The Information Accountability Foundation will hold a framing discussion about Dynamic Data Obscurity (“DDO”) in Washington, DC, during January 2015.
Data management, particularly in an age of observational data and big data analysis, requires both effective polices for data application and controls to implement the policies. The Foundation’s past work has focused on accountability-based policies and assessments of ethical use. It is now time to turn to controls.
Early analytics, dating from the 1980s, were dependent on anonymization and de-identification to ensure compliance and individual protection. For example, information used for credit marketing needed to be de-identified to comply with the Federal Fair Credit Reporting Act. Technology provided the tools to de-identify, and the assurance came from the requirements of the FCRA. Effective de-identification and anonymization tools have always rested on this marriage of policy and technology.
Today’s analytics, driven by observation, makes the mandate for the “belt and suspenders” of policy and technology even more compelling. The technologies are challenged internally by organizations’ need for knowledge and externally by very smart cyber criminals. Even with the belt of policy, the suspenders of technology need upgrading to match today’s challenges. If we do not meet that challenge, we could see real resistance to the information age’s dual mandates for innovation and fairness. The policy community needs to explore DDO to see if it will enhance data security and privacy to facilitate increased data value and protection compared to legacy approaches.
There are new technology solutions emerging. The information governance community needs to understand those technologies and encourage more participants in that marketplace. Furthermore, the policy requirements need to be harmonized with newer capabilities including parsing proportionality of the robustness of the solution with the risk of the endeavor.
DDO is about this process of understanding and encouraging more robust technology solutions, interplaying policy with technology, and creating guidance for proportionality. The January discussion is the real beginning of putting flesh on the bones of DDO.