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Designing for privacy and its legal framework : data protection by design and default for the Internet of Things
Tamò-Larrieux A., Springer International Publishing, New York, NY, 2018. 254 pp. Type: Book (978-3-319986-23-4)
Date Reviewed: Jun 9 2020

Rarely have I seen a book on such a contemporary sociotechnical topic as privacy protection that so successfully combines information and communications technology (ICT) concepts to legal principles, (European) regulation to implementation approaches, and examples to theory.

The author has produced a masterwork that, after having read many other books and articles on the subject, finally gave me peace of mind--not in the sense that the book revealed any magical universal recipe to resolve the privacy protection issues that agitate myself as an ICT professional and other designers of sociotechnical solutions, but in the sense that at last I have at hand “the reference book.” That is, a book that will guide me and help me resolve all the legal-technical intricacies that I face, that will liberate me of the anxiety that at some phase “I missed that legal something,” that will help me choose the best technology to try to resolve specific issues during the critical design phase of a solution, that will help me to identify and prioritize those aspects that I should cover first when designing, for example, the next software application, the next web app thing, the next marketing campaign, the next social media thing, in the best possible “regulation-correct” manner.

Many legal “things” (terminology, principles, concepts, interlinks) are clearly defined and explained in the first chapters, though this adds to the length of the book. Each chapter ends with literature selections and references, which are meticulously linked to the text via plentiful footnotes on almost every page. Example toy cases are systematically used to explain how legal principles and regulations can be applied in specific cases. An Internet of Things (IoT) product and startup company demo case is extensively discussed in chapters 4 and 9. This discussion is very useful to anyone getting involved in this arena. One chapter (10) is devoted to developing guidelines for an effective privacy engineering approach.

The book contains a huge amount of information that requires a lot of reading and rereading; assessing every chapter in this review would be tiresome to read. To help both this review and prospective readers, I located the core of the book--nine sections--at least from an ICT professional/designer point of view: Section 5.3: “Taxonomy of Legal Principles,” Section 6.2: “Taxonomy of Technical Tools,” Section 6.3: “Security Tools,” Section 6.4: “Anonymity Tools,” Section 6.5: “Autonomy Tools,” Section 6.6: “Transparency Tools,” Section 7: “Mapping the Privacy Protection Tools Throughout the Life Cycle of Data,” Section 8.2: “Regulation’s Guidance on Technical Tools,” and Section 10.2: “Developing Privacy Engineering Guidelines.”

The first seven sections referenced above contain an immense amount of material, collected and organized in simple yet complete sets of principles and tool clusters and accurately intercorrelated between them and to the data life cycle model (DLCM). The last two sections provide concise guidelines on how to apply the knowledge distilled from the previous selections to actual work in the field. Readers must read the whole book in order to fully grasp the vastness of the topic, but this core should help busy professionals find results fast.

Now, I must say a few words on what exactly these nine sections so nicely depict.

Section 5.3 capitalizes on all the chapters before it and does an extensive tour of all legal principles in European law that form the legal point of view about privacy protection. So, principles are discussed concerning the legality of data processing (involving concepts like lawfulness, fairness, transparency, informed consent, purpose limitation), the design of data processing systems (involving concepts like data minimization, proportionality, use disclosure and storage limitation, data security, anonymity and pseudonymity, data quality and accuracy), the rights of individuals (involving concepts like the participation principle, information and access rights, reaction, erasure and objection rights), and compliance and enforcement (involving concepts like accountability, liability, risk assessment, government supervision, sanctions, and compensation).

Keeping in mind the exact way all the legal information is organized, when readers go to the tool taxonomy in Sections 6.2 to 6.6, they will understand why many of the specific tools are selected and why they are comprehensively grouped to the four tool clusters: security (discussed under the approach of preservation of confidentiality, integrity, and availability, with lengthy discussion of cryptology, authentication, certificates and key infrastructures, and secure communication methodologies), anonymity (understood as the inability to sufficiently identify the subject within a set of subjects, with lengthy discussion of randomization, generalization, pseudonymization, identity management, and communication obfuscation), autonomy (understood as the ability to decide for oneself on the data processing about she/he, with discussion of access and permission control, disposal control, deletion control), and transparency (tools that provide users with information on what happens to their data during the data life cycle, with discussion of visualization privacy tools, automatic privacy assessment tools, and privacy impact assessment tools).

Chapter 7 is an in-depth look at mapping the tools presented in Chapter 6 and the legal principles of Chapter 5 to a DLCM with the following phases: collection, analysis, implementation, and deletion. This chapter is the glue that explains how Chapters 5 and 6 interrelate from a point of view that any ICT professional can clearly understand (due to links to DLCM) and more importantly put to immediate use. So, for example, an ICT professional can easily understand that, in the analysis phase, the legal principles of purpose limitation, use and disclosure limitation, anonymity and pseudonymity, access and reaction rights, and data quality are in effect, and critically choose specific tools coming from all four tool clusters to help in the implementation of these principles.

The last two selected sections (8.2 and 10.2) discuss how to critically apply all of the above knowledge. They can be used as guidelines, as work flows of usage for the legal and technological tools that we now possess.

The book usefully combines information from both legal and cyber-technical perspectives, focusing on European law, including the General Data Protection Regulation (GDPR). It is written in very readable language, that is, it does not trap readers in legalese but instead accurately exposes the issues. Extensive links to other legal and technical documents--International Organization for Standardization (ISO) standards, textbooks, and articles--are included throughout the book. It is a must-read for software architects, information technology (IT) managers, data protection officers (DPOs), chief information officers (CIOs), and marketing managers, especially those working heavily with social media.

Reviewer:  Constantin S. Chassapis Review #: CR146988 (2010-0240)
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