I was studying this ‘old’ idea of mine of drafting some form of impact-based criteria for data sensitivity when, along with a couple of fundamental logical errors in some of the most formally adopted (incl legal) standards and laws, I suddenly realised:
In these times of easily provable easy de-anonymisation of even the most protective homomorphic encryption multiplied with the ease of de-anonymisation throught data correlation of even the most innocent data points, all even the most innocent data points/elements must (not should) be classified at the highest sensitivity levels so why classifiy data ..!?
This may not be a popular point, but that doesn’t make it less true.
In similar vein, in European context where one is only to process data in the first place if (big if) there is no alternative and one can process for the Original intent and purpose only,
To prevent data from unauthorised disclosure internally or externally, without tight need-to-know/need-to-use IAM implementation, one already does too little; with, enough.
That’s right; ‘internal use only’ is waaay too sloppy hence illegal — it breaks the legal requirement for due (sic) protection, and if the use of data is, ‘by negligence’ not changing a thing here, let possible, the European privacy directive (and its currently active precursors) do not allow you to even have the data. This may be a stretch but is still understandable and valid once you take the effort to think it through a bit.
Maybe also not too popular.
Needless to say that both points will not be understood the least by all the ‘privacy officer’ types that have rote learned the laws and regulations, but have no experience/clue how to actually use those in practice and just wave legal ‘arguments’ (quod non) around as if that their (song and) dance is the end purpose of the organisation but cannot answer even the most simple questions re allowablity of some data/processing with anything that logically or linguistically approaches clarity. [Note the ‘or’ is a logical one, not the sometimes interpreted xor that the too-simpletons (incl ‘privacy officers’) interpret but don’t know exists.]
OK. So far, no good. Plus:
[Not a fortress, nor a real maze once you see the structure; Valencia]