[Rchivist]

Originally Posted by Pasanonic

So you admit then that any subsequent PIA is flawed by the nature of the fact it comes too late in the process?

Yes, that's made very clear in the interim report - page 4.

However, despite our positive findings regarding Phorm’s
approach to privacy protection we are disappointed that the
company has not benefited from an earlier implementation of a
PIA. While we are encouraged that Ernst & Young were engaged
to perform a privacy examination, the full scope and influence of
an “early intervention” PIA has not been possible. At this late stage
of product development it will not be possible to fully exploit the
value of a PIA.