The purpose of this document is to provide a record of the monitoring activities that take place in the context of the OCTAVE developments, for aspects that relate to collection, storage and processing of personal data. In order to carry out this monitoring in a structured way, this document starts with an overview of the overall TBAS architecture and its provisions for the protection of personal data: this first chapter already introduces the concept that the splitting of user sensitive data among the application provider, the identity management provider and the authentication provider, along with pseudonymisation of those data at different stages, follows the Privacy by Design guidelines and provides adequate measures for guaranteeing the privacy of the stored personal data. Thereafter, the deliverable reports the list of privacy issues related to personal data that have been collected during the first seventeen months of the project: for every item of this list, the document describes the way the issue has been handled and addressed by the OCTAVE TBAS platform, together with a pertinent reference. Issues are numbered in increasing order, with no implication to their relative importance. A brief overview of the design issues related to the protection of personal data, for both SEA and Findomestic trials, follows; this additional bird’s eye view supports the conclusion that not only the way the OCTAVE TBAS platform is structured, but also the way this platform interacts with application providers is compliant with legal and technical requirements documented by deliverables D6 and D24 and consequently provides adequate measures for guaranteeing the privacy of the stored personal data. The consistency and full compliancy of the overall service with the principles that relate to collection, storage and processing of personal data will be a key element to determine the successful exploitation and the spread adoption of the OCTAVE TBAS solution.
Source: WP 5 Standards and Procedures for Personal Data Protection
Dissemination level: Confidential
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