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As the technology has never before been the subject of a PIA wouldn't a truely accurate Privacy Impact Assessment require the product being run in a live environment so that scenarios could be created and system response observed?
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Its perfectly possible to run in simulation to a reasonable degree of accuracy to be able to run a PIA on what a system says its
meant to do and various scenarios based on that.
Unfortunately I doubt you will get in a PIA what a system
could do with a few software tweaks, as in this case is possible. I expect the PIA to cover what the system will do initially. This current state is bad enough but the possibilites as stated by Phorm themselves are almost mind boggling.