The transparency goals of the open data movement serve important social, economic, and democratic functions in cities like Seattle. At the same time, some municipal datasets about the city and its citizens’ activities carry inherent risks to individual privacy when shared publicly. In 2016, the City of Seattle declared in its Open Data Policy that the city’s data would be “open by preference,” except when doing so may affect individual privacy. To ensure its Open Data program effectively protects individuals, Seattle committed to performing an annual risk assessment and tasked the Future of Privacy Forum (FPF) with creating and deploying an initial privacy risk assessment methodology for open data.
This Draft Report provides tools and guidance to the City of Seattle and other municipalities navigating the complex policy, operational, technical, organizational, and ethical standards that support privacyprotective open data programs. Although there is a growing body of research on open data privacy, open data managers and departmental data owners need to be able to employ a standardized methodology for assessing the privacy risks and benefits of particular datasets internally, without a bevy of expert statisticians, privacy lawyers, or philosophers. By following a flexible, risk-based assessment process, the City of Seattle – and other municipal open data programs – can maximize the utility and openness of civic data while minimizing privacy risks to individuals and community concerns about ethical challenges, fairness, and equity.
This Draft Report first describes inherent privacy risks in an open data landscape, with an emphasis on potential harms related to re-identification, data quality, and fairness. Accompanying this, the Draft Report includes a Model Open Data Benefit Risk Analysis (MODBRA). The model template evaluates the types of data contained in a proposed open dataset, the potential benefits – and concomitant risks – of releasing the dataset publicly, and strategies for effective de-identification and risk mitigation. This holistic assessment guides city officials to determine whether to release the dataset openly, in a limited access environment, or to withhold it from publication (absent countervailing public policy considerations). The Draft Report methodology builds on extensive work done in this field by experts at the National Institute of Standards and Technology, the University of Washington, the Berkman Klein Center for Internet & Society at Harvard University, and others, and adapts existing frameworks to the unique challenges faced by cities as local governments, technological system integrators, and consumer facing service providers.