Listers,
On the topic of transparency - I somehow feel that the office of
the data protection commissioner should be required to publish
(preferably on the web) at least statistics on the number of
cases/complaints brought to them for various periods of time -
this way it would be easier to determine if the problem of
data-protection is growing.
I might argue that it should even be public which company the individual complaints are against so that it is possible for the public to take note of which companies they reliably can trust with their data.
On the topic of fairness I am deeply concerned that the
legislation is written only with "large data holders" in mind and
not SME's - In terms of requirements for compliance,
fee-structures, administrative-overhead. The burden may be too
large for startups and SME's and hereby limit innovation and
growth of new companies.
It might be more fair if the requirements increased as a result of
the amount of data you hold - i.e. if you hold data for less than
10000 individuals you may only need to provide a compliance report
to the office once a year. But if you hold data for more than
1million indidviduals then you need to report monthly/quaterly
etc.
Kind regards
Michael Pedersen
Listers,
please note that the bill is also hosted on the Jadili platform @ http://jadili.ictpolicy.org/docs/privacy-and-data-protection-policy-and-bill-,2018#heading-1 for your easy access.
Lets have your views so that what finally goes to parliament has stakeholder support with less risk of court-cases ;-)
walu.
On Wednesday, August 22, 2018, 10:47:31 AM GMT+3, kanini mutemi via kictanet <kictanet@lists.kictanet.or.ke> wrote:
_______________________________________________Day 1- Principles of Data Protection
Dear Listers,
As GG had indicated on Monday, we will hold online moderated discussions on the policy and regulatory framework on privacy and data protection. I will kick us off with a discussion on the proposed principles of data protection (Part 5 of the draft policy and Part IV of the draft bill).
There are seven proposed principles–
(a) Fairness, lawfulness and transparency
(b) Purpose limitation
(c) Data minimisation
(d) Storage limitation
(e) Accuracy
(f) Confidentiality and Integrity
(g) Accountability
To begin with, I welcome comments on
-what is your first impression of the principles?
-why do we need to set out principles?
-are the principles clearly defined in the draft policy and bill?
Tujadiliane!--
Mercy Mutemi.
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