The General Data Protection Regulation (GDPR) is an European law governing the use of consent and personal data. Some of its obligations involve concepts related to the lifecycles of consent and personal data. Such obligations are concerned with how the collection, use, processing, sharing, and storing of consent and personal data takes place and provides the motivation for a form of documentation that can demonstrate the required information towards compliance. GDPRov is an OWL2 ontology for representing this information as provenance metadata using terms relevant to the GDPR. It extends PROV-O and P-Plan to represent the lifecyles as an abstract model of how things should happen or will happen (future) as well as instance of what has happened (past). The ontology is being developed as part of contributions towards PhD research by its primary author.
GDPRov is an OWL2 ontology to express provenance metadata of consent and data lifecycles towards documenting compliance for GDPR.
The GDPR Provenance ontology
gdprov
GDPRov is an ontology for expressing provenance metadata in the context of the General Data Protection Regulation (GDPR) and its compliance. It extends PROV-O and P-Plan. PROV-O is the ontology based on the PROV model, a W3C recommendation, while P-Plan is an extension of PROV-O. PROV is used to define terms or 'instances' of what has happened in the past, while P-Plan is used to define the abstract model or 'Plan' of things to happen. GDPRov uses P-Plan to create a template/model/plan as an abstract or model representation of a system which is then recorded using PROV-O instances to show something has happened. The aim of the ontology is to enable representation of consent and personal data lifecycles using terms relevant to GDPR and to facilitate expression of this information towards documentation related to compliance.
anonymity level
Archives the consent into some entity
archives consent as
Links data obtained (collected) by the step/activity that acquired it
collectsData
Indicates that an DataAnonymisationStep transforms a Data object into AnonymisedData
generatesAnonymisedData
Generates ConsentAgreement which is a the consent granted by the user based on the ConsentAgreementTemplate through a ConsentAcquisitionStep
generatesConsentAgreement
produces data
generatesData
Indicates the anonymity level of an AnonymisedData object using instances of the AnonymityLevel class
hasAnonymityLevel
hasLegalBasis
has legal justification
hasSharedDataWith
isAnonymisedByStep
isConsentAgreementTemplateForStep
isDataCollectedByStep
isDataGeneratedByStep
isGeneratedByStep
isJustificationForDataStep
justifies use of data by step through specified consent agreement
isJustifiedUsingConsentAgreement
isPartOfProcess
isTermsAndConditionsForStep
isUsedByStep
Indicates sharing of Data through a DataStep
sharesData
sharesDataWith
Shares data with a third party
sharesDataWithThirdParty
transferredDataToRegion
transfersDataToRegion
uses Consent Agreement entity
uses Consent Agreement
links a Consent Acquisition Step with the Consent Agreement Template used to acquire consent
usesConsentAgreementTemplate
links step with data used
usesData
Links a Consent Acquisition Step with the Terms and Conditions presented to the user when acquiring Consent
usesTermsAndConditions
Is an activity that acquires consent.
Acquire Consent Activity
Is an activity that anonymises data.
Anonymisation Activity
Represents data that has been Anonymised at some level reflected by the hasAnonymityLevel object property
AnonymisedData
Is an entity where personal data has been anonymised to some extent.
Anonymised Data Entity
Provides a way to express the Anonymity Level of AnonymisedData objects through the object property hasAnonymityLevel. There are four levels defined within the GDPR, each represented by an instance in the ontology. The levels are: (completely) anonymous, pseudo-anonymous where the organisation does not have data required to de-anonymise, pseudo-anonymous where the organisation has data to de-anonymise, and not-anonymised.
AnonymityLevel
Reflects the process(es) used to appoint processors
Appoint Processor
An activity that archives given/acquired consent for storage.
Archive Consent Activity
An activity that is automated.
Automated Activity
A Step that is Automated, or involves automation in processing operations.
AutomatedStep
ConsentAcquisitionStep deals with acquiring consent. If consent is obtained from the user, the relevant Terms and Conditions along with the appropriate Consent Model (template) can be associated with the step. The output of this step is the consent agreed upon by the user.
Consent Acquisition Step
Is an activity dealing with consent.
Consent Activity
ConsentAgreement reflects the consent provided by the user based on the provided Terms and Conditions and Consent Agreement Templates. It is the set of permissions the user has specifically provided or refused to provide with respect to processing their personal data. This consent is useful to provide justification of activities that use user data.
ConsentAgreement
This is a template for consent requested from the user. The template is the generic options provided to all data subjects to obtain their consent.
ConsentAgreementTemplate
ConsentArchivalStep archives acquired consent to form a record of the consent given by the user.
Consent Archival Step
ConsentModificationStep deals with modifications to the consent. It invalidates the previous consent object and produces a new updated consent object that represents the modified consent.
Consent Modification Step
A ConsentStep acts/interacts with/uses Consent
Consent Step
Is the template used to obtain the given consent.
Consent Template
A ConsentWithdrawalProcess deals with the withdrawal of consent by the user and the corresponding activity carried out within the system
Consent Withdrawal Process
ConsentWithdrawalStep deals with withdrawal of consent
Consent Withdrawal Step
A ThirdPartyDataController is a Third Party entity that acts as a Data Controller
Controller
A Representative of the Controller
Controller Representative
A step that involves cross-border transfer of data
Cross-border Data Transfer Step
Is an activity that transfer data across borders (as defined in the GDPR).
Cross Border Transfer Activity
The Data Protection Officer appointed to an organisation.
Data Protection Officer (DPO)
Represents class of data collected or generated through various activities
Data
A DataAccessProcess corresponds to the request made by an user for access to their data within the system. This process is responsible for handling the request process and providing the appropriate data to the end user.
Data Access Process
Is an activity involving data.
Data Activity
DataAnonymisationStep anonymises data by transforming it from one form to another along the anonymisation chain (not-anonymised --> pseudo-anonymised --> anonymised). Anonymisation can be represented as a spectrum going from raw user data to pseudo-anonymised data that can be de-anonymised by the same agent/organisation to pseudo-anonymous data that cannot be deanonymised internally, but may be done by external agents who have access to other data, and finally to completely anonymised data.
Data Anonymisation Step
Is an activity that archives data. Archival is transformation of data into some form for storage.
Data Archival Activity
A DataArchivalProcess describes the process of data archival
Data Archival Process
DataArchivalStep archives data by transforming it and storing it
Data Archival Step
Is an activity dealing with data breach.
Data Breach Activity
A record of a data breach.
Data Breach Record
A record of a Data Breach that took place.
Data Breach Record Entity
Step representing an action associated with data breach.
Data Breach Step
Is an activity that collects or acquires data.
Data Collection Activity
DataCollectionStep collects data from the user
Data Collection Step
DataDeanonymisationStep deanonymises data by transforming it from one form to another along the anonymisation chain (anonymised --> pseudo-anonymised --> not-anonymised)
Data Deanonymisation Step
Is an activity that deletes or erases data.
Data Deletion Activity
DataDeletionStep deletes personal data from within the system; The deletion is expressed as prov:invalidated over the dataset. Note that deletion is not the same as erasure. Deletion denotes removal of data, whereas erasure implies destruction.
Data Deletion Step
Represents a data entity.
Data Entity
An activity that erases data.
Data Erasure Activity
A DataErasureProcess is responsible for handling the data erasure of a data subject.
Data Erasure Process
DataDeletionStep erases personal data from within the system; The deletion is expressed as prov:invalidated over the dataset. Note that deletion is not the same as erasure. Deletion denotes removal of data, whereas erasure implies destruction.
Data Erasure Step
A DataRectificationProcess describes the process of data rectification, which is the correction of data already present within the system
Data Rectification Process
Is an activity that shares data.
Data Sharing Activity
DataSharingStep shares data with another agent/organisation which act as a third party. In this context, sharing is a synonym for disclose, give, provide, or access (by third party).
Data Sharing Step
A DataStep involving with personal data
Data Step
A step that involves personal data but whose records are not available or will not be kept. This allows explicit declaration of an activity without any logs or records.
Data Step without Provenance
Is an activity that stores data.
Data Storage Activity
DataStorageStep stores data within the system
Data Storage Step
An individual or entity
Data Subject
Activity that involves data transfer.
Data Transfer Activity
This step involves transfer of data to another location or organisation (that is not a third party). Note that transfer and sharing are separate terms. GDPRov uses the technical definition of transfer - to move or copy data from one place to another. If data is being "transfered"@en .o another organisation, it should be represented using DataSharingStep.
DataTransferStep
Is an activity that transforms data.
Data Transformation Activity
DataTransformationStep transforms data from one form into another.
Data Transformation Step
Is an activity that uses data. Can also be termed as 'Processing' of data.
Data Usage Activity
A DataUsageStep is a DataStep that uses existing or available personal data present within the system
Data Usage Step
Is an activity that deanonymises data.
DeAnonymisation Activity
Direct Marketing where the marketing is done directly to the data subject.
Direct Marketing
Represents the given consent by the data subject.
Given Consent
A process that defines the actions that should be undertaken in event of a data breach
Handle Data Breach Process
The process or series of steps that handle the right of data portability.
Handle Right of Data Portability
The process or series of steps that handle the right of erasure.
Handle Right of Erasure
The process or series of steps that handle the right to access personal data.
Handle Right to access Personal Data
The process or series of steps that handle the right to basic information about processing.
Handle Right to basic information about Processing
The process or series of steps that handle the right to not be processed automatically.
Handle Right to not be evaluated through Automated Processing
The process or series of steps that handle the right to object to direct marketing.
Handle Right to Object to Direct Marketing
The process or series of steps that handle the right to object to processing.
Handle Right to Object to Processing
The process or series of steps that handle the right to rectification of personal data.
Handle Right to Rectification
The process or series of steps that handle the right to restrict processing.
Handle Right to restrict Processing
The process or series of steps that handle the right to transparency.
Handle Right to Transparency
Handle Subject Access Requests made by the Data Subject
Handle Subject Access Requests
Represents the process or collection of steps representing the Impact Assessment.
Impact Assessment
A Joint Controller is where two or more controllers jointly determine the purposes and means of processing.
Joint Controller(s)
Marketing as a process or collection of steps.
Marketing
Is an activity that modifies given consent.
Modify Consent Activity
The process of monitoring compliance as mandated by the GDPR.
Monitor Compliance
Is an activity that notifies controller about data breach
Notify Controller Activity
Step that notifies relevant controller(s) about the data breach.
Notify Controller Step
Is an activity that notifies data protection authorities about data breach
Notify DPA Activity
Step that notifies the Data Protection Authorities of a data breach.
Notify Data Protection Authority Step
Is an activity that notifies data subjects about data breach
Notify Data Subject Activity
Step that notifies the data subject about the data breach.
Notify Data Subject Step
PersonalData is any data pertaining to the user which can contain personally identifiable information or a data set generated by the system using personally identifiable information acquired through direct or indirect means
PersonalData
Represents a personal data entity.
Personal Data Entity
Privacy Policy for usage of personal data as provided to the user in agreement of provided service
Privacy Policy
A Privacy Policy for usage of personal data for data processing.
Privacy Policy Entity
A Process describes a 'Plan' of action for carrying out a particular activity that uses or is related to Data or Consent
Process
A ThirdPartyDataProcessor is a Third Party entity that acts as a Data Processor
Processor
A representative of the Processor.
Processor Representative
Activity that provides a copy of personal data (to a data subject).
Provide Copy of Data Activity
A step that provides (the data subject or other agent) with a copy of personal data.
Provide copy of Personal Data Step
Is an activity that recitifies data.
Rectify Data Activity
Rectifies existing data. Rectify means to change with the intention of correction or removal of errors.
Rectify Data Step
The process of reporting after a data breach has taken place.
Report Data Breach
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.
Sensitive Personal Data
Is an entity containing sensitive personal information.
Sensitive Data Entity
A Processor appointed under or by another Processor is a Sub-Processor.
Sub-Processor
Terms and Conditions of usage as provided to the user in agreement of provided service
TermsAndConditions
Represents the Terms and Conditions entity.
Terms and Conditions Entity
A ThirdParty is an entity other than the Data Subject and the Data Controller.
ThirdParty
An UserIdentifier is a specific way to identify the user through a unique ID or a combination of other attributes
UserIdentifier
Is an entity acting as the user identifier. Or contains an identifier.
User Identifier Entity
Activity that involves the user providing an input. The input can be a choice or an action or the provision of some information.
User Input Activity
Step that involves the user providing an input. The input can be a choice or an action or the provision of some information.
User Input Step
Activity that involves interaction with the user.
User Interaction Activity
Step that involves interaction from the user.
User Interaction Step
Activity that involves providing some information (output) to the user. Output can be information given or shown, or a document, or an email, or message.
User Output Activity
Step that involves providing some information (output) to the user. Output can be information given or shown, or a document, or an email, or message.
User Output Step
Is an activity that withdraws given consent. Can also term it so as to depict withdrawal as a modification of consent.
Withdraw Consent Activity
Represents the class of Lawful basis under the GDPR. There are a total of six lawful basis according to Article 6, each represented by an instance.
Lawful basis for Processing
Anonymised represents the Anonymisation level where the data cannot be de-anonymised to retrieve personally identifiable information.
Anonymised
DeAnonymised represents the Anonymisation level where the data is completely de-anonymised and contains directly accessible personally identifiable information.
DeAnonymised
PseudoAnonymised represents the Anonymisation level where the data is anonymised but cannot be de-anonymised without additional data which is NOT accessible to the data-holding organisation to retrieve personally identifiable information.
PseudoAnonymised
PseudoOrganisationalAnonymised represents the Anonymisation level where the data is anonymised but cannot be de-anonymised without additional data which is accessible to the data-holding organisation to recreate the de-anonymised information.
PseudoOrganisationalOrganised