We're pretty much on track, and as you can see, our original plan is to finish the DPIA by March 2024. It's possible that parts of the DPIA might not be completed by then, but we'll keep you updated through this newsletter.
However, this newsletter isn't just about showcasing our plan to emphasize how good we are at sticking
to it. Not entirely, at least.
Those of you who have worked according to a plan know that a plan is a starting point, and it needs to be adjusted when it meets reality.
What we want to discuss in this newsletter is how we've genuinely used time to our benefit. How working on the national DPIA over time has been essential to understand the contoller's actual needs, so that we produce a final result that actually help the contoller.
Our expectation as experts that we should work fast
Even though many of us working on the project are experts in our respective fields and have a lot of experience with privacy, DPIAs, and everything related, the project has been a significant learning process for us too.
As experts, we tend to want to rush forward. After all, we are the experts, and many of us have an internalized expectation that we should already know the answer. That what we're doing should be so easy for us, that we should have already finished.
But that's not how we, as humans, operate. Things need time to mature and progress take sits own time. Even when you're an expert. Let's illustrate this by discussing how we've worked with features in Google Workspace for Education.
Progress takes its own time
When we first started working on the national DPIA, we quickly realized we needed to do something about «features».
Initially, it was unclear to us what «features» meant. Our understanding at the time was that it referred to functionality in Google Workspace for Education, and that this functionality could change rapidly.
Bergen municipality had already tried to get an overview of how many «features» existed in Google Workspace for Education, but it was challenging to get a complete overview.
As previously mentioned, we knew we had to «do something about features», but we didn't know what.
Should we view «features» as a processing of personal data? Was it essential for the municipality to have a complete overview of the functionality in order to know what personal information they processed? Should we make a complete overview of all features?
We concluded that no, it wouldn't be practical to create an overview of all features since that overview would become outdated almost as soon as we finished it. This is because new functionality in the form of «features» is continously rolles out.
And right here, we began to understand what we had to «do about features»: We needed to figure out how the data controller should set themselves up to handle such changes. Yes, this was about ✨change management✨.
When you purchase a system like Google Workspace for Education, you're not buying something static. The system gets updated and changed, and it requires that you, as a controller, can manage these changes.
For us, this meant that what we should do about features, had nothing to do with getting an overview, but everything to do with what the controller needed to have in place to manage a system like Google Workspace for Education that is constantly changing.
If the change is significant enough, the controller have to determine if the overall risk that the controller face has also changed. If it has, your DPIA or risk assessment might need an updating.
And if it's a minor change, it can still have consequences that you need to address. For instance, a change might mean that Google has altered the default settings so that an additional service you've decided not to use is actually turned on. It might not pose a significant risk, but it's still a situation that you as the data controller have to control.
The point is: the realization that features were about change management, was an insight we wouldn't have had if we had rushed the process. We took our time and it payed off!
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.