Hi !
This is an odd title. We've previously discussed how the national DPIA project should assist you in conducting similar DPIAs for other large systems. So, why are we now saying that our DPIA is NOT an example to follow?
What we're doing in this project is significant and complex. Firstly, we're dealing with one of the world's largest suppliers. Secondly, we're fortunate that the municipalities we collaborate with, KS (the Norwegian Association of Local and Regional Authorities), and central authorities have allocated resources for this work.
It's neither realistic nor necessary for you to assemble a project of this magnitude for every DPIA you conduct.
This newsletter is for those who see the resources we're using on this project and think, "Help, this is a bit much. If THIS is the standard, I'm afraid to start any other DPIAs!"
Why it's resource-intensive to assess a large supplier like google
Let's first explain why we're using so many resources on this DPIA. It primarily concerns what we're assessing (Google Workspace for Education) and who the supplier is (Google).
Google is a large supplier. They appear as a single company outwardly but actually consist of many different companies. For simplicity, services like YouTube, Google Search, and Gmail are made by entirely separate companies. This makes privacy compliance in the solution complex because it's quite difficult to get an overview.
Another aspect affecting you as a municipality and school owner is the response you get from your local community.
Several municipalities assisting in this DPIA report different questions and privacy concerns from parents regarding Google Workspace for Education, compared to tools from other suppliers.
And this concern doesn't come out of nowhere. For example, Google has been in the news for the Helsingør case. Additionally, other parts of the company have a business model based on processing personal data that many find quite intrusive.
This reputation of Google's privacy practices means we must scrutinize Google Workspace for Education more closely when conducting a DPIA. We need to ensure we have a complete overview. It takes time.
Differences between a "regular" DPIA and ours
Remember that a large and somewhat complicated system and service like Google is more challenging to assess in a DPIA than smaller systems, which are more common in schools. We assume Google's services and products in schools are more the exception than the rule regarding complexity and access to relevant information when evaluating a DPIA.
This means that usually, you don't need as many experts and resources to conduct a DPIA on other smaller systems. Also, remember that it's better to have done a DPIA with the resources you currently have than not to have done one at all.
Conducting a DPIA is a journey into the system, making you familiar with the product's strengths and weaknesses. This can provide a better basis for a more targeted implementation, focusing on what you really want to achieve with the available tools, rather than spreading everything out and letting users figure it out over time.
Hopefully 😊
We do much more than just a DPIA
So, let's clarify how what we do in the national DPIA project differs from the DPIA you have in your municipality. Firstly, we do much more than a DPIA.
In fact, we have several other deliveries in addition to the DPIA we need to complete by March 2024.
We will provide guidance on various issues arising from the DPIA. The most obvious guidance is related to taking the DPIA we create from an 80% version to a 100% version. In other words, how should each municipality proceed to get this DPIA approved? We've also created guidance on experience management, treatment protocol, and basis for treatment. These are activities you don't need to do when conducting a DPIA.
The DPIA we create will be used by many different municipalities with varying access to resources and expertise. This means we must simplify. And to simplify, we first need a complete overview that allows us to decide what we can afford to simplify.
This is something you don't need to consider when conducting a DPIA. You create a DPIA for your municipality and don't need to worry about it being understood by a neighboring municipality with far fewer resources at its disposal.
When we assess risk and come up with recommendations for risk-reducing measures, we try to ensure that our advice can be used by two municipalities that have set up Google Workspace for Education differently.
This is also not something you need to do when conducting a regular DPIA for processing personal data in your municipality. You just need to decide how your municipality has set up Google Workspace for Education. You can focus on completing the DPIA.
One last thing we do, which you don't need to do, is communicate to the outside world how things are going with your DPIA. We know many are waiting for us to finish this DPIA and are very eager to hear our recommendations. Therefore, it was essential for us to keep those curious updated along the way. We do this in these newsletters, our live broadcasts on LinkedIn, and publishing things we finish.
Advice for conducting a DPIA
So, to those who see what we're doing in this DPIA and think it's pointless to conduct a DPIA if you can't do it at this level, remember that our DPIA is not an example to follow. Even if you're conducting a DPIA of a large system, we have several additional activities in this project that you'll never need to do in a regular DPIA.
But even though our DPIA doesn't need to be an example to follow, we have some advice for those conducting a DPIA: collaborate with others on your DPIA!
Yes, collaboration makes things take a bit longer. But it can also take a really long time to do a DPIA alone. Many of us working in privacy and information security are quite isolated in many municipalities. Being solely responsible for conducting DPIAs is burdensome. And that loneliness itself can make you take longer.
Let's also emphasize that we understand the scarcity of resources and how challenging this can be. You conducting DPIAs in your municipality probably have several other tasks and roles in addition to privacy.
What you can take from our approach is that you can collaborate with others. This can look different. For example, you can assemble a team with different professional expertise to help come up with risk scenarios and assess privacy consequences.
Or you can collaborate with that really skilled professional in the neighboring municipality who is dealing with the same evaluations alone. Have regular working meetings where you do the job together or discuss issues.
Don't know any professionals in the neighboring municipality? We encourage you who are conducting a DPIA, big or small, to establish, participate in, and use local and regional networks like digitalization networks to discuss and collaborate.
I wish you a wonderful, privacy-friendly week-end!
Best regards,
Ida Thorsrud
Project manager national DPIA
This newsletter was translated from Norwegian to English with assistance from ChatGPT by OpenAI. While it guided our translation, we made independent editorial choices. Any discrepancies result from this combined approach.