"#Data: a new direction" - a public consultation by @DCMS on "reforms to the UK’s #DataProtection regime":

gov.uk/government/con…

The consultation ends on 19 Nov 2021, and you can respond by e-mail to DataReformConsultation@dcms.gov.uk or online here:

dcms.eu.qualtrics.com/jfe/form/SV_4P… Image
A quick sample of initial reactions...

We're clearly going to be hearing a lot about #LegitimateInterests, as well as #commercial and #public ones. The real question being, how do this Government's interests actually align with YOURS?

140+ pages on a Friday is a lot to digest, but @lilianedwards' "penumbra of often futile determinedly populist ideas largely not evidence-based" seems entirely consistent with @DCMS's Drunkard's Walk through #data and #ID this past year...

But... but... it's all about #innovation, don'tcha know?

OF COURSE their plan is baldly profit centric. What else is Government for? (I'm also not entirely sure that at this point they'd recognise a #principle, even if they happened to read one...)

REALLY important point from @CampaignFoI that shouldn't be lost.

Weakening #SubjectAccess would be a direct assault on our fundamental #rights as #citizens within the #InformationSociety:



#DataProtection IS NOT #FreedomOfInformation and never should be!
A point emphasised by @WorkerInfoX, which uses #SARs in challenging unfair dismissals and making algorithmic management systems transparent:



HT @lilianedwards
Then there's this [Thread] of [Threads] from @WolfieChristl:



Prompted in large part by those ever-expanding (and ever-expandable) #LegitimateInterests... Image
(a) doesn't seem *too* contentious - though a person's "#concerns" aren't the same as criminal #acts.

While delivering #statutory public comms *may* make sense, who decides what is & what isn't a "public health & safety message" for (b) - plus, #AllYourMailingListsAreBelongToUs? Image
Not sure (c) should be a "#LegitimateInterest" as much as a #LawfulObligation. Indeed, depending on the type of #bias, I think it already is!

(d) is transparently what #AdTech has lobbied for; not so much a 'massacre of the #cookies' as @OliverDowden selling you down the river.. Image
#Security is good, and necessary - but wouldn't (e) provide a blanket excuse to, say, read anyone's or everyone's e-mails?

Ditto safety, in which (f) could play out in... unpredictable ways - especially under the coming #OnlineHarms regime.

#BewareWhatYouWishFor! Image
Not sure (g) does anything at all - though it clearly intends to give that impression. You'll still be #processing #PersonalData, so people's DP rights should apply.

I suspect the real intent here is more to do with "#CompatibleUses", which hasn't played out so well for #GPdata! Image
(h) is *exactly* the clause @Google got into its #ProjectNightingale contract with @Ascensionorg:

businesswire.com/news/home/2019…

i.e. 'Now all your #patients' data is flowing through our systems, let us use it to i̶m̶p̶r̶o̶v̶e̶ train our #AIs - and then charge you even more!'

🤦‍♂️🤦‍♂️🤦‍♂️ Image
And finally (i), which again seems like an existing #LawfulObligation - unless @DCMS has never heard of (or doesn't understand) #DataMinimisation?

All in all, the list reveals more about who Government's been listening to and how poorly it grasps existing law than anything else. Image
This [Thread] by @ds_m4riano doesn't so much 'scratch the surface' of the Government's plans as gut them with a fillet knife!



And here's the blog post that goes with it:

openrightsgroup.org/blog/why-on-ea… Image
When the @FT calls Government's so-called 'business-friendly' #data proposals "#foolhardy", its recent data initiatives "#lamentable" and an "#assault on rights", and its policies even more #extreme than China's, then you know you're in trouble...

Image
Excellent [Thread] by @owenboswarva:



...with whose assessment I also agree, on @DCMS having put in some self-evidently batshit suggestions to "draw fire".

I might be more convinced by mention of "Privacy Management Program(mes)" if the Government...
...showed any sign of #accountability itself & wasn't so obviously hell-bent on tearing up #governance across the board (cf. 'extract once, use many times').

Entirely as predicted, its 'bonfire of the #regulations' looks more like the systematic dismantling of citizens' #rights.
N.B. "#PrivacyManagement Program(me)s" aren't a daft idea:

priv.gc.ca/en/privacy-top…

...especially if you don't have a GENERAL #DataProtection Law that covers *all* data processing. Canada's #PIPEDA covers mostly private sector #commercial activities, not all #federal entities... Image
...which might go some way towards explaining why the UK Government seems so attracted to the notion.

Worth noting #PIPEDA's replacement, #DCIA/#CPPA, is still predominantly focused on #PrivateSector data use:

ic.gc.ca/eic/site/062.n… Image
A carefully #balanced view from @Pinsent_Masons, who spotted the Government's interest in #DataTrusts - in particular "what predefined criteria would have to be met to #remove the need for recourse to #consent"(!):

pinsentmasons.com/out-law/news/u…

One the one hand... and on the other: Image
And a healthy dose of #scepticism from a man who knows his onions, on 'building #trustworthy AI systems':

[Thread]

Gotta wonder if @ICOnews's 'contribution' will continue to favour '#innovation' over people's #rights and effective #enforcement:



Or if it'll be as forthright as @NDGoffice has been about @NHSX's recent 'data strategy':

gov.uk/government/pub… ImageImageImageImage
Oops! @DCMS should've chosen its examples more carefully, if it didn't want to give the game away:

techcrunch.com/2021/09/09/uk-…

While the @Moorfields research is admirable, mentioning @Google @DeepMind and the #NHS will more likely remind people of the illegal @RoyalFreeNHS deal 🤦🏻‍♂️ Image
N.B. For those who believe doing #ethical #scientific #research without people's #knowledge and #permission is *ever* OK, a #Tuskegee [Thread]:



(The impacts of this are playing out, even to this day...)
Here's a more recent example of what @DCMS's '#DataReforms'
as proposed would define as an automatically "#CompatiblePurpose" for "#ScientificResearch", requiring no "#BalancingTest":



and that's even before they get lost in the thicket of #AI #fairness!
Excellent breakdown by @RobertJBateman of the 74 - count 'em! - #DataProtection "#reforms" the Government is proposing:



(And yes, 38 is a doozy!) Image
Another couple of initial reactions, first from @alex_mizzi of @hk_employment:

employment.howardkennedy.com/post/102h6g6/d…

and a helpful summary from @DLA_Piper:

blogs.dlapiper.com/privacymatters… Image

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More from @EinsteinsAttic

17 Sep
Welcome back, George.

Now, about that "race-to-the-bottom" slashing of #data #protections... Image
...which, despite fine words about "maintaining high standards", is plainly the intent of @DCMS's proposed #DataProtection 'reforms':

assets.publishing.service.gov.uk/government/upl…

...which include the intent to (re)define "#ScientificResearch" 🤔🤔🤔 Image
Of course, we understand #TIGRR's "enthusiasm for #digital", its eye on the value of "highly #profitable consumer data", and frustration with the pesky #protections and #safeguards of #UKGDPR...

assets.publishing.service.gov.uk/government/upl… Image
Read 6 tweets
17 Sep
It's quite something to watch a nation that didn't emerge until a century after it ended reinvent #feudalism...

bloomberg.com/opinion/articl…

...presented as a great leap forward by a former #HedgeFund manager, no less! Image
Herded towards the cliff by the #BigFour (dodgy) Accountants of the #Apocalypse...
eand.co/our-civilizati…

(Who'da thunk that #externalities aren't so 'external' in a finite #ecosystem?) Image
Those who still read books get it, of course:

Read 4 tweets
16 Sep
On 8 September - during a consultation on the same, co-sponsored by @JuliaLopezMP - @mattwarman updated the 'UK digital #identity & attributes trust framework':
gov.uk/government/pub…

On 10 September, @OliverDowden
published '#Data: a new direction'...

gov.uk/government/con…
...a week later, they were both gone.

Also @cj_dinenage, who never quite managed to get out @DCMS's "upcoming" #DigitalStrategy, as teased in the #NationalDataStrategy (NDS).

And co-chair of the #NDS Forum, @JWhittingdale, who was "sad to give up":

bbc.co.uk/news/uk-politi… Image
The aforementioned
@JuliaLopezMP stepped from @cabinetofficeuk into @JWhittingdale's shoes at @DCMS - where, given her trajectory: ukauthority.com/articles/gds-r… and the joint consultation 👇 that closed just 3 days ago, one suspects she'll be spending a lot of her time on #identity... Image
Read 4 tweets
15 Sep
#LegalTwitter seems... unimpressed at the appointment of the new Lord Chancellor:

Image
And those with an appreciation of the complex moving parts are raising eyebrows at this particular 'change of horses mid-stream':

Image
Read 6 tweets
15 Sep
More info on the @CancerPrev_KCL & @CR_UK-run NHS-Galleri™ #screening trial:

kcl.ac.uk/news/kings-lea…

cancerresearchuk.org/about-cancer/c…

Worth noting you can't #volunteer for this trial, but if you are 50-77 & haven't been diagnosed with cancer in the past 3 years, you may be #invited... Image
The NHS-Galleri™ #screening trial is a proper #RCT, which means half of the 140,000 participants WON'T be tested (certainly not in the initial phase) and NONE will be told whether they have been #tested or not.

Of course if the test indicates *possible* markers for #cancer... Image
...then you will be contacted by the trial nurse by phone, and will be referred to an NHS hospital for further tests.

So every participant in the NHS-Galleri™ #screening trial should still attend standard screening & should contact their GP if they notice any unusual symptoms: Image
Read 5 tweets

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