Hi !
It has been a while since you received an update on how far we have come and when we will publish the DPIA. We previously said "end of March," but now it's April, so it's time for a little update.
First things first: when will we be finished? We expect to publish the DPIA before the summer. We are still in the final stretch, and we are working on several things that you can look forward to. Let us tell you about them:
Third country assessments for Singapore and Taiwan
We are now working on the third country assessments for Singapore and Taiwan. We will publish them when they are finished.
It may take some time, but we will nonetheless have a new LinkedIn Live about the method we use in June. Save the date: Friday, June 14th, from 12-13 for this! This is for those particularly interested as we will delve deep into the 6-step model of the European Data Protection Board and their guidance on the standard "essentially equivalent."
We have gone back and forth on the method we use, and we have ended up with a much clearer opinion on how you can conduct a TIA. We are also working on a description of this method which we will share as well.
Guidance on the Right to Object The right to object is challenging.
This is particularly the case when the municipality's basis for processing is legal authorization. This because the right to object means that a student can object to the processing even though it is legal.
However, there is a difference between having the right to object and being successful in that objection.
Here we are working on a guide on how you as a municipality can distinguish between an objection, a complaint, and a request where the student asks for deletion. If you want to read the legal article where we explained this, you can find it here.
We are also working on a separate article about the method for the actual assessment, and a guide that is hopefully much simpler than the legal article.
The record of processing 2.0
We previously published a proposal for a record of processing for the core services in Google Workspace for Education. You can read it here.
Now version 2.0 is coming soon. Look forward to additional services being included, and that we will propose to also include a particular category of personal data.
What meta data can we share with our vendors?
One of the most challenging issues we have had in this project is the question of whether it is okay for Google (or another provider) to use metadata for its own purposes. This is the issue that is also up in the Danish Chromebook case, and we have previously written about it here.
We are about to also finalize this assessment. It will likely be part of the DPIA, and a legal article that particularly interested parties can take a look at.
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.