DSIT on data intermediaries
DSIT are consulting on creating more loopholes, here are the questions they're hiding away
[Update: here are the questions for the second consultation on data brokers]
DSIT is running a consultation on “data intermediaries” and there is no public copy of the questions unless you go through the answering process.
According to DSIT, “The full list of questions are as follows:
Section A: Exercise of data subject rights
Q1. Can you provide examples of where data subject rights are currently exercised by third parties on the instruction of, or in the interest of, the data subject?
Q2. What barriers do individuals, businesses, or other organisations face in the uptake of the right to data portability or other data subject rights?
Q3. Aside from personal data protection laws, how do other areas of law interact with the operation of data intermediaries?
Section B: Data intermediaries
Q4. Does the taxonomy above fully reflect the range of models of data intermediaries in the UK or elsewhere?
Q5. Is the current law around the operations of data intermediaries sufficiently clear? What changes and/or additional guidance would be required to provide clarity to data intermediaries? Does this differ based on operating model?
Section C: Barriers to data intermediary sector
Q6. What are the main barriers to performing data intermediation services in the UK, and how do they differ across sectors and models?
Q7. What role should the government have in addressing these barriers? Are there examples of effective or ineffective government interventions in other countries or markets?
Q8. Can you provide examples of successful data intermediaries and the technological and non-technological factors that contributed to their success?
Section D: Risks associated with exercise of data subject rights by third parties
Q9. Can you provide any evidence on potential risks for the wider exercise of data subject rights by third parties (such as data stewards) on behalf of a data subject? Can you identify any risks associated with the activities of data intermediaries?
Q10. Are there potential implications for digital inclusion of delegation of data subject rights and the activity of data intermediaries? Are there any disproportionate effects on those with protected characteristics under the Equality Act 2010?
Q11. Can you provide any evidence of a best practice approach to managing those risks? What should the roles of Government, regulators, and the market be?
”
You've gotta be fucking kidding! No wonder they don't make it public!!! This is deliberately designed to deter the public from engaging! Who can even understand the questions, let alone respond! They've done exactly the same with the Genetically Modified Organisms 'Consultation'. Reams of text with the critical issues buried in them somewhere. Outrageous! Imprisoned by data and this seems to be the way neoliberalism has walled itself off from us, the public. My local council barricaded behind a wall of computerised, telephone answering systems, the companies I'm forced to do business with locked away behind incomprehensible Web Pages that behave like mazes.