Quote:
Originally Posted by Pasanonic
Cant you just make a definitive statement about the screening process and the criteria and compliance checking met for the PIA? There is little to be gained by an " I know something you don't know" attitude. I'm not really concerned about the PIA content, I'm fairly confident of what I think it will say.
I'm more concerned with the framework applied to the process and would hope that you might offer up information about that, in the interests of openness and transparency of course? I'll be happy to accept your own ( perceived by me from your last comment ) view that you will have met the stakeholder criteria and if so then well done. All I ask is you tell me who the stakeholders are, how they were identified and why no poll of the public who are the biggest stakeholder outside of Phorm?
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Two points here. The first is that Phorm is a somewhat unusual (though not unique) case in terms of PIA screening. In isolation (having regard to the ICO guidance) it appears to be either compliant or exempt from conditions relating to the UK DPA. This does
not apply to overall privacy criteria though, as we pointed out in our interim PIA. So, we actually adopted a broader screening than the one suggested by the ICO. This is why we can include environments outside Phorm itself (such as the ISP's).
In terms of stakeholders, we accept the definition adopted by the ICO, which is "a collective word for the various groups and individuals who have a significant interest in the project and its outcomes, because they are participating in it, or may be affected by it." That, of course, is clearly the public.
However, polling does not offer a solution. As an activist I always found polling to be intellectually dodgy. Results are used when it suits, and ignored otherwise. We don't accept privacy intrusion on the basis of polling (CCTV is a good example) because principle is a far more robust basis to run an argument. If we down the years relied on a majority verdict to determine our position we would be immobalised on hundreds of privacy issues. In the case of targeted advertising, I wouldn't want to presume how the results would pan out. We always thought mandatory fingerprinting would be widely opposed, then discovered most of the population were in favour.
Simon