Bartolini, C., Muthuri, R., & Santos, C. (2015, November). Using ontologies to model data protection requirements in workflows. In JSAI International Symposium on Artificial Intelligence (pp. 233-248). Springer, Cham.
The General Data Protection Regulation (GDPR) defines legal obligations over the use of personal data by organisations. This ontology aims to identify and model such terms and obligations as an OWL vocabulary and to directly link the terms to their occurence, usage, and influence in the GDPR text.
This is an ontology to represent GDPR text as a set of RDF resources
This ontology extends the canonical (official) GDPR text with additional annotations
It signifies that two concepts are related within the context of the GDPR.
indicates the legal resource has the Article
indicates the legal resource has the Chapter
indicates the legal resource has the Point
indicates the legal resource has the Recital
indicates the legal resource has the Section
indicates the legal resource has the SubPoint
represents a legal resource subdivision to be part of a article
represents a legal resource subdivision to be part of a chapter
represents a legal resource subdivision to be part of a point
represents a legal resource subdivision to be part of a section
The principle of accountability states that the controller shall be responsible for, and be able to demonstrate compliance with the processing of personal data as defined by the justifications permissible under the GDPR
The principle of accuracy states that personal data must be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
The data subject can exercise the right to restrict processing of their personal data when the accuracy of personal data is contested
when accuracy of personal data is contested
This obligation specifies that the collection of (or collected) personal data should in an accurate form - i.e. the personal data should be accurate.
collected personal data should be accurate
An Activity signifies some process(es) or step(s) towards specific deed(s), action(s), function(s), or sphere(s) of action.
Only the personal data adequat for required processing should be maintained
retention should be adequate for processing
The seal or certification does not reduce or impact the responsiblity of the controller or processor for compliance with the GDPR
Data is termed to be anonymous if it cannot be connected or associated with individual person or persons that have provided or are associated with it.
These are the obligations for Processors over appointing sub-processors
These are the obligations specified by the GDPR for the appointment of Processors by Controllers.
An activity where personal data is archived
Processors must assist Controllers in complying with the various rights provided by the GDPR to data subjects which can be exercised at any time.
assist Controller in complying with data subject's rights
This type of processing involves automated processing that does decision making having significant effects on the data subject.
automatic decision making with significant effect for data subject
This is automated processing of data subject's personal data.
This obligation states that the data subject should be able to withdraw the consent as easily as it was to give it.
consent should be able to withdrawn as easily as it was given
A certification pertaining to GDPR compliance
A Certification Body is an entity that can award/issue/renew a certification pertaining to compliance towards the GDPR.
Obtaining consent must provide clear explanations of the processing involved over the personal data
should contain clear explanation of processing
A Code of Conduct for the purpose of specifying the application of GDPR which may be monitored, evaluated, or processed by a third party appointed by the organisation.
Collection of Personal Data is an Activity that deals with acquiring data subject's personal data through some model of interaction.
collection of personal data
Represents the act of complying with the obligations and actions specified by the GDPR.
The processor has an obligation to comply with the controller's instructions
compliance with Controller's instructions
GDPR mentions some conditions or criterion for the creation and issuing of seals and certifications pertaining to GDPR compliance
conditions for awarding Seals and Certifications
This type of processing involves matching data subject's identity or personal data in different datasets.
confirming or matching using datasets of data subject's personal data
Consent in the context of the GDPR refers to the assent or agreement by the data subject in relation to their personal data for the proposed processing activities associated with one or more organisations.
An activity involving data subject's consent.
The right of erasure applies when the data subject withdraws given consent
The purpose of new processing should take the context of how the original data was collected into consideration
context of how personal data was collected
The lawful basis for processing personal data is provided through a contract with the data subject.
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
These obligations specify the accountability of the Controller.
The data subjects were not notified about the data breach because the controller had already taken action regarding the data breach.
Controller has already taken action on the Data Breach
These are the obligations specified by the GDPR as being specifically the responsbility of the Controller.
A natural or legal person established in the Union who, designated by the controllerin writing, represents the controller with regard to their respective obligations under the GDPR.
These obligations specify the responsiblity of the Controller
This obligation specifies the Controller/Processor must co-operate with the Data Protection Authority (DPA).
Personal data related to criminal convictions and offences.
data related to crimes and criminal convictions
Cross-border data transfer refers to data transfer crossing the boundaries of EU (legislative) region.
The Data Protection Authority (DPA) is a public institution responsible for monitoring the application of data protection laws.
The Data Protection Officer (DPO) is an individual(s) appointed by the organisation to monitor compliance and assist in complying with the GDPR.
These are the obligations specified for the Data Protection Office (DPO) within the GDPR
A generic term to refer to Data.
An activity involving personal data of data subject(s).
A data breach is the intentional or unintentional release of secure or private/confidential information to an untrusted environment.
The right to erasure applies where data is no longer needed for original purposes for which it was collected
erase personal data if it is no longer needed for original purpose under which it was acquired
The principle of data minimisation states that personal data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
The data subject can exercise the right to restrict processing of their personal data when the personal data is no longer required for the original purpose it was collected under
when data is no longer needed for original purpose it was acquired under
This obligation requires Controllers to follow data protection by design and by default.
data protection by design and by default
These are obligations regarding security of data managed by the Controllers.
An individual or entity to whom their personal data relates.
The obligation or activity coult not be completed because the data was inferred or derived, and therefore did not come from the data subject or other sources.
data was inferred or derived from personal data
The act of demonstrating consent is an activity whereby previously acquired consent is provided as sufficient justification for processing activities involving data subject's personal information.
demonstrating valid consent given by data subject
Type of Marketing that reaches data subjects directly by communications directly addressed to the data subject.
A general term for any institution, company, corporation, partnership, government agency, university, or any other organization including individuals.
Whether the proposed activity involves the evaluation of the data subject.
Exceptions associated with compliance for reporting data breach to the affected data subjects.
exceptions on reporting data subjects about data breach
Exclusions and Exemptions provided by the GDPR for not complying with the specified obligations.
Exlcusions and Exceptions as applicable to compliance towards GDPR
Lawful basis for processing is provided by National Law
The request or activity could not or was not completed because there was no sufficient proof of the data subject's identity.
exempted from action without sufficient proof of data subject's identity
The activity represents exercising of rights provided by GDPR by the data subject.
The purpose of new processing should take into context the existence of appropriate safeguards
existence of safeguards over personal data
This obligation specifies that the collected (or collection) of personal data should be for/with explicit purposes.
collection of personal data should be for explicit purpose
Lawful basis for processing is provided by Employment Law
These are the factors stated by the GDPR for Impact Assessment.
GDPR obligation that specifies consent must be freely given by the data subject for it to be valid.
Personal data relating to the inherited or acquired genetic characteristics of a natural person which result from the analysis of a biological sample from the natural person in question, in particular chromosomal, deoxyribonucleic acid (DNA) or ribonucleic acid (RNA) analysis, or from the analysis of another element enabling equivalent information to be obtained.
Given Consent refers specifically to the form of consent given by the data subject in relation to their personal data and the proposed usage by activities.
The data subjects were not notified about the data breach because the harm was deemed to be remote.
harm done in the data breach was only remote
Personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status.
data related to health, medical, or diagnosis records
Lawful basis if provided by the GDPR for processing related to historic, statistical, or scientific purposes.
for historic, statistical, or scientific purposes
Retention of personal data should be identifiable for the requried processing
retention where personal data is identifiable for required processing
Activity where the data subject is explicitly identified through direct or indirect means.
The right to access personal data also includes information about whether and where the controller is processing the data subject's personal data
if and where Controller is processing personal data
The activity wherein the controller carries out an assessment of the impact of the envisaged processing operations on the protection of personal data.
This obligation requires Controllers to implement the required technical measures necessary for compliance of the GDPR
implement required technical measures for ensuring and demonstrating compliance
The processor must impose confidentiality agreements on its personnel in relation to handling of personal data
impose confidentiality obligations on personnel with access to data subject's personal data
The right to access personal data also includes information about automated processing that has significant effects on the data subject.
information about automated processing with significant effects on data subject
The right to access personal data also includes information about the categories of recipients the data is shared with.
information about categories of recipients personal data is shared with
The right to access personal data also includes information about categories of data being processed
information about categories of personal data being processed
The right to access personal data also includes information about the existence of rights provided by the GDPR to the data subject
information about existence of data subject's rights
The right to access personal data also includes information about the processing of personal data of the data subject
information about processing of personal data
The right to access personal data also includes information about the source of the personal data
information about source of personal data
The right to access personal data also includes information about the storage period of the data subject's personal data
information about storage period of personal data
In case of conflict with the controller's intructions and the law, the processor must immediately inform the controller of this conflict
inform Controller of conflicting obligations under Controller's instruction and legal obligations
The right to basic information also provides data subject's with information about third parties involved in the processing.
information about third parties involved
The information provided under the right to transparency should be concise
The information provided under the right to transparency should be easily accessible
The information provided under the right to transparency should be intelligible
The information provided under the right to transparency should be transparent and clear (i.e. not umambigious or vague)
GDPR obligation that specifies consent must be informed for it be valid.
consent must be given through informed decision
The principle of integrity and confidentiality states that personal data must be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
Principle of Integrity and Confidentiality
The obligation or activity could not be completed as it was deemed to be impossible.
A joint controller is two or more controllers jointly determine the purposes and means of processing.
Retained personal data must be kept up-to-date
The processing of personal data at a large scale of quantity or significant proportions.
This provides the basis for lawful processing of personal data.
The principle of lawfulness, fairness, and transparency states that personal data must be processed lawfully, fairly and in a transparent manner in relation to the data subject.
Principle of Lawfulness, Fairness, and Transparency
Lawful basis for processing is provided by legal claims.
Lawful basis for processing is covered by legal obligation(s).
Lawful basis for processing is provided through the legitimate interests pursued by the Controller or by a third party
This specifies that the collection (or collected) personal data should be used/specified to be used for legitimate purposes.
collection of personal data should be for legitimate purposes
These specify the liability of Joint Controllers, i.e. cases where more than one Controller share the responsiblity.
Personal data retained should be limited in its use only for the requried processing
personal data should be retained and limited for required processing
Whether there is a link between the new and old purposes of processing
link between new and old purpose of processing
Lawful basis is provided through the data being publicly made available by the data subject
GDPR mandates the recording of data breaches and its effects.
This obligation requires the Controller/Processor to maintain adequate records about their processing activities.
maintain records for processing activities involving personal data
The process or technique of promoting, selling, and distributing a product or service.
The maximum validity for all seals and certifications should be 3 years from the date of issue.
Lawful basis for processing is provided by the GDPR for medical or diagnostics purposes pertaining to the data subject
for medical treatement or diagnostics purposes
The activity or process of overseeing an organisation's compliance.
The nature of the personal data involved, whether it is sensitive or confidential.
The right to access personal data should not incur any undue charge levied on the data subject for exercising their right
no undue or unreasonable charges must be levied for right to access
Lawful basis is provided by the GDPR for activities of/for not-for-profit organisations
Consent should not be obtained from silence or inactivity of the data subject
consent should not be taken from silence or inactivity
This obligation specifies that the collected personal data should not be processed beyond the purpose for which it was originally collected without an updated consent for the proposed purposes.
collected personal data should not be used for further processing other than the original purpose
The data subjects were not notified about the data breach because it required disproportionate efforts.
data breach notifications require disproportionate efforts
Affected data subject's must be notified about the consequences of the data breach.
notify data subject about consequences of data breach
Affected data subjects must be notified with the name and contact of the DPO responsible/handling for the data breach.
notify data subject about DPO contact regarding data breach
Affected data subjects must be notified of the data breach and its effects.
Affect data subjets must be notified of the measures taken against the data breach.
notify data subject of measures taken regarding occured data breach
These are the obligations specified by the GDPR. Following the obligations is necessary for compliance.
These are the obligations specified by the GDPR for obtaining consent
obligations for obtaining consent from data subjects
The act of getting a data subject's consent.
The processor must only act on the intructions provided and documented by the controller
only act on documented instructions from Controller
The activity was deemed to be outside the material scope of the GDPR.
Personal data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
The possible consequences of the change in processing for the data subject
A Principle is a rule or standard defined by the GDPR which is essential to be followed for compliance
Privacy by Design is the approach of taking privacy into consideration throughout the whole planning and execution processes.
Processing here refers to an Activity that acts on the Data Subject's personal information.
This type of processing involves data subjects that are vulnerable, such as children, or people with disabilities.
processing affected and/or vulnerable individuals
The data subject can exercise the right to restrict processing of their personal data when the processing is unlawful
This involves processing involving sensitive personal data.
This type of processing uses technologies that are new or have not yet been deemed to be fit or stable for usage.
processing personal data using untested technologies
A natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Signifies the agreement between Controller and Processors for processing of personal data
Agreement between Processor and Controller
These are the obligations specified by the GDPR in the context of Processors
A natural or legal person established in the Union who, designated by the processor in writing, represents the processor with regard to their respective obligations under the GDPR.
To propogate a data subject's right once they have been exercised to other third parties that are involved through the data subject's personal data.
propogate data subject rights to third parties
Protection of data subject's personal data against accidental loss.
protection against accidental loss of personal data
Protection of data subject's personal data against damage to the data.
protection against damage to personal data
Protection of data subject's personal data against destruction of data.
protection against destruction of personal data
Protection of data subject's personal data against unlawful processing of data.
protection against unlawful processing of personal data
The processor must provide the controller with the information necessary to demonstrate compliance
provide Controller with information required for demosntrating compliance
The right of data portability requries providing a copy of the data subject's personal data
provide copy of data subject's personal data
Personal data that can no longer be attributed to a specific data subject without the use of additional information.
Lawful basis is provided by the GDPR as being in the interest of the public
The principle of purpose limitation states that personal data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1) of the GDPR, not be considered to be incompatible with the initial purposes.
These are the obligations over determining the new or changed purposes of processing
The stated obligation could not be completed as it concerns rights and freedoms protection and/or issues of national security.
does not apply over rights and freedoms protection and for national security
Related to Regulation (EC) No. 45/2001
Regulation (EC) No 45/2001 should follow adoption of GDPR
Exempted as the GDPR does not apply to personal or household activity that does not have a professional or commercial activity associated with it.
does not apply to personal or household activity without any professional or commercial activity
Exempted as it involves areas covered by Directive (EU) 2016/680
does not apply to areas covered by Directive (EU) 2016/680
Personal data revealing racial or ethnic origin.
data identifying racial or regional origins
This obligation requires Controllers to record the categories of data subjects and the personal data involved in processing/activities.
record categories of data subjects and personal data involved
This obligation requires Controllers to record the categories of recipients the personal data was shared with.
record categories of recipients where personal data was shared
This obligation requires Controllers to record the cross-border data transfers.
This obligation requires Controllers to record the data retention period of personal data.
This obligation requires Controllers to record the purpose of processing associated with personal data and the given consent.
This obligation requires Controllers to record the measures taken to ensure adequate safety measures of personal data and the involved activities.
Any inaccuracies or discrepancies in the retained data must be rectified
any accuracies in personal data should be rectified
The authority responsible for regulating data protection laws.
Any retained personal data must be relevant for subsiquent processing
retained personal data should be relevant for processing
The act of reporting a data breach to entities mentioned within the GDPR. These are the Data Protection Authority (DPA), and in the case of Processors, the Controller they have an agreement with.
The occurence of a data breach must be reported to the Controller.
The occurence of a data breach must be reported to the Data Protection Authority (DPA) within 72 hours
report data breach to DPA within 72 hours
The stated obligation or activity could not be completed as it requires disproportionate efforts to complete.
Appointing a sub-processor requires the written consent of the controller specifying permission or consent
requires written consent of Controller to appoint Sub-Processor
These provide restrictions on cross-border transfers for Processors
These are the obligations specified by the GDPR on the retention of personal data
The processor must return or destroy personal data at the end of term (of its agreement with the controller)
return or destroy personal data at end of agreement term
The data subject has the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and has the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided.
The data subject has the right to obtain erasure of their personal data
The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data along with additional information about it.
The right to basic information about processing provides data subjects with information about the processing activities involving their personal data
Right to basic information about processing of personal data
The data subject has a right to not be evaluated through automated processing
Right to not be evaluated through automated processing
The data subject has a right to object to direct marketting based on their personal data
The data subject has the right to object to processing of their personal data
Right to object to processing of personal data
The data subject has a right to recitify their personal data
The data subject has the rights to restrict the processing of their personal data
Right to restrict processing of personal data
The right to transparency requires controllers to provide information about the processing activities as well as personal data and its usage in a transparent manner
The GDPR provides several rights to the data subjects which may be exercised at any time by the data subject and which are mandatory for the organisation to provide, comply with, and inform the data subject about.
A seal pertaining to GDPR compliance
GDPR provides for the creation and provision of seals and certificates pertaining to compliance or related activities
This activity refers to security of data subject's personal data.
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.
This activity represents the sharing of data subject's personal data with a third party.
The provided copy of personal data should be in a commonly used format
Obtained consent should be in a demonstrable form
Obtained consent should be distinguishable from other related matters (in the context of the process)
consent should be distinguishable from other matters
The provided copy of personal data should be machine readable
The provided copy of personal data should be structured
The provided copy of personal data should support reuse
GDPR obligation that specifies consent must be specific for it to be valid.
given consent must be specific and must not be ambigious
This obligation states that the collection of personal data should happen only for the specified purposes (for which the data subject has consented).
collection of personal data should take place only for specified purpose
The principle of storage limitation states that personal data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) of the GDPR subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject.
An activity where personal data is being stored
A sub-processor is a processor acting under another processor.
Sub-processors must follow the same rules and obligations (or terms) as the agreement between processor and controller.
Sub-Processor must follow same terms as Processor-Controller have agreed upon
This activity provides a systematic monitoring or overview of processes/activities taking place within the context of the organisation.
systematic monitoring of processing activities
Consent is termed to be valid if it passes all the criteria or obligations laid down by the GDPR.
These are obligations pertaining to the vital interests of the data subjects
Consent must be obtained through the data subject's voluntary action and should be opt-in and not opt-out or by default.
The seals and certifications should be a voluntary system of accredition
This activity represents the data subject withdrawing given consent.
An ontology for representing provenance traces pertainining to GDPR compliance. It uses concepts from GDPRtEXT along with extending PROV and P-Plan.