WPF comments to NTIA re: privacy governance frameworks

In response to the NTIA’s request for information regarding its proposed privacy framework, the World Privacy Forum submitted detailed comments to the agency regarding modern privacy governance. At the core of WPF’s comments is the belief that privacy is in a critical moment of transition.

From the comments:

“The emerging world is one of rapid data transformation and data fusion. It requires an approach that will empower all stakeholders to participate in solutions and will provide an architecture for identifying, assessing, and mitigating privacy risk on an ongoing basis. This is modern governance, and correctly constructed, governance that will allow for a broadened approach to privacy and data that is collaborative, fair, and acknowledges the challenges of highly complex data environments. The challenges of the early Internet era are not the same challenges we face today. It therefore makes sense to adapt the frameworks we are using to solve new data-related problems.”

Read the complete comments here.

Related documents:

WPF_Comments to the NTIA re: privacy governance frameworks, November 2018 (15 pages, PDF)

Posted November 28, 2018 in Data Fusion, Digital Privacy, Do No Harm, NTIA

New Report: Risky Analysis: Assessing and Improving AI Governance Tools

We are pleased to announce the publication of a new WPF report, “Risky Analysis: Assessing and Improving AI Governance Tools.” This report sets out a definition of AI governance tools, documents why and how these tools are critically important for trustworthy AI, and where these tools are around the world. The report also documents problems in some AI governance tools themselves, and suggests pathways to improve AI governance tools and create an evaluative environment to measure their effectiveness. AI systems should not be deployed without simultaneously evaluating the potential adverse impacts of such systems and mitigating their risks, and most of the world agrees about the need to take precautions against the threats posed. The specific tools and techniques that exist to evaluate and measure AI systems for their inclusiveness, fairness, explainability, privacy, safety and other trustworthiness issues — called in the report collectively AI governance tools – can improve such issues. While some AI governance tools provide reassurance to the public and to regulators, the tools too often lack meaningful oversight and quality assessments. Incomplete or ineffective AI governance tools can create a false sense of confidence, cause unintended problems, and generally undermine the promise of AI systems. The report contains rich background details, use cases, potential solutions to the problems discussed in the report, and a global index of AI Governance Tools.
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Report: From the Filing Cabinet to the Cloud: Updating the Privacy Act of 1974

This comprehensive report and proposed bill text is focused on the Privacy Act of 1974, an important and early Federal privacy law that applies to the government sector and some contractors. The Privacy Act was written for the 1970s information era -- an era that was characterized by the use of mainframe computers and filing cabinets. Today's digital information era looks much different than the '70s: smart phones are smarter than the old mainframes, and documents are now routinely digitized and stored and perhaps even analyzed in the cloud, among many other changes. The report focuses on why the Privacy Act needs an update that will bring it into this century, and how that could look and work. This work was written by Robert Gellman, and informed by a two-year multi-stakeholder process.