Addressing privacy and data protection systematically throughout the process of engineering information systems is a daunting task. Although the research community has made significant progress in theory and in labs, meltdowns in recent years suggest that we're still struggling to address systemic privacy issues. Privacy engineering, an emerging field, responds to this gap between research and practice. It's concerned with systematizing and evaluating approaches to capture and address privacy issues with engineering information systems. This article serves to illuminate this nascent field. The authors provide a definition of privacy engineering and describe encompassing activities. They expand on these with findings from the First International Workshop on Privacy Engineering (IWPE), and conclude with future challenges.
Data protection authorities worldwide have agreed on the value of considering privacy-by-design principles when developing privacy-friendly systems and software. However, on the technical plane, a profusion of privacy-oriented guidelines and approaches coexists, which provides partial solutions to the overall problem and aids engineers during different stages of the system development lifecycle. As a result, engineers find difficult to understand what they should do to make their systems abide by privacy by design, thus hindering the adoption of privacy engineering practices. This paper reviews existing best practices in the analysis and design stages of the system development lifecycle, introduces a systematic methodology for privacy engineering that merges and integrates them, leveraging their best features whilst addressing their weak points, and describes its alignment with current standardization efforts.
The number and dynamic nature of web sites and mobile applications present regulators and app store operators with significant challenges when it comes to enforcing compliance with applicable privacy and data protection laws. Over the past several years, people have turned to Natural Language Processing (NLP) techniques to automate privacy compliance analysis (e.g., comparing statements in privacy policies with analysis of the code and behavior of mobile apps) and to answer people’s privacy questions. Traditionally, these NLP techniques have relied on labor-intensive and potentially error-prone manual annotation processes to build the corpora necessary to train them. This article explores and evaluates the use of Large Language Models (LLMs) as an alternative for effectively and efficiently identifying and categorizing a variety of data practice disclosures found in the text of privacy policies. Specifically, we report on the performance of ChatGPT and Llama 2, two particularly popular LLM-based tools. This includes engineering prompts and evaluating different configurations of these LLM techniques. Evaluation of the resulting techniques on well-known corpora of privacy policy annotations yields an F1 score exceeding 93%. This score is higher than scores reported earlier in the literature on these benchmarks. This performance is obtained at minimal marginal cost (excluding the cost required to train the foundational models themselves). These results, which are consistent with those reported in other domains, suggest that LLMs offer a particularly promising approach to automated privacy policy analysis at scale.
The pervasiveness of Android mobile applications and the services they support allow the personal data of individuals to be collected and shared worldwide. However, data protection legislations usually require all participants in a personal data flow to ensure an equivalent level of personal data protection, regardless of location. In particular, the European General Data Protection Regulation constrains cross-border transfers of personal data to non-EU countries and establishes specific requirements to carry them out. This article presents a method to systematically assess compliance of Android mobile apps with the requirements for cross-border transfers established by the European data protection regulation. We have validated the method with one hundred Android apps, finding an outstanding 66% of ambiguous, inconsistent and omitted cross-border transfer disclosures.
A privacy policy describes the operations an organization carries out on its users’ personal data and how it applies data protection principles. The automated analysis of privacy policies is a multidisciplinary research topic producing a growing but scattered body of knowledge. We address this gap by conducting a systematic mapping study which provides an overview of the field, identifies research opportunities, and suggests future research lines. Our study analyzed 39 papers from the 1097 publications found on the topic, to find what information can be automatically extracted from policies presented as textual documents, what this information is applied to, and what analysis techniques are being used. We observe that the techniques found can identify individual pieces of information from the policies with good results. However, further advances are needed to put them in context and provide valuable insight to end-users, organizations dealing with data protection laws and data protection authorities.