Micah Altman, David O’Brien, Salil Vadhan, and Alexandra Wood. 3/31/2014. “Comment to The White House Office of Science and Technology Policy (OSTP): Big Data Study, Request for Information”.
On January 23, 2014, President Barack Obama asked John Podesta to perform a comprehensive review of big data and privacy. During this review, the White House Office of Science and Technology Policy issued a request for public comment on questions related to the public policy implications of big data.
Micah Altman, David O’Brien, Salil Vadhan, and Alexandra Wood submitted a response on behalf of the Privacy Tools for Sharing Research Data project. Their comments outline a broad, comprehensive, and systematic framework for privacy analysis and provide a taxonomy of modern technological, statistical, and cryptographic approaches to preserving both data privacy and utility. They argue that an analysis of information privacy should address the scope of information covered, the sensitivity of that information, the risk that sensitive information will be disclosed, the availability of control and accountability mechanisms, and the suitability of existing data sharing models, as applied across the entire lifecyle of information use, from collection through dissemination and reuse.
With this submission, the authors discuss the inadequacy of traditional approaches to privacy protection and recommend a modern approach that considers three principles. First, the risks of informational harm are generally not a simple function of the presence or absence of specific fields, attributes, or keywords in the released set of data. Second, redaction, pseudonymization, coarsening, and hashing, are often neither an adequate nor appropriate practice, nor is releasing less information necessary more privacy protective. Third, a thoughtful analysis with expert consultation is necessary in order to evaluate the sensitivity of the data collected, to quantify the associated re-identification risks, and to design useful and safe release mechanisms.