[WG-InfoSharing] Issue with terms and referencing terms;

Mark Lizar - OCG m.lizar at openconsentgroup.com
Thu Mar 24 12:15:24 CDT 2016

Hi All, 

As I am editing the spec at the moment, I have come across a couple of issues with terms.  github issue #27 <https://github.com/KantaraInitiative/CISWG/issues/27>

First, as we no longer need to put the spec work forward to a standard development organisation to create a specification standard candidate I think its important to have all terms in the spec so that it is usable without having to reference external documents. 

Second, we have used the term PII as defined in IS0 29100, to refer to the consent grantee, or data subject.  It has occurred to me that the consent grantee doesn’t necessarily have to be identified, to provide both personal data and consent.  As well, we are working on consent centric focus and not necessarily an the basis that all consents require personal identifiable information. 

The ISO definition is
"personally identifiable information PII
any information (a) that can be used to identify the person to whom such information pertains, (b) from which such information can be derived, or (c) that is or might be directly or indirectly linked to a natural person.

NOTE To determine whether a PII principal is identifiable, account should be taken of all the means which can reasonably be used by the entity holding the data, or by any other party, to identify that individual. “ 

In this regard, I am wondering if moving to the term personal data would be suffice instead? 

Mark Lizar
Executive Director
Open Consent Group

Email: m.lizar at openconsentgroup.com
Mobile: +447738382658
Twitter: @smartopian

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