Privacy Impact Assessment

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Click here to download the interim PIA from 80/20 Thinking (PDF)

We're pleased to be able to release the interim Privacy Impact Assessment that we've referred to in interviews and our live chats on Webwise. Simon Davies, Managing Director of 80/20 Thinking, conducted the Privacy Impact Assessment with his colleague Gus Hosein, who is Visiting Fellow, Information Systems Group at the London School of Economics (bios below).

The Privacy Impact Assessment is a review of Phorm systems and policies. Since this preliminary, initial report was written several weeks ago, we have addressed several claims in it. Among them, we have confirmed to 80/20 Thinking that Webwise does not track behaviours across sensitive sites; that anonymous cookies cannot be traced back to users; and that Webwise deliberately ignores "https" pages used by banks, and other personal data. We will work with 80/20 Thinking on an ongoing basis throughout the year to complete the assessment and ensure we confirm our leading privacy standards.

In the press, Mr Davies has openly commented: "In our view, Phorm has implemented privacy as a key design component in the development of its system. In particular, Phorm has quite consciously avoided the processing of personally identifiable information." In particular, Mr Davies told BBC News: "Phorm does advance the whole sector of protecting personal information by two to three steps."

We certainly want to be clear: Privacy International, one of the leading privacy advocacy bodies, did not endorse us and do not endorse any companies. We engaged Mr Davies (founder and director of Privacy International, though not acting in that capacity to produce the report) because of his expertise and experience. He has spent decades railing against infringements of privacy. We expect that he and his team in a consulting capacity would apply the same intellectual rigour to their assessment of companies that they do in campaigning for privacy rights.

As a consultancy, 80/20 Thinking conducts audits for companies and it charges a fee to do so. Audits take time and resources, as the one conducted by Ernst & Young (View report PDF), and we haven't yet found a free audit service that is worth our trust or anyone else's.

We await a date for the final Assessment to be issued and will update this page when we know.

Who conducted the report

Simon Davies
From his bio listed on the EPIC site:
"Simon Davies is one of the world's leading figures in privacy and data protection and has worked in more than 30 countries on issues ranging from identity cards to military surveillance. His work in privacy, data protection, consumer rights, policy analysis and technology assessment has spanned more than twenty years. Simon's role as founder and director of the watchdog group Privacy International has put him at the cutting edge of privacy across the full spectrum of issues. His expertise in identity and identity systems, in particular, has been called upon by many of the world's intergovernmental organisations and parliaments. The UK based Privacy International, now with members in more than 40 countries, was founded in 1990 and is a strong voice for privacy reform across the world.

"Davies is also the founder of the Big Brother Awards, a prize now given internationally to organizations and individuals who commit particularly flagrant violations of the right to privacy. Since 1997 Simon has been a Visiting Fellow in the Department of Information Systems of the London School of Economics. He has also been a consultant adviser to numerous government, professional and corporate bodies in Europe and North America. His publications include Privacy and Human Rights 1998: An International Survey of Privacy Laws and Developments, by David Banisar and Simon Davies (1998) and Big Brother: Britain's Web of Surveillance and the New Technological Order (Pan Books, 1997)."

Gus Hosein
From his bio listed on the London School of Economics site:

• Visiting Fellow in the Information Systems and Innovation Group in the Department of Management at the London School of Economics and Political Science
• Senior Fellow at Privacy International
• Visiting Scholar at the American Civil Liberties Union project on Technology and Liberty.
• Co-Founder (with Simon Davies) of the LSE-funded Policy Engagement Network. PEN is currently running projects on internet governance, identity policy, and constitutional change. He also consults for governmental and inter-governmental institutions.
• Chartered Fellow of the British Computer Society
• Chartered IT Professional (FBCS CITP)
  
  Academic Qualifications:
• PhD in technology policy and regulation from the University of London
• MSc in Information Systems Security from the University of London
• B.Math (Hons) from the University of Waterloo in Canada