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What to include in disclaimer and privacy policy of IoT devices and services?



The 2019 Stack Overflow Developer Survey Results Are InWindows 10 Eula Privacy RightsDo I still have to include data owner in privacy policy if I do not collect any data?Can I make a privacy policy on my own for free?User consent required under GDPRUsing Personal data before consentIs Google's privacy policy compliant with GDPR for the data processing agreement between a controller and a processor?Is Facebook Invading My Privacy?Changes to the privacy policy that require the user's consent: GDPR complianceShould I have a privacy policy on my personal website?EU Cookie Law: Consent required in addition to accepted privacy policy










0















IoT allows any devices to connect to a server which collect sensitive privacy data such as whether or not you are at home etc.



What are the main consent of users that need to be addressed when it comes to IoT devices?










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    0















    IoT allows any devices to connect to a server which collect sensitive privacy data such as whether or not you are at home etc.



    What are the main consent of users that need to be addressed when it comes to IoT devices?










    share|improve this question














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      IoT allows any devices to connect to a server which collect sensitive privacy data such as whether or not you are at home etc.



      What are the main consent of users that need to be addressed when it comes to IoT devices?










      share|improve this question














      IoT allows any devices to connect to a server which collect sensitive privacy data such as whether or not you are at home etc.



      What are the main consent of users that need to be addressed when it comes to IoT devices?







      privacy disclaimers






      share|improve this question













      share|improve this question











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      asked Aug 16 '16 at 5:13









      NikNik

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      1086





      bumped to the homepage by Community 7 mins ago


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          I've just started reading about privacy in IoT therefore I thought I might give you some pointers (my day to day work is spent on making privacy policies and their management for websites and apps easier at iubenda).



          I think reading through any privacy by design principles might be the best start.



          I'm citing from a worksheet published by a Pan-European entity called the Article 29 Working Party (which I will link to at the bottom of this answer):




          In particular, users must remain in complete control of their personal
          data throughout the product lifecycle, and when organisations rely on
          consent as a basis for processing, the consent should be fully
          informed, freely given and specific.




          Consent on IoT devices isn't really a simple matter.



          For example, displaying a privacy policy document on your site is not sufficient. The FTC recommends (relevant for US based activities) that you find a way to present privacy notices and multiple choices of levels to customers, including in the set-up or purchase of the IoT device itself.



          Again, here is the Art 29 WP




          In addition, classical mechanisms used to obtain individuals’ consent
          may be difficult to apply in the IoT, resulting in a “low-quality”
          consent based in a lack of information or in the factual impossibility
          to provide fine-tuned consent in line with the preferences expressed
          by individuals. In practice, today, it seems that sensor devices are
          usually designed neither to provide information by themselves nor to
          provide a valid mechanism for getting the individual’s consent. Yet,
          new ways of obtaining the user’s valid consent should be considered by
          IoT stakeholders, including by implementing consent mechanisms through
          the devices themselves.




          There is no one-size-fits-all approach. Users must be able to access, view and remove the data you collect from them. Users should be able to disconnect their IoT devices when they want to do so.



          Another issue deserving of your attention is "sensitive data", again quoted from the Art 29 WP document:




          Applications in the IoT may process personal data that can reveal
          racial or ethnic origin, political opinions, religious or
          philosophical beliefs, trade-union membership, health or sex life,
          which actually qualify as “sensitive data”, deserving special
          protection in the sense of Article 8 of Directive 95/46/EC. In
          practice, the application of Article 8 to sensitive data in the IoT
          requires that data controllers obtain the user’s explicit consent,
          unless the data subject has made himself the data public.




          This type of data needs explicit consent.



          Beyond the requirement of fair collection of the data, you must communicate
          specific information about the product: the identity of the controller,
          the purposes of the processing, the recipients of the data, the existence of their rights of access and right to oppose (which includes information about how to disconnect the object to prevent disclosure of further data).



          Hopefully this helps to get started and here are some resources:



          https://www.ftc.gov/system/files/documents/reports/federal-trade-commission-staff-report-november-2013-workshop-entitled-internet-things-privacy/150127iotrpt.pdf



          http://ec.europa.eu/justice/data-protection/article-29/documentation/opinion-recommendation/files/2014/wp223_en.pdf



          http://www.internet-of-things-research.eu/pdf/IERC_Position_Paper_IoT_Governance_Privacy_Security_Final.pdf






          share|improve this answer























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            1 Answer
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            0














            I've just started reading about privacy in IoT therefore I thought I might give you some pointers (my day to day work is spent on making privacy policies and their management for websites and apps easier at iubenda).



            I think reading through any privacy by design principles might be the best start.



            I'm citing from a worksheet published by a Pan-European entity called the Article 29 Working Party (which I will link to at the bottom of this answer):




            In particular, users must remain in complete control of their personal
            data throughout the product lifecycle, and when organisations rely on
            consent as a basis for processing, the consent should be fully
            informed, freely given and specific.




            Consent on IoT devices isn't really a simple matter.



            For example, displaying a privacy policy document on your site is not sufficient. The FTC recommends (relevant for US based activities) that you find a way to present privacy notices and multiple choices of levels to customers, including in the set-up or purchase of the IoT device itself.



            Again, here is the Art 29 WP




            In addition, classical mechanisms used to obtain individuals’ consent
            may be difficult to apply in the IoT, resulting in a “low-quality”
            consent based in a lack of information or in the factual impossibility
            to provide fine-tuned consent in line with the preferences expressed
            by individuals. In practice, today, it seems that sensor devices are
            usually designed neither to provide information by themselves nor to
            provide a valid mechanism for getting the individual’s consent. Yet,
            new ways of obtaining the user’s valid consent should be considered by
            IoT stakeholders, including by implementing consent mechanisms through
            the devices themselves.




            There is no one-size-fits-all approach. Users must be able to access, view and remove the data you collect from them. Users should be able to disconnect their IoT devices when they want to do so.



            Another issue deserving of your attention is "sensitive data", again quoted from the Art 29 WP document:




            Applications in the IoT may process personal data that can reveal
            racial or ethnic origin, political opinions, religious or
            philosophical beliefs, trade-union membership, health or sex life,
            which actually qualify as “sensitive data”, deserving special
            protection in the sense of Article 8 of Directive 95/46/EC. In
            practice, the application of Article 8 to sensitive data in the IoT
            requires that data controllers obtain the user’s explicit consent,
            unless the data subject has made himself the data public.




            This type of data needs explicit consent.



            Beyond the requirement of fair collection of the data, you must communicate
            specific information about the product: the identity of the controller,
            the purposes of the processing, the recipients of the data, the existence of their rights of access and right to oppose (which includes information about how to disconnect the object to prevent disclosure of further data).



            Hopefully this helps to get started and here are some resources:



            https://www.ftc.gov/system/files/documents/reports/federal-trade-commission-staff-report-november-2013-workshop-entitled-internet-things-privacy/150127iotrpt.pdf



            http://ec.europa.eu/justice/data-protection/article-29/documentation/opinion-recommendation/files/2014/wp223_en.pdf



            http://www.internet-of-things-research.eu/pdf/IERC_Position_Paper_IoT_Governance_Privacy_Security_Final.pdf






            share|improve this answer



























              0














              I've just started reading about privacy in IoT therefore I thought I might give you some pointers (my day to day work is spent on making privacy policies and their management for websites and apps easier at iubenda).



              I think reading through any privacy by design principles might be the best start.



              I'm citing from a worksheet published by a Pan-European entity called the Article 29 Working Party (which I will link to at the bottom of this answer):




              In particular, users must remain in complete control of their personal
              data throughout the product lifecycle, and when organisations rely on
              consent as a basis for processing, the consent should be fully
              informed, freely given and specific.




              Consent on IoT devices isn't really a simple matter.



              For example, displaying a privacy policy document on your site is not sufficient. The FTC recommends (relevant for US based activities) that you find a way to present privacy notices and multiple choices of levels to customers, including in the set-up or purchase of the IoT device itself.



              Again, here is the Art 29 WP




              In addition, classical mechanisms used to obtain individuals’ consent
              may be difficult to apply in the IoT, resulting in a “low-quality”
              consent based in a lack of information or in the factual impossibility
              to provide fine-tuned consent in line with the preferences expressed
              by individuals. In practice, today, it seems that sensor devices are
              usually designed neither to provide information by themselves nor to
              provide a valid mechanism for getting the individual’s consent. Yet,
              new ways of obtaining the user’s valid consent should be considered by
              IoT stakeholders, including by implementing consent mechanisms through
              the devices themselves.




              There is no one-size-fits-all approach. Users must be able to access, view and remove the data you collect from them. Users should be able to disconnect their IoT devices when they want to do so.



              Another issue deserving of your attention is "sensitive data", again quoted from the Art 29 WP document:




              Applications in the IoT may process personal data that can reveal
              racial or ethnic origin, political opinions, religious or
              philosophical beliefs, trade-union membership, health or sex life,
              which actually qualify as “sensitive data”, deserving special
              protection in the sense of Article 8 of Directive 95/46/EC. In
              practice, the application of Article 8 to sensitive data in the IoT
              requires that data controllers obtain the user’s explicit consent,
              unless the data subject has made himself the data public.




              This type of data needs explicit consent.



              Beyond the requirement of fair collection of the data, you must communicate
              specific information about the product: the identity of the controller,
              the purposes of the processing, the recipients of the data, the existence of their rights of access and right to oppose (which includes information about how to disconnect the object to prevent disclosure of further data).



              Hopefully this helps to get started and here are some resources:



              https://www.ftc.gov/system/files/documents/reports/federal-trade-commission-staff-report-november-2013-workshop-entitled-internet-things-privacy/150127iotrpt.pdf



              http://ec.europa.eu/justice/data-protection/article-29/documentation/opinion-recommendation/files/2014/wp223_en.pdf



              http://www.internet-of-things-research.eu/pdf/IERC_Position_Paper_IoT_Governance_Privacy_Security_Final.pdf






              share|improve this answer

























                0












                0








                0







                I've just started reading about privacy in IoT therefore I thought I might give you some pointers (my day to day work is spent on making privacy policies and their management for websites and apps easier at iubenda).



                I think reading through any privacy by design principles might be the best start.



                I'm citing from a worksheet published by a Pan-European entity called the Article 29 Working Party (which I will link to at the bottom of this answer):




                In particular, users must remain in complete control of their personal
                data throughout the product lifecycle, and when organisations rely on
                consent as a basis for processing, the consent should be fully
                informed, freely given and specific.




                Consent on IoT devices isn't really a simple matter.



                For example, displaying a privacy policy document on your site is not sufficient. The FTC recommends (relevant for US based activities) that you find a way to present privacy notices and multiple choices of levels to customers, including in the set-up or purchase of the IoT device itself.



                Again, here is the Art 29 WP




                In addition, classical mechanisms used to obtain individuals’ consent
                may be difficult to apply in the IoT, resulting in a “low-quality”
                consent based in a lack of information or in the factual impossibility
                to provide fine-tuned consent in line with the preferences expressed
                by individuals. In practice, today, it seems that sensor devices are
                usually designed neither to provide information by themselves nor to
                provide a valid mechanism for getting the individual’s consent. Yet,
                new ways of obtaining the user’s valid consent should be considered by
                IoT stakeholders, including by implementing consent mechanisms through
                the devices themselves.




                There is no one-size-fits-all approach. Users must be able to access, view and remove the data you collect from them. Users should be able to disconnect their IoT devices when they want to do so.



                Another issue deserving of your attention is "sensitive data", again quoted from the Art 29 WP document:




                Applications in the IoT may process personal data that can reveal
                racial or ethnic origin, political opinions, religious or
                philosophical beliefs, trade-union membership, health or sex life,
                which actually qualify as “sensitive data”, deserving special
                protection in the sense of Article 8 of Directive 95/46/EC. In
                practice, the application of Article 8 to sensitive data in the IoT
                requires that data controllers obtain the user’s explicit consent,
                unless the data subject has made himself the data public.




                This type of data needs explicit consent.



                Beyond the requirement of fair collection of the data, you must communicate
                specific information about the product: the identity of the controller,
                the purposes of the processing, the recipients of the data, the existence of their rights of access and right to oppose (which includes information about how to disconnect the object to prevent disclosure of further data).



                Hopefully this helps to get started and here are some resources:



                https://www.ftc.gov/system/files/documents/reports/federal-trade-commission-staff-report-november-2013-workshop-entitled-internet-things-privacy/150127iotrpt.pdf



                http://ec.europa.eu/justice/data-protection/article-29/documentation/opinion-recommendation/files/2014/wp223_en.pdf



                http://www.internet-of-things-research.eu/pdf/IERC_Position_Paper_IoT_Governance_Privacy_Security_Final.pdf






                share|improve this answer













                I've just started reading about privacy in IoT therefore I thought I might give you some pointers (my day to day work is spent on making privacy policies and their management for websites and apps easier at iubenda).



                I think reading through any privacy by design principles might be the best start.



                I'm citing from a worksheet published by a Pan-European entity called the Article 29 Working Party (which I will link to at the bottom of this answer):




                In particular, users must remain in complete control of their personal
                data throughout the product lifecycle, and when organisations rely on
                consent as a basis for processing, the consent should be fully
                informed, freely given and specific.




                Consent on IoT devices isn't really a simple matter.



                For example, displaying a privacy policy document on your site is not sufficient. The FTC recommends (relevant for US based activities) that you find a way to present privacy notices and multiple choices of levels to customers, including in the set-up or purchase of the IoT device itself.



                Again, here is the Art 29 WP




                In addition, classical mechanisms used to obtain individuals’ consent
                may be difficult to apply in the IoT, resulting in a “low-quality”
                consent based in a lack of information or in the factual impossibility
                to provide fine-tuned consent in line with the preferences expressed
                by individuals. In practice, today, it seems that sensor devices are
                usually designed neither to provide information by themselves nor to
                provide a valid mechanism for getting the individual’s consent. Yet,
                new ways of obtaining the user’s valid consent should be considered by
                IoT stakeholders, including by implementing consent mechanisms through
                the devices themselves.




                There is no one-size-fits-all approach. Users must be able to access, view and remove the data you collect from them. Users should be able to disconnect their IoT devices when they want to do so.



                Another issue deserving of your attention is "sensitive data", again quoted from the Art 29 WP document:




                Applications in the IoT may process personal data that can reveal
                racial or ethnic origin, political opinions, religious or
                philosophical beliefs, trade-union membership, health or sex life,
                which actually qualify as “sensitive data”, deserving special
                protection in the sense of Article 8 of Directive 95/46/EC. In
                practice, the application of Article 8 to sensitive data in the IoT
                requires that data controllers obtain the user’s explicit consent,
                unless the data subject has made himself the data public.




                This type of data needs explicit consent.



                Beyond the requirement of fair collection of the data, you must communicate
                specific information about the product: the identity of the controller,
                the purposes of the processing, the recipients of the data, the existence of their rights of access and right to oppose (which includes information about how to disconnect the object to prevent disclosure of further data).



                Hopefully this helps to get started and here are some resources:



                https://www.ftc.gov/system/files/documents/reports/federal-trade-commission-staff-report-november-2013-workshop-entitled-internet-things-privacy/150127iotrpt.pdf



                http://ec.europa.eu/justice/data-protection/article-29/documentation/opinion-recommendation/files/2014/wp223_en.pdf



                http://www.internet-of-things-research.eu/pdf/IERC_Position_Paper_IoT_Governance_Privacy_Security_Final.pdf







                share|improve this answer












                share|improve this answer



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                answered Mar 22 '17 at 10:59









                SimonSimon

                44925




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