=Paper=
{{Paper
|id=Vol-3114/paper5
|storemode=property
|title=Using the SQuaRE series as a guarantee for GDPR compliance
|pdfUrl=https://ceur-ws.org/Vol-3114/paper-05.pdf
|volume=Vol-3114
|authors=Alessandro Simonetta,Maria Cristina Paoletti,Alessio Venticinque
|dblpUrl=https://dblp.org/rec/conf/apsec/SimonettaPV21
}}
==Using the SQuaRE series as a guarantee for GDPR compliance==
Using the SQuaRE series as a guarantee for GDPR compliance Alessandro Simonetta Maria Cristina Paoletti Alessio Venticinque Department of Enterprise Engineering Rome, Italy Naples, Italy University of Rome Tor Vergata mariacristina.paoletti@gmail.com ORCID: 0000-0003-3286-3137 Rome, Italy ORCID: 0000-0001-6850-1184 alessandro.simonetta@gmail.com ORCID: 0000-0003-2002-9815 Abstract—In a context where the availability of information [4], could be frustrated due to poor data quality. represents the opportunity for companies to gain a competitive An example is the algorithm used in Florida [5] to score advantage in the market through the use of sophisticated AI the risk of reiteration for people who went in jail that was algorithms, data quality assumes a strategic role. With this paper we want to show that the adoption of an international subject to bias due to the wrong composition of the data used quality measurement standard such as the one present in the to trainee it and the features selected. Indeed, the algorithm SQuaRE series can on the one hand improve the ethical aspect for calculating the score was trained on a dataset where of machine learning algorithms and on the other hand meet the the criminals were unbalance towards black people and the requirements imposed by the European Community regarding weight given to the past record of crimes committed and their the protection of personal data of citizens in Member States (GDPR). Indeed, although the attention to the protection of importance was not properly set. Therefore, where this risk personal data is mainly directed towards the aspects of security assessment tool of dangerousness and re-offense risk was used and confidentiality, in a holistic view we should also evaluate African Americans scored higher in criticality compared to the risks arising from the absence of quality in the data. In Caucasian ones based on the skin color also if their records this context, we consider consistent and of reference for the were less critical. international community the choice of the Italian legislator made for the Public Administrations. Since 2013 the Agency for Digital This case study tell us the importance of the training data Italy (AgID) has suggested the adoption of ISO/IEC 25012 set and their quality and the great impact that can have on for public administrations in charge of managing databases of business decision or citizen life, especially if we concentrate national interest. In the article, we propose a methodological our study on the use that could do public administration or approach that ensures the governance of data quality and private companies about the people data. some open questions regarding the homogeneity of the selected measures. Attention to the use of data, its collection and its quality Index Terms—ISO 25000, ISO 25012, ISO 25024, SQuaRE is a very important issue also in Europe, where for years series, GDPR, data quality, COVID-19 the legislator has been addressing these issues and investing resources to align regulations with the problems arising from I. I NTRODUCTION new technologies and new business models [6]. An important According to The Economist [1], the data represent the new step taken in Europe is the introduction of the General Data oil for the modern business, not only related to the IT services, Protection Regulation (GDPR) 2016/679 [7], defined to har- but also for what concern the business decision and the monize the data privacy laws among the European countries marketing campaigns. Many companies are investing in data and, in order to remodel the methods and the approaches that analysis, machine learning based algorithms and in solutions the organizations manage the European citizens’ data. chosen through data driven approaches. In this scenario they The full compliance to this regulation in the past was ad- are realizing that the success or their investment are based dressed mainly focused for what concern security issues, but not only on the amount of data, that however is an important aspect as compliance, integrity and correctness of data are aspect, but mainly on their quality. This could have an impact now becoming central. In [8] some issues linked to GDPR on the results of machine learning algorithm that are subject are addressed and in particular the compliance of data man- to bias on results if the dataset is not properly chosen or have agement and usage for business process. The paper propose quality problems, i.e. contains unbalanced data. These issues three solutions to reduce data maintenance and information are more evident if the techniques used are taken to extreme as loss, avoiding degradation through data minimization during for example in [2] where the use of approximated computing the course of business process. The work covers only part for low power neural network could be more subject to of the accountability principle in that it is not concerned errors. Furthermore, the benefit of using methodologies such as with monitoring and measuring the quality of and maintaining Reinforcement Learning, to contrast the degradation of results the correctness of the data, but addresses the problem of and to distribute the decision system as reported in [3] and in degradation about information over the time to ensure that Copyright © 2021 for this paper by its authors. Use permitted under Creative Commons License Attribution 4.0 International (CC BY 4.0). the data once processed is usable for business purposes, in and adequacy of the data used (art. 104 [12]). In addition, accordance with regulations, even if some of it loses its insurance companies must provide for a regular cycle of correctness. validation of their internal model that includes assessment of These aspects are taken into account also in [9] that deals the accuracy, completeness, and adequacy of the data used in with the problems of GDPR compliance in use of Public the internal model (art. 124 [12]). Geographic Information System for research and practice. In this scenario, where regulations require to ensure certain The team apply the pseudonymisation to GIS information to characteristics related to the management and maintenance of guarantee the privacy of the users that share their data. the data over time, many efforts are directed towards ensuring In [10] the OpenEHR standard is proposed to address some a high level of security for information management, thanks requirements of data privacy regulation. It gives a guideline to the application of the ISO/IEC 27000 series [13], but to guarantee that software for electronic health records are fewer organizations are concerned about managing the risk interoperable and secure. The health domain is very sensi- associated with their management and quality. A good solution tive to data quality since the effects of a minimum error could be the application of the ISO 31000 series [14] which can cause irreparable damage with death or serious injuries. provides principles, a framework and a process for managing However, the work addresses the requirements of integrity and risk. In section II we describe the state of the art related to the traceability related to data quality; the proposed versioning SQuaRE approach to data quality assurance and what benefits assure the indelibility of the clinical record preventing any are recognized from its adoption in several case studies. A information from being deleted. The creation of a new version focus will be made on the implications of COVID-19 on the of the electronic clinical record is important against the lost, application of GDPR in the health field. In section III we destruction or accidental arm of data. This is only a part of the will present the extension of Italian institutions’ approach to data quality and a section of the requirements that sensitive data quality and we will extend it as a solution to be adopted information must meet, it does not define KPI or measurement by private organizations, also as an indispensable support to process. Furthermore, the paper is concentrated on clinical data demonstrate full complaince to GDPR. In section IV we will only and miss to consider other information as personal data identify the limitations of this work and how we intend to accuracy that are an important issue. In [11] more details on address them in the future. Finally, in section V we will present data quality are presented, and a clear picture of the problem concluding remarks. affecting clinical records is reported. However, the study focus II. S TATE OF A RT only on medical information and is not easy to standardize and applicate to different domains. A. GDPR Data Quality Compliance in COVID-19 Pandemic According to GDPR, each processing of personal information The pandemic emergency boosted the digitalization and the must be performed in accordance with the quality principles use of online services. The smart working catching on many established by art. 5 (adequacy, correctness, update, security, organizations highlighted problems related to data privacy and protection, integrity) following the requested criteria of ac- data quality, especially for what concern issues that clash with countability of the data owner. He must guarantee not only the need for infection tracking. New type of communication the respect of these principles, but also the evidence that he and workflows are been developed and adopted during this applied all the actions to protect the data (art. 5, par. 2 and time with the objective to be accepted by worker and to art. 24, par. 1). The regulation assigns specific obligation to transmit them trust in data management and security. A central the responsible for the processing, different compared to those point in this new situation is the compliance of all the data to identified for the owner, and in particular the implementation GDPR. Many organizations had problems related to guarantee of appropriate technical and organizational measures to ensure its requirements and to manage the information in the right the security of the treatment (art. 32) through the concepts of way. confidentiality, integrity, availability, resilience and ability to Scientific papers address different aspects of the consequence restore. of COVID-19 pandemic emergency on data privacy and pro- The GDPR is not the only regulation in which quality charac- tection in these two years. In [15] a literature review is pre- teristics (accuracy, completeness, correctness, up-to-date, se- sented about publications that explore the effect of the COVID- curity, protection, integrity) are reported with a clear meaning 19 outbreak on GDPR compliance. The work identifies some but difficult to compare in the absence of a common metric de- critiques of the regulation and in particular, it focus on the scribed by a calculation algorithm. Indeed, even the European ethical use of health data during the pandemic. Furthermore, Solvency II regulation [12], establishes the need for insurance the infrastructure use and the absence of controls let the companies to have internal procedures and processes in place possibility of cross border transfer of data outside the Europe. to ensure the appropriateness, completeness and accuracy of These aspects are treated also in [16], where the authors study the data used in the calculation of their technical provisions the use of personal information for research activities to defeat (art. 82 Data quality and application of approximations, in- the COVID-19 and some criticalities linked to specification cluding case-by-case methods, for technical provisions). When of GDPR. The normative has foreseen procedures to support granting the basic solvency capital requirement of approval, research in pandemic and the processing of sensitive data, insurance supervisors must verify the completeness, accuracy, included personal and health, but the derogation of some aspect to national laws is an obstacle to a coordinated global that can be used within the measurement framework of the research. This work enhance also the lack of a framework that serie SQuaRE. The integration of the proposed metrics into support the proof of compliance of data management to desired the data preparation pipeline for machine learning with the requirements. A particular case of this problem is studied in analysis of intrinsic properties of dataset could anticipate the [17]. The paper describes the problems linked to traceability emergence of discriminatory behavior of algorithms that in application offered by mobile devices, Android and iOS based, particular case may contravene laws or infringe human rights. to monitor the contacts between people and infections. The Nowadays, the most successful organizations are those who European legislation is analyzed with respect to sector-specific are able to collect data, select the right set and guarantee the international rules, as the US Health Insurance Portability and best quality. Their decisions follow a data driven approach Accountability Act (HIPAA), highlighting the pros and cons and if the basis are wrong, the strategies implemented and the of its flexibility in responding to critical health situation. services offered will be affected with negative consequences. These scenarios show that the action to protect data and the Therefore, organizations to be confident with the results of compliance to regulation is often unfulfilled due to the lack of their processing must trust their data. To achieve this level a common guidelines and the heterogeneity of normative. of confidence organizations are implementing the regulation Although, it is reported that data accuracy is a non-core present into the standards and applying process and frame- aspect of data privacy, individuals have the right to correct work. Many of them are applying data quality evaluation inaccurate or incomplete personal data that is processed. Using process and data quality management in order to obtain the SQuaRE series as a data quality measurement standard and certification for their repositories and not only for the software in order to support GDPR compliance provides for a single ref- that they use to process them. In [23] are reported three case erence with respect to individual national regulations helping studies of data quality evaluation and certification process to harmonize the application of legislative specializations in about repositories. An independent entity verifies and certifies different countries. that the company’s database complies with the requirements defined in the regulation. The organizations are different each B. The SQuaRE Approach other for what concern dimension and business domain. The In this section, in order to support our work, we report an two visions are analyzed to evaluate the impact of the adoption extensive scientific production that focuses on the application of the ISO/IEC 25012, ISO/IEC 25024 and ISO/IEC 25040 of data quality standards and in particular the SQuaRE series to [24] and their benefit recognized in the three organization achieve measurable and well-defined goals. Such approaches before and after the process. The case studies consist, for form the basis of our proposal that aims to achieve full each of them, of two phases. The first evaluate the data GDPR compliance by achieving the right level of accuracy quality and address the issues found; the second consist in and satisfying the entire data quality characteristic by applying another evaluation on the improved databases to obtain the the SQuaRE series. certification. The results show that applying their methodology Some studies propose a framework for data quality evaluation helps the organization to get a better sustainability in the long to let organizations to be able to support and maintain data term, improve the knowledge of the business and drive the quality. In [18] the described framework is based on ISO/IEC organizations in better data quality initiatives for the future. 25012 [19] and ISO/IEC 25024 [20] and consist of a software An element often found in these articles is related to the use that recognize several patterns that identify common failures of open formats for archiving aspects to promote portability of organization and help to evaluate the KPI defined for this regardless of the technology used. These are all concepts patterns obtaining a clear picture of the data quality. Small defined in the SQuaRE series. organizations could be not prepared in the application of the standards to their data. The framework presented and the tools, that are starting to spread, represent a solution, that, III. T HE S OLUTION P ROPOSED if widely adopted, can help such companies to guarantee the compliance to the standards with advantage for services results and business decisions. Previously, we have shown that there are ambiguous The problem of data quality and in particular of bias present interpretations about characteristic of data quality linked to in dataset used for machine learning algorithm is studied in regulations and laws that lead to heterogeneous approaches [21]. This type of systems go under the name of Automated and uncertainty in the level of adherence to the requirements Decision Systems (ADM) as described in [22]. These are tools that must be met. These issues are addressed by scientific in which the decision is taken by an AI algorithm in autonomy. works that, also with the support of some case studies, The use of algorithms in software involves aspects of daily manage to define methodologies and processes to achieve a life such as the marketing campaigns to suggest to customers high level of data quality through the application of standards. on a web platform. The work aim is to verify the balance of In the following we will show our proposal starting from the dataset before it will be used in prediction algorithm and it what has been done by the Italian Public Administration to cause discriminatory problems. The paper defines metrics with achieve the levels of data quality it needs. the dual purpose of identifying bias and providing solutions A. Italian Digitization Process In Italy, the process of modernization and digitization of the Public Administration began with the Digital Administration Code (Legislative Decree n.82 of March 7, 2005), which states that public administration data must be made available and accessible with information and communication technologies that allow their use and reuse. In 2013, AgID (Digital Italy Agency) with the resolution n. 68 defines, for databases of national interest, the compliance with the quality characteristics defined in the international standard ISO/IEC 25012 ”Data quality model”. Fig. 1. Data Quality Governance. The adoption of the standard for databases of national interest is thus the reference for both the Public Administration and private companies, also in order to enhance the value of infor- The measurement process can take place through commercial mation assets and improve the quality of services offered and software or, more simply, by building a set of modular queries, their efficiency. The adoption of this data quality governance reusable and moldable on different realities depending on the system responds to their growing need for dissemination and model identified. The evaluation of the results must be carried transparency of the information processed. At the beginning, out by an expert who assesses the level of quality achieved the AgID, in order to simplify the adoption of ISO/IEC 25012, at the end of each iteration and the progress of the same, had identified a minimum set of characteristics (accuracy, at various levels of granularity, over time. The organization completeness, consistency and currentness) from which to start has to implement, if needed, improvement actions to mitigate and then extend to the entire set. Moreover, in the following risk and improve services through greater IT efficiency and years through the Three-Year Plan for Public Administration, enhancement of data as an asset. an essential tool to promote the digital transformation of the C. Expected Results Italian Public Administration, the importance of the use of ISO/IEC 25012 is reaffirmed. The application of the proposed approach allows the organi- In particular, in the Plan for the three-year period 2020-2022 zation to measure the quality of their data and to identify issues [25] AgID promotes the increase of data and metadata quality related to their acquisition and management. The organization (OB.2.2) of which the increase in the number of open datasets can have the possibility of quality controlled and certified in- conforming to a subset of quality characteristics derived from formation. The automatization of data management and control the ISO/IEC standard (R.A.2.2b). eliminates manual queries and cleaning operation. High quality data support the collaboration and the exchange of information B. Method between internal and external company structures. The proposed approach is based on four main phases On the other hand, if organizations do not control data quality, (Fig. 1): the initial design, the exercise of the measurement they may not only be exposed to bias in sensitive data due to process, the evaluation of the obtained results, and the last incomplete dataset, but are also subject to different types of phase about the identification of improvement actions. In the risk [26]. initial design phase we need to choose the reference context The methodology proposed in this paper allows the organiza- (conceptual, logical and physical level), we define the quality tion to demonstrate that all activities have been put in place requirements and the quality model of data to adopt. During to control and properly manage the data. this phase it is evaluated the opportunity to reduce/extend the The application of a standard capable of supporting the achiev- model (override/overload of characteristics and/or measures) ing the quality objectives common to the public and private and identify the target entities in the appropriate phase of sectors, allows to trace a collaborative direction between these the data life-cycle. Fig. 2 shows the relationship between two actors, establishing a virtuous cycle where the application the data quality characteristics provided in ISO/IEC 25012 of the same principles makes it easier for both the verify and and the GDPR principles, noting that these relationships have the prove of compliance with certain national or European been highlighted as examples and depend on the context rules. of application. Since each quality characteristic is calculated through the sum of the contribution of several sub-measures, IV. LIMITATION AND FUTURE WORKS each organization can choose to give more or less importance In this paper, are not considered problems linked to the to individual contributions by assigning a weight to them. traceability and the validity of the source of information In addition, if we consider comparing different quality charac- that can play a key role in automate the process of data teristics, we may find a different granularity of the constituent controls over the time. In a scenario where the organization contributions to the measures. In this case, the organization has traceability on the source of its data or part of it, and may choose to adopt new sub-characteristics or select a subset can easily know its validity status, it can automate the of them in order to make the measurement system balanced. measurement of its quality and take action to meet its targets. Fig. 2. Relationship between ISO/IEC 25012 characteristics and GDPR principles As we presented, the data integrity has great importance The Ethereum Virtual Machine (EVM) provide the services in those applications where the quality of the services is to publish the smart contracts on the Ethereum blockchain. linked to the composition of dataset. The correctness and These can be used to store variables within them, which in the absence of malicious acts is paramount to avoid that our case can be the data or information related to them. If organizations can offer a wrong results to their customers on the one hand this allows to validate the contents in the or make wrong business decision. The spread of services blocks through automatic operations, public and shared, there based on corrupted data could distribute misinformation and is a limitation in the use of the blockchain due to the size of compromise compliance with the directives. the transactions because of the content that you want to put In order to get this target we will evaluate in our future in the blocks. In particular, it is difficult to ensure that every work the use of blockchain technology. Its use is starting to participant agrees to and complies with the relevant rules be analyzed especially for domain as healthcare and food on personal data protection in public blockchains. Aspects and beverage as reported in [27]. In this approach, the data such as a data principal, a data fiduciary, or a data processor are distributed over a network of nodes that approve the on a blockchain network have no clear demarcation.The correct transaction, with a consensus algorithm, and reject the compliance of these aspects with the GDPR and how the malicious one. This architecture guarantee the absence of a SQuaRE series can help to solve them will be discussed single point of failure and of central control that could be a in more detail in future works due to their complexity of point of attack. The data are stored in chain of blocks, where treatment. each of this contains the data, a timestamp and the hash of previous block. If the data inside a block is changed, its hash V. C ONCLUSION will be different from the hash stored into the chain, so the blocks will be invalidate. GDPR compliance is well addressed by following compli- These features are what we need to guarantee the integrity and ance with the ISO/IEC 27000 and ISO/IEC 31000 series, how- the validation of data and between the different methodologies ever the lack of quality in some features mentioned in art. 5 that implements the blockchain we will consider the use of of the GDPR can lead to errors that impact European citizens. the Ethereum and his smart contracts functionality. These For example, a health recall campaign for a cancer prevention smart contracts enforce a contract or an agreement between screening sent to an outdated residential address causes harm parties through code without the use of an authority. to the citizen who is not reached by the communication. 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