Agree - we should not Modify the legal term and expand, And, Interestingly in the Conv 108+ they also have article 88 - which is for logging records, and we want mirrored record logs (but not sure where that actually fits in the architecture. As logging does not appear in GDPR, is seems that logging for international data and control transfers, for regulators, ( - m On 5 Nov 2023, at 10:32, Salvatore D'Agostino <sal@idmachines.com> wrote: So for me transparency provides a means of measuring the RoPA, transparency as a requirement of a RoPA, whereas today they exists without a record for the performance. Given the term RoPA has legal heft why would be modify it, imo we should leverage, define, enhance the requirement. From: SP AMINA <Sharon.Polsky@AMINAcorp.ca> Sent: Sunday, November 5, 2023 8:18 AM To: Mark Lizar <mark@transparencylab.ca> Cc: Salvatore D'Agostino <sal@idmachines.com>; wg-ancr@kantarainitiative.org Subject: Re: [WG-ANCR] csf comments “ROT - Pa” doesn’t exactly roll off the tongue. And starting the acronym with “ROT” doesn’t present positive connotations. Grammatically, it’s also is backward and therefore unintuitive — like a “privacy impact assessment” is backward. The title actually means that it’s an assessment of the impact that privacy has, which is the exact opposite of what it is and ought to be — an assessment of the impact upon privacy that something might have. How about Processing Activity Record of Transparency — PART— or Privacy Processing Activity Record of Transparency — PPART. my 2c On Nov 5, 2023, at 5:27 AM, Mark Lizar <mark@transparencylab.ca<mailto:mark@transparencylab.ca>> wrote: . Perhaps we should refer to this as a Digital Privacy Record of Transparent Processing Activity (RoTPA) ? On 3 Nov 2023, at 18:30, Salvatore D'Agostino <sal@idmachines.com<mailto:sal@idmachines.com>> wrote: Yes RoPA! Get Outlook for iOS<https://aka.ms/o0ukef> ________________________________ From: Mark Lizar <mark@transparencylab.ca<mailto:mark@transparencylab.ca>> Sent: Friday, November 3, 2023 5:34:55 PM To: Salvatore D'Agostino <sal@idmachines.com<mailto:sal@idmachines.com>> Cc: wg-ancr@kantarainitiative.org<mailto:wg-ancr@kantarainitiative.org> <wg-ancr@kantarainitiative.org<mailto:wg-ancr@kantarainitiative.org>> Subject: Re: [WG-ANCR] csf comments Nice Job Sal, I noticed that there is little to no awareness of notice standards, that we can move beyond clear and simple language, addressing the dark patterns. Perhaps we can work on this? Refer to 29184 and 27560 and the DPV, which can be used on or for records of processing, And that the digital transparency indicators assess these elements privacy elements in security. What do you think? -
On 3 Nov 2023, at 15:16, Salvatore D'Agostino <sal@idmachines.com<mailto:sal@idmachines.com>> wrote:
Of course this is last minute but I think this is enough to put us on their map and set up our relevance generally
Will send off if no objections comments close today.
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