CrimeProsecutionImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with the prosecution of criminal offences
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justifications:DataSubjectProtectionImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with the protection of the data subject
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justifications:DefenceImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with necessary tasks to safeguard defence
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justifications:IdentityVerificationFailure: Justification that the process could not be fulfilled or was not successful because identity verification failed
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justifications:NationalSecurityImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with necessary tasks to safeguard national security
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justifications:PublicSecurityImpaired: Justification that the process could not be fulfilled or was not successful because it would interfere with necessary tasks to safeguard public security
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Delay
Where a particular process is delayed, the justifications are represented through the concept DelayJustification.
justifications:DelayJustification: Justification to delay a process
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justifications:ComplexityOfProcess: Justification that the process is delayed due to complexity in fulfilling it
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justifications:HighVolumeOfProcesses: Justification that the process is delayed due to high volume of similar processes required to be fulfilled
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justifications:IdentityVerificationRequired: Justification that the process could not be fulfilled or was not successful because identity verification is required
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justifications:InformationRequired: Justification that the process is delayed due to additional information being required
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Exercise
To indicate why a particular process must be undertaken or is being requested, the justifications are represented using the concept ExerciseJustification.
justifications:ExerciseJustification: Justification for why the process should be carried out
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justifications:InformationSocietyServicesOffer: Justification that the process should be carried out due to it being related to the offer of information society services
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justifications:LegalObligation: Justification that the process should be carried out due to it being a legal obligation
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justifications:Objection: Justification that the process should be carried out due to specified objection(s)
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justifications:ContestAccuracy: Justification that the process should be carried out due it being an objection to the accuracy e.g. of system, outputs, data
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justifications:LegalityLackingObjection: Justification that the process should be carried out due to it being an objection to the lack of further legality or legal basis of specified context
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justifications:NonNecessityObjection: Justification that the process should be carried out due to it being an objection to the non-necessity of specified context
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justifications:UnlawfulActivityObjection: Justification that the process should be carried out due to it being an objection of unlawful activity
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Justification that the process could not be fulfilled or was not successful because it would interfere with the enforcement of civil laws, including civil claims
Justification that the process could not be fulfilled or was not successful because it would interfere with the detection of breaches of ethics for regulated professions
Justification that the process could not be fulfilled or was not successful because it would interfere with the investigation of breaches of ethics for regulated professions
Justification that the process could not be fulfilled or was not successful because it would interfere with the prevention of breaches of ethics for regulated professions
Justification that the process could not be fulfilled or was not successful because it would interfere with the prosecution of breaches of ethics for regulated professions
Justification that the process could not be fulfilled or was not successful because it would interfere with the right of freedom of expression and information of others
Justification that the process could not be fulfilled or was not successful because it would interfere with the protection of judicial independence and proceedings
Justification that the process could not be fulfilled as the requestor or initiator did not have a sufficient intent to complete it
Usage Note
An example of such intent is where the individual makes a request but then offers to withdraw it in return for some form of benefit from the organisation - see https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/individual-rights/right-of-access/when-can-we-refuse-to-comply-with-a-request/#refuse2
Justification that the process could not be fulfilled or was not successful because it would impair the establishment, exercise, or defence of a legal claim
Justification that the process could not be fulfilled or was not successful because it falls under legal exemption i.e. a law allows the non-fulfilment
Justification that the process could not be fulfilled or was not successful because the legitimate interest of the controller overrides the interests or rights of the data subject
Justification that the process could not be fulfilled or was not successful because it would interfere with necessary tasks to safeguard national security
Justification that the process could not be fulfilled or was not successful because it was found to be malicious e.g. with intent to cause disruption or harassment
Justification that the process could not be fulfilled because of one of more reasons associated with the process itself e.g. it was excessive, malicious, etc.
Justification that the process could not be fulfilled or was not successful because it would interfere with necessary tasks carried out for public health reasons
Justification that the process could not be fulfilled or was not successful because it would interfere with necessary tasks carried out for public interest
Justification that the process could not be fulfilled or was not successful because it would interfere with necessary tasks to safeguard public security
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
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 Beatriz Esteves have received funding through the PROTECT ITN Project from the European Union’s Horizon 2020 research and innovation programme under the Marie Skłodowska-Curie grant agreement No 813497. Beatriz Esteves is funded by SolidLab Vlaanderen (Flemish Government, EWI and RRF project VV023/10), and by the imec.icon project PACSOI (HBC.2023.0752) which was co-financed by imec and VLAIO.
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.