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Data Quality Principle

From the OECD Guidelines: “Personal data should be relevant to the purposes for which they are to be used, and, to the extent necessary for those purposes, should be accurate, complete, and kept up-to-date.”

There are two key ideas in this principle. The first is “relevancy” (i.e., the data collected/used must be genuinely pertinent to the purpose and proportional, that is, only the appropriate amount and type of data to suit the purpose for its collection or processing). The second idea is accuracy. This is important because it creates obligations on behalf of the entity that controls the data to ensure data integrity. This requirement has evolved to also require giving data owners the ability to access their data and correct or update any errors.

It should be noted that data “integrity” is one of the core principles and goals for the security practitioner as well. For security, confidentiality, integrity, and availability are key markers for success and planning security requirements. Throughout this book we will note where synergies and common goals exist such as the case of data integrity. In doing so, the building and maintenance requirements for privacy engineers should be viewed as additive to other requirements rather than competing or negating “compliance” post facto requirements.

Purpose Specification Principle

From the OECD Guidelines: “The purposes for which personal data are collected should be specified not later than at the time of data collection and the subsequent use limited to the fulfilment of those purposes or such others as are not incompatible with those purposes and as are specified on each occasion of change of purpose.”

This principle provides guidance regarding the type and quality of transparency or notice. From an innovator's perspective, creators of systems or services should carefully consider how PI will be used throughout the lifecycle of the current situation and should plan ahead as carefully and fully as possible to ensure that enough flexibility for data processing is introduced into the system and any contextual cues, including notice leading to transparency and understanding of data use.

Use Limitation Principle

From the OECD Guidelines: “Personal data should not be disclosed, made available or otherwise used for purposes other than those specified in accordance with Paragraph 9 [Purpose Specification Principle] except:

a) With the consent of the data subject; or

b) By the authority of law.”

This principle qualifies both the limits for data processing and the expectations of the data subject and also suggests conditions for potentially adding to the type, kind, and timing of data processing when that processing was not included in the initial authorization. As discussed previously, some legal enforcement should be contemplated and presented in the original “Purpose Specification of the Notice.”

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