The Many Bills of Rights
This post is an aggregation of Bills of Rights and Principles developed about data, privacy and social networks.
by Kaliya Hamlin, Identity Woman
The future is at stake – without control over our own personal data, having a copy of all the digital bread crumbs we are leaving behind in the digital world, we leave ourselves to be tracked, and potentially manipulated by commercial interests without our knowledge.
This presents a vision for core aspects of the emerging interoperable, open standards based ecosystem of personal data services – rooted in the core functionality of a Personal Data Store – the vault/locker/services/broker where all an individuals data is collected and stored and managed.
Dignity of the Individual is Core Human dignity must lie at the core of the Personal Data Ecosystem. People must be able to shape how they represent themselves in digital contexts. People need the freedom to shape how they present themselves and how the data they generate in their lives is collected and used.
Systems Must Respect Relationships Relationships must be respected between people, between people and groups, and between groups and groups. The Personal Data Ecosystem must respect that people and communities have different levels of publicness. The relationships that people have with one another must be respected and the social context in which they are formed must be honored.
Remember the Greatness of Groups Personal Data and control over it give people a core human dignity. It also must be remembered that human social life and human identity is shaped by our participation and membership in groups. It is the core organizing form of our society. Fundamental functionality must enable people to organize in groups, and it must be abstracted from any particular service or domain space.
The Social Web is not Networked Individualism People broadcasting what they do to their friends or followers does not make a social web; communities and groups do.
Protocols that Enable Broad Possibilities are Essential Protocols matter deeply: they shape what is possible by their definition of use cases that are possible or not in a given protocol landscape. To have a truly social and dynamic web, there is a role for protocols that are designed specifically for that purpose, not just to create web pages or send emails.
Open Standards for Data and Metadata are Essential It is vital that the personal data store ecosystem be interoperable with open standards so people are free to choose which personal data services they wish to use. Just like people are free to pick which bank to hold their money and provide services to them in the financial realm.
Defaults Must Work for Most People Most of the Time All systems have defaults. The paradox of choice is that more options can overwhelm people and they end up not considering the choices they have. Real people need to have input into the creation and ongoing development of systemic defaults.
Norms and Practices in the Personal Data Ecosystem Must be Backed up by Law Emerging technologies need to have legal agreements and frameworks innovated to match their functionality. The work on the legal framework for this ecosystem is as important as the protocols and code that make it go.
Business Opportunities Abound in this New Personal Data Ecosystem The paradigm of user collection, control and management of the personal data they are creating implicitly and explicitly around the web is a huge opportunity for services and ways of doing business. Creativity is needed to think through these new possibilities.
Diversity is Key to the Success of the Personal Data Ecosystem Large companies and nimble startups are all needed for the success of this emerging ecosystem.
by Phil Windley, CTO Kynetx, Technometria Blog
Here’s a list of a few things that I think distinguish a PDX from just places where your personal data is stored:
- user-controlled – the user needs to be in control of the data, who has access, and how it is used. Once that data is in my PDX, I make decisions about it. That doesn’t mean the data might not also be somewhere else. For example, data about my purchases from Amazon will certainly be stored at Amazon and not under my control. But I might also be emailing the receipts to a service that parses them and puts the data in my PDX for my use.
- federated – there isn’t one place where your data is stored, but multiple places that the data needs to be able to flow between, in a permissioned way. There’s no center, just a lot of cooperating system with my PDX orchestrating the interactions. While Amazon might not give my PDX access to and control over my transactions, my phone company might provide a PDX-capable contact service where I choose to store my contact information.
- interoperable – various PDX services and brokers have to be able to operate together according to standards to perform their roles. When I take money out of my account at Wells Fargo and deposit it at Chase, I don’t lose part of the value because Chase doesn’t know how to handle some part of the transaction. The monetary system is interoperable with standards and, sometimes, shims that connect it all together.
- semantic – a PDX knows more about the data that it holds than existing data stores do. Consider Dropbox. I can put all kinds of things in my Dropbox, but it’s syntactic, not semantic. By that I mean that if I want to put healthcare data in Dropbox and control who uses it, I create a folder and put the data in it with specific permissions. The fact that there is a folder with a certain name located at a particular place in the folder hierarchy is purely syntactic. In a semantic world, the data itself is tagged as healthcare data and no matter where it is, it’s protected according to the policies I’ve put in place.
- portability – a PDX doesn’t trap data in proprietary formats. If my phone company is storing my contact data in the cloud and I decide that I want to move it to my own server or another service, I can—from a technical as well as a policy standpoint. Note that this doesn’t mean we have to wait until thousands upon thousands of data format specification get hammered out. Semantic metadata can provide a means of translating from one format to another.
- metadata management – one of the primary roles of the PDX is managing data about my data. What are the roles I’ve created? What permissions have I granted as exceptions to the defaults? What semantics surround the various data fields? What data sharing, encoding, and encrypting policies have I created? All of this has to be kept and managed in my behalf in the PDX.
- broker services – the PDX is a place where the user manages a federated network of data stores. As an example of why this is important, consider the shortcomings of OAuth. If I use an application that needs access to four OAuth mediated APIs, I have to go through the OAuth ceremnoy with each API provider separately. Now consider that I might have dozens of apps that use a popular API. I have to go through the OAuth ceremony for each of them separately. In short a broker saves us from the N x M explosion of permissioning ceremonies. Similarly for various data services.
- discoverable – a PDX should provide discoverability for its APIs and schemas so that any application I’m interested in knows how to interact with it. Discoverability protects users from having to completely specify addresses, mappings, and schemas to every application that comes along.
- automatable and scriptable – a PDX without automation is worse than no PDX at all because it burdens the user rather than saving effort. A PDX will be a player in a larger ecosystem of services. I don’t see is as a mere API that allows services and applications to GET and PUT data—it’s not WEBDAV on steoids. The PDX is an active participant in the greater ecosystem of services that are cooperating on the user’s behalf.
June 18, 2010
Computers Freedom and Privacy Conference
For more background on the social network users’ bill of rights, also known as #BillOfRights, please see It’s time for a Social Network Users’ Bill of Rights,
We the users expect social network sites to provide us the following rights in their Terms of Service, Privacy Policies, and implementations of their system:
- Clarity: Make sure that policies, terms of service, and settings are easy to find and understand
- Freedom of speech: Do not delete or modify my data without a clear policy and justification
- Empowerment : Support assistive technologies and universal accessibility
- Self-protection: Support privacy-enhancing technologies
- Data minimization: Minimize the information I am required to provide and share with others
- Control: Let me control my data, and don’t facilitate sharing it unless I agree first
- Predictability: Obtain my prior consent before significantly changing who can see my data.
- Data portability: Make it easy for me to obtain a copy of my data
- Protection: Treat my data as securely as your own confidential data unless I choose to share it, and notify me if it is compromised
- Right to know: Show me how you are using my data and allow me to see who and what has access to it.
- Right to self-define: Let me create more than one identity and use pseudonyms. Do not link them without my permission.
- Right to appeal: Allow me to appeal punitive actions
- Right to withdraw: Allow me to delete my account, and remove my data
May 19, 2010
Commentary by Kurt Opsahl, EFF
Social network service providers today are in a unique position. They are intermediaries and hosts to our communications, conversations and connections with loved ones, family, friends and colleagues. They have access to extremely sensitive information, including data gathered over time and from many different individuals.
Here at EFF, we’ve been thinking a lot recently about what specific rights a responsible social network service should provide to its users. Social network services must ensure that users have ongoing privacy and control over personal information stored with the service. Users are not just a commodity, and their rights must be respected. Innovation in social network services is important, but it must remain consistent with, rather than undermine, user privacy and control. Based on what we see today, therefore, we suggest three basic privacy-protective principles that social network users should demand:
#1: The Right to Informed Decision-Making
Users should have the right to a clear user interface that allows them to make informed choices about who sees their data and how it is used.
Users should be able to see readily who is entitled to access any particular piece of information about them, including other people, government officials, websites, applications, advertisers and advertising networks and services.
Whenever possible, a social network service should give users notice when the government or a private party uses legal or administrative processes to seek information about them, so that users have a meaningful opportunity to respond.
#2: The Right to Control
Social network services must ensure that users retain control over the use and disclosure of their data. A social network service should take only a limited license to use data for the purpose for which it was originally given to the provider. When the service wants to make a secondary use of the data, it must obtain explicit opt-in permission from the user. The right to control includes users’ right to decide whether their friends may authorize the service to disclose their personal information to third-party websites and applications.
Social network services must ask their users’ permission before making any change that could share new data about users, share users’ data with new categories of people, or use that data in a new way. Changes like this should be “opt-in” by default, not “opt-out,” meaning that users’ data is not shared unless a user makes an informed decision to share it. If a social network service is adding some functionality that its users really want, then it should not have to resort to unclear or misleading interfaces to get people to use it.
#3: The Right to Leave
Users giveth, and users should have the right to taketh away.
One of the most basic ways that users can protect their privacy is by leaving a social network service that does not sufficiently protect it. Therefore, a user should have the right to delete data or her entire account from a social network service. And we mean really delete. It is not enough for a service to disable access to data while continuing to store or use it. It should be permanently eliminated from the service’s servers.
Furthermore, if users decide to leave a social network service, they should be able to easily, efficiently and freely take their uploaded information away from that service and move it to a different one in a usable format. This concept, known as “data portability” or “data liberation,” is fundamental to promote competition and ensure that users truly maintain control over their information, even if they sever their relationship with a particular service.
June 22, 2009
endorsed by many organizations and companies
In an era when technology allows personal health information to be more easily stored, updated, accessed and exchanged, the following rights should be self-evident and inalienable. We the people:
- Have the right to our own health data
- Have the right to know the source of each health data element
- Have the right to take possession of a complete copy of our individual health data, without delay, at minimal or no cost; if data exist in computable form, they must be made available in that form
- Have the right to share our health data with others as we see fit
These principles express basic human rights as well as essential elements of health care that is participatory, appropriate and in the interests of each patient. No law or policy should abridge these rights.
Mobility in a Networked World The Global Information Technology Report 2008-2009, World Economic Forum
The first step toward open information markets is to give people ownership of their data. The simplest approach to defining what it means to “own your own data” is to go back to Old English Common Law for the three basic tenets of ownership, which are the rights of possession, use, and disposal:
1. You have a right to possess your data. Companies should adopt the role of a Swiss bank account for your data. You open an account (anonymously, if possible), and you can remove your data whenever you’d like.
2. You, the data owner, must have full control over the use of your data. If you’re not happy with the way a company uses your data, you can remove it. All of it. Everything must be opt-in, and not only clearly explained in plain language, but with regular reminders that you have the option to opt out.
3. You have a right to dispose or distribute your data. If you want to destroy it or remove it and redeploy it elsewhere, it is your call. Ownership seems to be the minimal guideline for the “new deal on data.” There needs to be one more principle, however—which is to adopt policies that encourage the combination of massive amounts of anonymous data to promote the Common Good. Aggregate and anonymous location data can dramatically improve society. Patterns of how people move around can be used for early identification of infectious disease outbreaks, protection of the environment, and public safety. It can also help us measure the effectiveness of various government programs, and improve the transparency and accountability of government and nonprofit organizations.
At a Crossroads: Personhood and Digital Identity in the Information Society
articulated by Bob Blakley, Jeff Broberg, Anthony Nadalin, Dale Olds, Mary Ruddy, Mary Rundle, and Paul Trevithick.
Identity behaves according to a number of observable properties, as follows:
Identity is social. Humans are naturally social. To engage in social interactions (including commerce) people need something that persists and that can be used as a basis for recognition of others – an “identity”.
Identity is subjective. Different people have different experiences with the same individual and therefore attribute different characteristics to that individual; that is, they will construct different identities for him.
Identity is valuable. By building a history of a person’s past actions, exchange of identity information creates social capital and enables transactions that wouldn’t be possible without identity. In other words, identity lends predictability to afford a comfortable level of confidence for people making decisions.
Identity is referential. An identity is not a person; it is only a reference to a person. Even if a person develops spin-off personas so that other people know him through those various digital identities, and even if others create profiles of a person, ultimately the collection of characteristics that signal who a person is need to point back to that person.
Identity is composite. Some information about a person arises from the person himself; he volunteers it. But other information about him is developed by others without his involvement.
Identity is consequential. Because identity tells of a person’s past actions, the decision to exchange identity information carries consequences: Disclosure of identity information in a certain context can cause harm; failure to disclose identity information in another context can create risk.
Identity is dynamic. Identity information is always changing; any particular identity dossier might be inaccurate at any given moment.
Identity is contextual. People have different identities that they may wish to keep entirely separate. Information can be harmful in the wrong context, or it can simply be irrelevant. Keeping identities separate allows a person to have more autonomy.
Identity is equivocal. The process of identification is inherently error-prone.
September 5, 2007
By Joseph Smarr, Marc Canter, Robert Scoble, and Michael Arrington, Open Social Web
We publicly assert that all users of the social web are entitled to certain fundamental rights, specifically:
Ownership of their own personal information, including:
- their own profile data
- the list of people they are connected to
- the activity stream of content they create;
Control of whether and how such personal information is shared with others; and
Freedom to grant persistent access to their personal information to trusted external sites.
Sites supporting these rights shall:
- Allow their users to syndicate their own profile data, their friends list, and the data that’s shared with them via the service, using a persistent URL or API token and open data formats;
- Allow their users to syndicate their own stream of activity outside the site;
- Allow their users to link from their profile pages to external identifiers in a public way; and
- Allow their users to discover who else they know is also on their site, using the same external identifiers made available for lookup within the service.
April 25, 2007
By John Battelle, The Search Blog
So, I submit for your review, editing and clarification, a new draft of what rights we, as consumers, might demand from companies making hay off the data we create as we trip across the web:
- Data Transparency. We can identify and review the data that companies have about us. A sticky issue is whether we can also identify and review data that is made about us based on other data the company might have. (IE, based on your behavior, we at Amazon know you might also like….)
- Data Portability. We can take copies of that data out of the company’s coffers and offer it to others or just keep copies for ourselves.
- Data Editing. We can request deletions, editing, clarifications of our data for accuracy and privacy.
- Data Anonymity. We can request that our data not be used, cognizant of the fact that that may mean services are unavailable to us.
- Data Use. We have rights to know how our data is being used inside a company.
- Data Value. The right to sell our data to the highest bidder.
- Data Permissions. The right to set permissions as to who might use/benefit from/have access to our data.
Read more: http://battellemedia.com/archives/2007/04/the_data_bill_of_rights#ixzz1KwXPBJkN
July 27, 2005
By Seth Goldstein
The choruses of attention, data, privacy and identity are all converging in one giant conceptual mashup, which stretches from Web 2.0 pundits to members of Congress grappling with identity theft regulation. Lost at times are the basic rights we are fighting for, which I understand to be:
- You have the right to yourself.
- You have the right to your gestures.
- You have the right to your words.
- You have the right to your interests.
- You have the right to your attention.
- You have the right to your intentions.
1. User Control and Consent: Digital identity systems must only reveal information identifying a user with the user’s consent.
2. Limited Disclosure for Limited Use: The solution which discloses the least identifying information and best limits its use is the most stable, long-term solution.
3. The Law of Fewest Parties: Digital identity systems must limit disclosure of identifying information to parties having a necessary and justifiable place in a given identity relationship.
4. Directed Identity: A universal identity metasystem must support both “omnidirectional” identifiers for use by public entities and “unidirectional” identifiers for private entities, thus facilitating discovery while preventing unnecessary release of correlation handles.
5. Pluralism of Operators and Technologies: A universal identity metasystem must channel and enable the interworking of multiple identity technologies run by multiple identity providers.
6. Human Integration: A unifying identity metasystem must define the human user as a component integrated through protected and unambiguous human-machine communications.
7. Consistent Experience Across Contexts: A unifying identity metasystem must provide a simple consistent experience while enabling separation of contexts through multiple operators and technologies.
January 26th, 2000
by Rolf Kosters
When a time comes that new modes and venues exist for communities, and said modes are different enough from the existing ones that question arises as to the applicability of past custom and law; and when said venues have become a forum for interaction and society for the general public regardless of the intent of the creators of said venue; and at a time when said communities and spaces are rising in popularity and are now widely exploited for commercial gain; it behooves those involved in said communities and venues to affirm and declare the inalienable rights of the members of said communities. Therefore herein have been set forth those rights which are inalienable rights of the inhabitants of virtual spaces of all sorts, in their form henceforth referred to as avatars, in order that this declaration may continually remind those who hold power over virtual spaces and the avatars contained therein of their duties and responsibilities; in order that the forms of administration of a virtual space may be at any time compared to that of other virtual spaces; and in order that the grievances of players may hereafter be judged against the explicit rights set forth, to better govern the virtual space and improve the general welfare and happiness of all.
Therefore this document holds the following truths to be self-evident: That avatars are the manifestation of actual people in an online medium, and that their utterances, actions, thoughts, and emotions should be considered to be as valid as the utterances, actions, thoughts, and emotions of people in any other forum, venue, location, or space. That the well-established rights of man approved by the National Assembly of France on August 26th of 1789 do therefore apply to avatars in full measure saving only the aspects of said rights that do not pertain in a virtual space or which must be abrogated in order to ensure the continued existence of the space in question. That by the act of affirming membership in the community within the virtual space, the avatars form a social contract with the community, forming a populace which may and must self-affirm and self-impose rights and concomitant restrictions upon their behavior. That the nature of virtual spaces is such that there must, by physical law, always be a higher power or administrator who maintains the space and has complete power over all participants, but who is undeniably part of the community formed within the space and who must therefore take action in accord with that which benefits the space as well as the participants, and who therefore also has the rights of avatars and may have other rights as well. That the ease of moving between virtual spaces and the potential transience of the community do not limit or reduce the level of emotional and social involvement that avatars may have with the community, and that therefore the ease of moving between virtual spaces and the potential transience of the community do not in any way limit, curtail, or remove these rights from avatars on the alleged grounds that avatars can always simply leave.
- Avatars are created free and equal in rights. Special powers or privileges shall be founded solely on the common good, and not based on whim, favoritism, nepotism, or the caprice of those who hold power. Those who act as ordinary avatars within the space shall all have only the rights of normal avatars.
- The aim of virtual communities is the common good of its citizenry, from which arise the rights of avatars. Foremost among these rights is the right to be treated as people and not as disembodied, meaningless, soulless puppets. Inherent in this right are therefore the natural and inalienable rights of man. These rights are liberty, property, security, and resistance to oppression.
- The principle of all sovereignty in a virtual space resides in the inalterable fact that somewhere there resides an individual who controls the hardware on which the virtual space is running, and the software with which it is created, and the database which makes up its existence. However, the body populace has the right to know and demand the enforcement of the standards by which this individual uses this power over the community, as authority must proceed from the community; a community that does not know the standards by which the administrators use their power is a community which permits its administrators to have no standards, and is therefore a community abetting in tyranny.
- Liberty consists of the freedom to do anything which injures no one else including the weal of the community as a whole and as an entity instantiated on hardware and by software; the exercise of the natural rights of avatars are therefore limited solely by the rights of other avatars sharing the same space and participating in the same community. These limits can only be determined by a clear code of conduct.
- The code of conduct can only prohibit those actions and utterances that are hurtful to society, inclusive of the harm that may be done to the fabric of the virtual space via hurt done to the hardware, software, or data; and likewise inclusive of the harm that may be done to the individual who maintains said hardware, software, or data, in that harm done to this individual may result in direct harm done to the community.
- The code of conduct is the expression of the general will of the community and the will of the individual who maintains the hardware and software that makes up the virtual space. Every member of the community has the right to contribute either directly or via representatives in the shaping of the code of conduct as the culture of the virtual space evolves, particularly as it evolves in directions that the administrator did not predict; the ultimate right of the administrator to shape and define the code of conduct shall not be abrogated, but it is clear that the administrator therefore has the duty and responsibility to work with the community to arrive at a code of conduct that is shaped by the input of the community. As a member of the community himself, the administrator would be damaging the community itself if he failed in this responsibility, for abrogation of this right of avatars could result in the loss of population and therefore damage to the common weal.
- No avatar shall be accused, muzzled, toaded, jailed, banned, or otherwise punished except in the cases and according to the forms prescribed by the code of conduct. Any one soliciting, transmitting, executing, or causing to be executed, any arbitrary order, shall be punished, even if said individual is one who has been granted special powers or privileges within the virtual space. But any avatar summoned or arrested in virtue of the code of conduct shall submit without delay, as resistance constitutes an offense.
- The code of conduct shall provide for such punishments only as are strictly and obviously necessary, and no one shall suffer punishment except it be legally inflicted according to the provisions of a code of conduct promulgated before the commission of the offense; save in the case where the offense endangered the continued existence of the virtual space by attacking the hardware or software that provide the physical existence of the space.
- As all avatars are held innocent until they shall have been declared guilty, if detainment, temporary banning, jailing, gluing, freezing, or toading shall be deemed indispensable, all harshness not essential to the securing of the prisoner’s person shall be severely repressed by the code of conduct.
- No one shall be disquieted on account of his opinions, provided their manifestation does not disturb the public order established by the code of conduct.
- The free communication of ideas and opinions is one of the most precious of the rights of man. Every avatar may, accordingly, speak, write, chat, post, and print with freedom, but shall be responsible for such abuses of this freedom as shall be defined by the code of conduct, most particularly the abuse of affecting the performance of the space or the performance of a given avatar’s representation of the space.
- The security of the rights of avatars requires the existence of avatars with special powers and privileges, who are empowered to enforce the provisions of the code of conduct. These powers and privileges are therefore granted for the good of all and not for the personal advantage of those to whom they shall be entrusted. These powers and privileges are also therefore not an entitlement, and can and should be removed in any instance where they are no longer used for the good of all, even if the offense is merely inactivity
- A common contribution may, at the discretion of the individual who maintains the hardware, the software, and the data that make up the virtual space, be required in order to maintain the existence of avatars who enforce the code of conduct and to maintain the hardware and the software and the continued existence of the virtual space. Avatars have the right to know the nature and amount of the contribution in advance, and said required contribution should be equitably distributed among all the citizens without regard to their social position; special rights and privileges shall never pertain to the avatar who contributes more except insofar as the special powers and privileges require greater resources from the hardware, software, or data store, and would not be possible save for the resources obtainable with the contribution; and as long as any and all avatars are able to make this contribution and therefore gain the powers and privileges if they so choose; nor shall any articles of this declaration be contingent upon a contribution being made.
- The community has the right to require of every administrator or individual with special powers and privileges granted for the purpose of administration, an account of his administration.
- A virtual community in which the observance of the code of conduct is not assured and universal, nor the separation of powers defined, has no constitution at all.
- Since property is an inviolable and sacred right, and the virtual equivalent is integrity and persistence of data, no one shall be deprived thereof except where public necessity, legally determined per the code of conduct, shall clearly demand it, and then only on condition that the avatar shall have been previously and equitably indemnified, saving only cases wherein the continued existence of the space is jeopardized by the existence or integrity of said data.
- The administrators of the virtual space shall not abridge the freedom of assembly, save to preserve the performance and continued viability of the virtual space.
- Avatars have the right to be secure in their persons, communications, designated private spaces, and effects, against unreasonable snooping, eavesdropping, searching and seizures, no activity pertaining thereto shall be undertaken by administrators save with probable cause supported by affirmation, particularly describing the goal of said investigations.
- The enumeration in this document of rights shall not be construed to deny or disparage others retained by avatars.
September 23, 1980
Collection Limitation Principle: There should be limits to the collection of personal data and any such data should be obtained by lawful and fair means and, where appropriate, with the knowledge or consent of the data subject.
Data Quality Principle: Personal data should be relevant to the purposes for which they are to be used, and, to the extent necessary for those purposes, should be accurate, complete and kept up-to-date.
Purpose Specification Principle: The purposes for which personal data are collected should be specified not later than at the time of data collection and the subsequent use limited to the fulfilment of those purposes or such others as are not incompatible with those purposes and as are specified on each occasion of change of purpose.
Use Limitation Principle: Personal data should not be disclosed, made available or otherwise used for purposes other than those specified in accordance with Paragraph 9 except:
a) with the consent of the data subject; or
b) by the authority of law.
Security Safeguards Principle: Personal data should be protected by reasonable security safeguards against such risks as loss or unauthorised access, destruction, use, modification or disclosure of data.
Openness Principle: There should be a general policy of openness about developments, practices and policies with respect to personal data. Means should be readily available of establishing the existence and nature of personal data, and the main purposes of their use, as well as the identity and usual residence of the data controller.
Individual Participation Principle: An individual should have the right:
a) to obtain from a data controller, or otherwise, confirmation of whether or not the data controller has data relating to him;
b) to have communicated to him, data relating to him
1. within a reasonable time;
2. at a charge, if any, that is not excessive;
3. in a reasonable manner; and
4. in a form that is readily intelligible to him;
c) to be given reasons if a request made under subparagraphs (a) and (b) is denied, and to be able to challenge such denial; and
d) to challenge data relating to him and, if the challenge is successful to have the data erased, rectified, completed or amended.
Accountability Principle: A data controller should be accountable for complying with measures which give effect to the principles stated above.