DHS Privacy and Integrity Report
Last year, the Department of Homeland Security finally got around to appointing its DHS Data Privacy and Integrity Advisory Committee. It was mostly made up of industry insiders instead of anyone with any real privacy experience. (Lance Hoffman from George Washington University was the most notable exception.)
And now, we have something from that committee. On March 7th they published their “Framework for Privacy Analysis of Programs, Technologies, and Applications.”
This document sets forth a recommended framework for analyzing programs, technologies, and applications in light of their effects on privacy and related interests. It is intended as guidance for the Data Privacy and Integrity Advisory Committee (the Committee) to the U.S. Department of Homeland Security (DHS). It may also be useful to the DHS Privacy Office, other DHS components, and other governmental entities that are seeking to reconcile personal data-intensive programs and activities with important social and human values.
It’s surprisingly good.
I like that it is a series of questions a program manager has to answer: about the legal basis for the program, its efficacy against the threat, and its effects on privacy. I am particularly pleased that their questions on pages 3-4 are very similar to the “five steps” I wrote about in Beyond Fear. I am thrilled that the document takes a “trade-off” approach; the last question asks: “Should the program proceed? Do the benefits of the program…justify the costs to privacy interests….?”
I think this is a good starting place for any technology or program with respect to security and privacy. And I hope the DHS actually follows the recommendations in this report.