Gaia-X-Hub-Germany / IF-Access-and-Usage-Policies-and-Enforcement

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test #2

Open mlziegelmeir opened 3 months ago

mlziegelmeir commented 3 months ago

 

ID Needed Services to be delivered by the System Initiating Actor In SCOPE ISO 29184/27560 or needed Extensions Business (need/motivation) Requirement Comments Solution (block) details.
1a Create a PII principal – PII Controller Secure channel PII Controller YES Extension Exchange digitally Consent related artefacts securely (prevent usurpation of identity and tampering of artefacts) Non Functional Requirement - Did com controller used in OCM/ CloudPCM

(used to share invitation link)

- then OID Protocol used 

- OID for VCI and VP

- Possible to extend with custom protocol
1b Create a PII Controller – PII Controller Secure channel PII Controller YES Extension Exchange digitally Consent and PII Access related artefacts securely (prevent usurpation of identity and tampering of artefacts) Non Functional Requirement - Did com controller used in OCM/ CloudPCM

(used to share link)

- then OID Protocol used
2a Receiving Privacy Notice – Human Readable PII Principal YES ISO 29184 ISO/GDPR conformity – Enabling PII Principal to decide if he consents on collection and usage of PII Data by a PII Collector for a specific purpose. - CloudPCM-OCM used for issuance of a Credential
- Resolving "Privacy notice" is in the Consent Mgt Plugin 

Challenge 1:  Definition of Privacy notice and how to embed the content in the credential such that it is tamper proof.

Solution Idea :

- The evidence like a Hash of file. (But drawback : insufficient as not showing/giving access to the details of the notice.
- "ZUGFeRD", JSON, pdf , 

Challenge 2 : If a link with hash is used as evidence, a broken link would result in an invalid consent but then a technical solution would be needed to revoke the consent automatically.

Challenge 3 : the privacy notice content might need to be "Private". 2 examples : 

- if the notice includes personal information.
- if the notice is derived from a product sold/licensed.by e.g. a lawyer

If you verify the validity of the consent and understand what was consented to, the content of the privacy notice is needed.

Solution Ideas :

- Decentralised Ledger tamper-proof  but public ? 

- The public ledger can be protected. (e.g. encryption key as an attribute in the consent to enable holder to access content of the notice)

- Misusing techno approach like DID Method and its resolution to retrieve a DID document. (instead of a DID document, retrieval of the privacy notice

Challenge 4: The privacy notice has to be accessible for different PII Controller (e.g. in Health sector several doctors for instance)

Other requirement : Versioning of privacy notice. Embedded link shall point to one specific Version.
2b Provide Privacy Notice - Human Readable PII Controller ISO 29184 See comments in 2a
(Here the issuer of the Privacy Notice Credential is the OCM on PII Controller side)
3 Receiving Consent Receipts PII Principal YES ISO 29184 / 27560 ISO/GDPR conformity –

Enabling PII Principal to make inquiries and complaints toward PII controller
- CloudPCM-OCM used for issuance of a Credential (like privacy notice)
- Resolving "Consent Receipt" is in the Consent Mgt Plugin
4 Sending Consent Receipts PII Controller YES ISO 29184 / 27560 ISO/GDPR conformity –

Enabling PII Principal to make inquiries and complaints toward PII controller
This System Use case 4 "Sending Consent Receipts" can be executed several times after Sys UC 6 .

The Consent Mgt Plugin needs at least one Consent Receipt Credential per Consent Credential.

The issuance of consent Receipt may be synchronous to the reception of a consent credential or asynchronous
5a Delivering a principal consent information to a PII Controller who sent previously a Privacy Notice. PII Principal YES ISO 29184 / 27560 ISO/GDPR conformity – Enabling PII Principal to decide if he consents on collection and usage of PII Data by PII Controller and Processor Issuer of Credential is here opposite to Privacy notice and Consent Receipt : The Cloud PCM (PII Principal)

- Either with 

synchronous REDIRECT to the PII Controller shall happen to continue the process on the PII Controller side.

This REDIRECT is triggered from the Plugin when giving Consent

- or  asynchronous delayed consent

The retrieval of the Consent Credential by the PII Controller (OCM) can trigger an action at the PII Controller side e.g. "Sending Consent Receipt" Sys UC 4
5b Delivering a revocation about a consent information to a PII Controller who sent previously a Privacy Notice. PII Principal YES ISO 29184 / 27560 ISO/GDPR conformity –

Enabling PII Principal to revoke previously  consented privacy notice.
The revocation shall not give public information that can be linked to a person.

The VERIFIER shall verify before using a consent.

A consent can be valid very long time. (many years)

IDEA Solutions :

- Dispute mechanism is not anymore W3C compliant
- Revocation List of Consent ID  + flag
- Did/verification Method from the consent Credential deleted
- expiration parameter in the consent
6 Receiving and Storing consent information (or revocation) in Consent Record for further processing PII Controller YES ISO 29184 / 27560 ISO/GDPR conformity –

Enabling PII Controller to fullfill his legal obligations (incl. revocation)
MS: not moved as I'm unsure if this belongs to SeSoMan
7a Present a consent information to request PII access and ...

- upon success : 7b
PII Controller YES Extension Automate collection of PII Data (through the consent information) MS: not moved as I'm unsure if this belongs to SeSoMan
7b Receiving in return of 7a access key and address to a PII hosted by another PII Controller PII Controller Extension Automate collection of PII Data (through the consent information) MS: not moved as I'm unsure if this belongs to SeSoMan
8a Receiving consent information for PII access request and...

- if the consent is successfully verified (8b) 

- provide  access keys and address to a PII under my control (8c)
PII Controller Extension Automate collection of PII Data (through the consent information) MS: not moved as I'm unsure if this belongs to SeSoMan
8b Verify a consent legitimacy to confirm if 8a is successfull or not PII Controller YES Extension Automate collection of PII Data (through the consent information) MS: not moved as I'm unsure if this belongs to SeSoMan
8c Providing access keys and address to a PII under my control PII Controller Extension Automate collection of PII Data (through the consent information) MS: not moved as I'm unsure if this belongs to SeSoMan
9 Extension of Services 2 to 8 to handle not only a consent on a PII type but on a very specific instance of PII Data. (The consent is not valid for the PII type in general but ONLY for a unique PII_identifier) PII Controller / PII Principal YES Extension handling of uniquely identified PII data set.

And not only PII type.
To clarify how to enable this and such that the artefacts remain ISO Conform.

(How does the ISO understand a consent on PII type with a PII identifier ? Is the identifier only informational and an example of a PII Type or does it restrict the consent to that identifier ?)

MS: also not moved as this comprises several services
10 - Automated Consent functions limitation for Principal with legal representant

- Forward Privacy Notice / Delegate Consent function to another PII Principal (An official Legal representative of the under aged PII Principal)
PII Principal NO Extension Enable Use Case where the Principal is not yet legally in age to give himself a consent (Child/Parent) Note : PII Controller would not be able to find the other principal (only the contact of the one who sends the consent is known)
11 Same as 5 but the consent shall contain additionally:

- legal representative PII Principal Information who signed the consent.
PII Principal NO Extension Enable Use Case where the Principal is not yet legally in age to give himself a consent (Child/Parent) Note : PII Controller would not be able to find the other principal (only the contact of the one who sends the consent is known)
12 Browse and Read Consent Artefacts and their status (Privacy Notice received, Consent given, Consent Receipt received, Consent revoked or declined) PII Principal YES ISO/GDPR conformity –

Enabling PII Principal to make inquiries and complaints toward PII controllers
13 Browse and maintain Consent Records PII Controller NO ISO/GDPR conformity –

Fullfill a part of the legal responsibilities of a PII Controller
MS: not merged as this is part of service app but not of  SeSoMan
14 Validate PII Attributes PII Controller NO Extension Enabling PII controller to validate if the PII attributes collected match expectation the controller expectation MS: not merged as this is part of service app but not of  SeSoMan