Between 18 and 27 May 2020, the Brussels Laboratory for Data Protection & Privacy Impact Assessments (d.pia.lab) – a sub-group within the VUB-LSTS – has delivered a training on the concept of impact assessment for the members of the research consortium of the PERSONA (Privacy, ethical, regulatory and social no-gate crossing point solutions acceptance) project, of which the VUB is the coordinator. The PERSONA project – funded by the European Union – aims to develop and test an integrated and tailored impact assessment method to be used by public authorities to appropriately assess the consequences of new no-gate crossing point solutions that these authorities plan to deploy at state borders. The said method will be called ‘I AM PERSONA’ and will eventually be published in a handbook, due in early 2021.
Generally speaking, impact assessment is ‘tool’ to analyse the possible consequences of an initiative for relevant societal concerns with a view to supporting an informed decision on whether and how to deploy the initiative. To bear fruit, the process of impact assessment needs to follow an appropriate method. In the PERSONA project, such a method is tailored down to the reality and needs of border control and analyses, in an integrated way, four societal concerns, namely: privacy, personal data, ethics, and societal acceptance and acceptability.
In the PERSONA project, the assessment method is being developed in a collaborative process. While the d.pia.lab, building on its expertise (cf. a ‘framework’ and a ‘method’ for impact assessment), has already offered an initial version thereof (cf. Deliverable D3.1), the method is currently being refined. A part of this refinement is to test the draft assessment method in practice. To that end, in the second half of 2020, the PERSONA project will organise three-partite ‘test studies’ (cf. Deliverable D4.1) and therefore the consortium partners charged with executing these ‘test studies’ (i.e. border control authorities: SMOI of Serbia, MOPS of Israel and SPA of Sweden) needed to familiarise themselves with the concept of impact assessment. The results of these ‘test studies’ will then allow for the d.pia.lab to refine the assessment method for its final version.
The training was met with a considerable interest and further confirmed the need of such authorities to know precisely how to carry out various types of impact assessment, especially given the need for respect of democracy, the rule of law and fundamental human rights in the context of border control, as well as the fact that at least one type thereof – i.e. data protection impact assessment (DPIA) – is now mandatory in certain situations both under the General Data Protection Regulation (GDPR, 2016/679) and the Law Enforcement Directive (LED, 2016/680) in the European Union (EU).
The training was offered on-line (due to the current sanitary crisis), in English, in 4 sessions of 2 hours each, by a team composed of d.pia.lab members: Prof. Dr. J. Peter Burgess, Dr. Dariusz Kloza, Alessandra Calvi, Simone Casiraghi and Nikolaos Ioannidis with the assistance received from Irina Baraliuc and Ioulia Konstantinou. The materials therefrom (i.e. the agenda, presentations, reading list and the case study) are freely available here.
This training was offered for the first time and hence the d.pia.lab welcomes comments and feedback so that it could improve it in the future; please send an email to firstname.lastname@example.org.