This is a trip report on my attendance at the Computers, Privacy and Data Protection Conference in Brussels, Belgium May 21-24. My ambassadorship involves the development of a privacy best practice framework for the instantiation of the ILP, which ILF can recommend to all innovators, and perhaps require from those they fund. It is important that this open source technology be viewed as ethical and respecting of human rights and data protection best practices, whether or not it is being used in jurisdictions or content areas that are subject to privacy legislation.
Arguably the foremost privacy conference in Europe is the Computers, Privacy and Data Protection Conference (CPDP, https://www.cpdpconferences.org/) so I wanted to attend this year to meet with representatives of the data protection community, whether from academic, regulatory, or civil society groups. The theme this year, unsurprisingly, was Artificial Intelligence (AI)....most sessions were on this topic in some form or other. This did not matter much to me since my purpose for attending was to socialize the problem that I am researching and find out who is knowledgeable about, interested in, or researching into open payment systems. Unfortunately, I did not discover a treasure trove of existing policy, but there is definitely interest and I made some good contacts to get in touch with those who are working on the issues.
Those who are interested can check out the recorded sessions here:
https://www.youtube.com/@CPDPConferences/videos
Here are a few of the highlights of my chats.
• I had arranged to meet with the Secretary of the Council of Europe Data Protection Unit. They have just produced privacy guidance on complying with Know Your Customer regulations, which I am incorporating into the best practice framework (https://rm.coe.int/t-pd-2021-8rev8-aml-cft-guidelines-en-final- 2772-7823-8984-1/1680abdb4d). We discussed various venues to introduce data protection authorities to the topic of open payment system privacy issues, which civil society groups might be active in this area, other multilateral organizations that could be looking at regulation, and the activities current within the EU.
• I met a number of academic colleagues, and from them got contacts of academics who are writing on this matter with a privacy lens. I have a visit to my university library planned to run some of these leads to ground for my report. A reading list would be a useful item to add to my project, since there is a dearth of information available.
• I spoke to a couple of well-placed and respected US privacy lawyers, who expressed great reservations about any legal framework or best practice framework that was not the work of expert financial data privacy lawyers. I must emphasize that any framework I develop will be recommendations for best practice, not legal advice. Data protection law will not apply to Interledger itself in these instances, either as a body subject to law or as their recommended best practices being construed as legal advice. However, Interledger must take its liability issues very seriously. I am not a lawyer, the report will emphasize compliance with law. All regulatory requirements vary from place to place but we will stress that they have to be respected. Frankly though, given the inadequacy of current privacy law in protecting individuals with respect to their financial affairs, we are trying to promote a higher standard of human rights, ethical and nondiscriminatory behaviour, and fair pricing.
• There were not many civil society folks present, possibly representing the dismal state of funding at the moment. I spoke to a few and came up with a couple of leads as to who is actually looking into payment schemes and privacy.
• I asked just about everybody I encountered if they had seen a good summary of the costs, fees, any analysis of the dynamic pricing that seems to occur in some of the large payment processes (eg. Paypal, Western Union) but did not come up with a good source of information. If anyone knows where such a price and profit breakdown exists, please contact me.
• On the opening night of the conference, during awards for work in AI presented by the Center for AI and Digital Policy (https://www.caidp.org/) we heard and saw a wonderful presentation by artist Vladan Joler who works on visualizing in 3D the dataflow of personal information/AI. I highly recommend having a look at his work, https://futureeverything.org/profile/vladan-joler/, nothing is as complete as the presentation he gave us, which was enormous, but the map of AI listed on this site gives you some idea of his work. I have found that visualizing the dataflows in payment systems is very challenging, I wish he would draw a map of open payment systems next!
I am happy to chat with anyone who is interested in what I observed at this conference. I think it was well worth attending. A conference book will eventually be forthcoming, but not before my ambassadorship ends.
Stephanie Perrin stephanie@digitaldiscretion.ca
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