Posts by Martin Abrams
Who Is Paying the Policy Debt?
Everyone! There is a technology concept called the “tech debt.” It accumulates over time when software development applies the easy and quick incremental answer to complete or change a project…
Read MoreA Principled Approach to Data Protection Risk Balancing
Data is necessary for information, and information is necessary for knowledge. Knowledge can be used to advance as well as hinder individuals’ rights and interests. The individuals’ right to autonomy…
Read MoreTime for an Unfairness Rule on Fair Information Processing
The IAF has submitted its comments on the FTC Advanced Notice of Proposed Rule Making on Surveillance Capitalism and Security (ANPR). The IAF staff thinks it is time for the…
Read MoreLet’s Return Risk to the Risk Based Approach
Professor Lokke Moerel is right. The European data protection commissioners have done their best to use cases, guidance, and opinions to write the risk-based approach out of the General Data…
Read MoreLocation Data and Evidence for the FTC ANPR
I was well into writing a blog related to the Federal Trade Commission’s advanced notice of proposed rulemaking (ANPR) on “Commercial Surveillance and Security” when the FTC announced it had…
Read MoreAssessing the ADPPA for Improvements that Would Not Impact Basic Design
The views expressed are Martin Abrams’ and shared by other members of the IAF team. They do not necessarily reflect the views of the IAF Board or other members of…
Read MoreThe Summer of New Data Protection Redirection
Canada and the United Kingdom are putting forward fair processing ideas that I believe will lead to a new direction in the way data protection is being thought about. These…
Read MoreA Data Protection Bill with an Entirely Different Tone
The Queen’s speech, which was delivered by Prince Charles on May 10th, contained the expected announcement that the UK government intends to reform its data protection law. Rather than follow…
Read MoreThe Shape Shifting Nature of Privacy Risk Management
For the past decade, the privacy ecosystem, company CPOs, policymakers, regulators, academics, advocates, the courts and others have been using the term “risk-based” without any clear definition of what that…
Read MoreVerified Governance is Coming Like a Runaway Freight Train
There is growing evidence that data forward processes will require governance that considers impacts not just to privacy and cyber security but also considers inappropriate discrimination, precluded opportunities, and fair…
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