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AnalysisPhase.md

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Analysis Phase

  • Is there a need of data collection?

    • The principle Privacy by Design (link with details to intro) must be taken into consideration when planning app connection behavior and collection of user data

    • Device-specific information gathered has to follow some restrictions

      • Unique identifiers (UDID, IMEI, MAC addresses etc.) are obtained only after an user-confirmed Opt-In and only if they are necessary for the specific purpose
      • Unique identifiers are not used for individual user tracking
      • Tracking IDs (IDFA, AAID) are transmitted in encrypted form
      • User-disabled tracking options have to be respected

    • If the app is planned to process personal data, a Privacy Policy must be implemented and must include the minimum requirements of the local data protection laws

      • this implies, but is not limited to
        • Which types of personal data are accessed and why?
          • How will this data be used?
          • How will this data be stored?
          • Which third-parties will receive access to the data and under what conditions?
        • Statement, that collected data will be protected from unauthorized access
        • Contact data of the actual Data Protection Officer
        • Statement on how to access personal saved data as a user
        • Statement on how to initiate personal data deletion as a user
      • extended information about privacy policies etc. can be found here

    Is data leaving the main ecosystem?

    • definition of the level of data leakage
      • is data leaving the "local boundary"
      • is data leaving the "eco system boundary"
      • is data leaving the "3rd party boundary"
    • service provider needs data processing contract (german ADV)

    Which data needs which level of protection?

    Special categories of data are placed under particular protection of the law.

    1. no personal reference: no protection necessary

      ​ consequences on usage = no consequences, no abuse possible

    2. person related or relatable: protection necessary

      ​ consequences on usage = displeasing consequences, abuse possible

    3. sensitive data: processing not recommended

      ​ consequences on usage = unwanted consequences, can be used against individual

    4. dangerous data: processing prohibited

      ​ consequences on usage = threat to life or freedom of individual

      ​

      ​#### Sensitive Data

(REM: Ergänzungen vielleicht in eine Art Kasten)
Amongst these are personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation. These data generally may only be used where the data subject has given explicit consent regarding these very categories of information.

Extend of data used

(REM: Ergänzungen vielleicht in eine Art Kasten)
Where the information on individuals used by the app is particularly comprehensive, exposing their conduct or characteristics, particular attention needs to be paid to the protection of those data.

Is data used that must be deletable on user demand? (@ULD: which data is affected)

  • a routine must be implemented to ensure full deletion of user data on demand
    • all saved data from the user must be deletable
    • this applies also to data stored in the cloud
    • if no such routine is implemented, the user is provided with contact data to send a deletion request

Special protection

  • are persons with special protection needs concerned? (was dann @ULD? betroffene Schützenswert? Kinder etc.)

(REM: Ergänzeungen vielleicht in einer art Kasten) For instance if children or other persons who require particular legal protection are involved, the processing of data might be more restricted than otherwise.

Risk Assessment

(@Introduction.md - after each Development Phase the risk needs to be reassessed)

  • all processed data needs to be analysed to specify a risk level of potential malicious use of the data
    • based on these risk levels special protection routines need to be applied (hier auf standardisierte Risk-Level verweisen @ULD habt ihr da was?)

Examples: