Publications
18 January, 2023
Policy briefing on retained EU Law (Revocation and Reform) bill
Net neutrality to sunset if Retained EU Law Bill is passed
Retained Retained EU Law (Revocation and Reform) Bill will wipe out net neutrality from UK law on 31 December this year.
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16 January, 2023
Online Safety Bill third reading briefing
Briefing to inform the Third Reading debate in the House of Commons on 17 January 2023
Unintended consequences of the Online Safety Bill mean a trio of surveillance, prior restraint of speech, and restriction on access to online content and services.
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16 January, 2023
Policy briefing – Criminal liability for content harmful to children
A Policy briefing
Criminal liability for content harmful to children
Amendment NC2 Sir William Cash and Miriam Cates
Drafted by Dr Monica Horten – 16 Jan 2023
The Amendment is not about child protection.
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09 January, 2023
Council’s Against Data Discrimination: Model Council Motion
Council Motion on Stopping Data Discrimination:Council Notes:
– That UK GDPR, and the Data Protection Act 2018 protects individuals from harmful or discriminatory uses of their data.
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09 January, 2023
Data Discrimination: 10 Questions to Your Council
A guide for local authority Councillors wishing to prevent data discrimination occurring within their Council.
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05 January, 2023
The Online Safety Bill – Sector Support Roundtable
In September 2022, Open Rights Group convened a discussion between privacy and data protection experts and other civil society professionals exploring the nexus between privacy, protection from online abuse and freedom of expression.
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27 October, 2022
Response to Call for information: Unauthorised access to online accounts and personal data
ORG submission to the Home Office consultation on a duty to cyberprotect
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30 November, 2022
Who’s checking on your chats in private online spaces?
A policy brief on the inclusion of private communications in scope of the Online Safety Bill and the impact on end-to-end encryption
Chat monitoring of private messaging services has sneaked into the Online Safety Bill with very little public debate or Parliamentary Scrutiny.
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20 October, 2022
Campaign Pack – Data Discrimination Bill
Stop the Data Discrimination Bill Campaign Pack for ORG campaigners October 2022 – V1 CC BY-SA 3.
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19 October, 2022
Analysis: The UK Data Protection and Digital Information Bill
Open Rights Group analysis of the UK Data Protection and Digital Information Bill, as it was presented on 18 July 2022
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19 October, 2022
Stop the Data Discrimination Bill Leaflet
You can download and print this leaflet to use in campaigning against the Data Discrimination Bill.
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30 September, 2022
ORG response to the DCMS policy paper “Establishing a pro-innovation approach to regulating AI”
ORG response to the Government approach to regulating Artificial Intelligence
0 Executive Summary
Open Rights Group (ORG) is a UK-based digital campaigning organisation working to protect fundamental rights to privacy and free speech online.
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18 July, 2022
DATA THE WRONG DIRECTION
All the issues we expect to see in the UK Data Reform Bill
A summary of all the issue we expect to find in the upcoming UK Data Reform Bill
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14 July, 2022
Consultation response: Police extraction powers code
Open Rights Group’s Response to the Government consultation on the draft code of practice around powers for the extraction of information from electronic devices in the Police, Crime, Sentencing and Courts Act 2022.
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29 June, 2022
Submission to Parliament on Online Safety Bill
SUBMISSION TO PARLIAMENT Addressing automated, arbitrary, algorithmic censorship in the Online Safety BillJune 2022
Contents
About Open Rights Group 2
Addressing automated, arbitrary algorithmic censorship 2
Our concerns and recommendations 2
Summary 3
Automated censorship and arbitrary restrictions 4
Content moderation systems 5
Arbitrary restrictions 6
Why prevent has a special meaning (prior restraint) 9
Hands, face, age-gate 9
Ministerial powers to interfere with speech 10
Chat controls, to do lists and the spy in the your pocket 11
User Dis- Empowerment 13
Rights for online speech 13
Procedural safeguards and effective remedies 15
User experiences of restrictive content moderation measures 15
Procedural safeguards against arbitrary take-downs 16
About Open Rights Group
Open Rights Group (ORG) is the leading UK-based digital campaigning organisation.
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10 June, 2022
Open Letter to the DCMS – 10 June 2022
The Rt Hon Nadine Dorries MP,
Secretary of State,
Department for Digital, Culture, Media and Sport,
10 June 2022
Dear Secretary of State,
During the last Queen’s Speech, the Government announced the introduction of a Data Reform Bill, which will replace the United Kingdom’s existing data protection laws.
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16 May, 2022
Homes for Ukraine scheme: Open letter to Department for Levelling Up, Housing and Communities and Home Office
The Open Rights Group and our coalition of frontline migrants’ rights groups, including Refugee Action has written to the Department for Levelling Up, Housing and Communities and the Home Office to express our serious concerns regarding the data practices involved in the Homes for Ukraine Scheme.
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27 April, 2022
Online Safety Bill Second Reading briefing
ORG analysis and highlights concerning the Online Safety Bill and its adverse impact on human rights and the free internet
About Open Rights Group
Open Rights Group (ORG) is the leading UK-based digital campaigning organisation.
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06 April, 2022
Organisational Strategy Consultancy – Invitation to Tender
Staff Strategy and Planning Away Days / Workshop
Background and introduction
We’re looking to bring in an external organisational strategy consultant / facilitator to design, deliver and facilitate ORG’s first ‘in-person’ two-day workshop for a newly expanded staff team to ensure our ‘Strategic Priority Areas’ as defined by ‘The Strategy (2022-2025)’ are fully aligned with our ‘Strategic Objectives’ (goals) and a range of ‘outcomes’, ‘outputs’, ‘activities’, and ‘tasks’ across a range of our ‘programmes’, ‘projects’, and ‘campaigns’.
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04 April, 2022
ORG Representative actions under the UK GDPR
ORG Guide and lessons learnt report on our experience with representative actions under article 80(1) of the UK GDPR
1 Introduction
This report is about Open Rights Group (ORG) experience with representative actions under article 80(1) of the UK GDPR and Section 187 of the Data Protection Act 2018 (DPA).
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08 March, 2022
ORG response to the MoJ Human Rights Act Reform: A Modern Bill of Rights
We commented the Ministry of Justice proposals to reform the Human Rights Act 1998, focussing on the adverse consequences for the right to data protection.
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07 February, 2022
ORG – EDRi joint submission to the ICO Technology and Innovation Foresight call for views: Biometric Technologies
ORG – EDRi joint submission to the ICO on the issues surrounding the use of biometric data
p.
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07 February, 2022
Experts challenge Govt’s anti-encryption campaign
Leading cybersecurity experts and human rights activists say scaremongering tactics being used to mislead the public and make bogus case for weakening encryption.
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03 January, 2022
ORG submission to the Information Commissioner’s Office
The use of age assurance
ORG response to the ICO consultation on methods of age assurance
Open Rights Group (ORG) is a UK-based digital campaigning organisation working to protect fundamental rights to privacy and free speech online.
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17 January, 2022
Parliamentary briefing note on proposed legislative amendments to the Immigration Exemption
Briefing to the Statutory Instruments (Joint Committee)
The Data Protection Act 2018 (Amendment of Schedule 2 Exemptions) Regulations 2022
The above statutory instrument is due to be considered by the Joint Committee.
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19 November, 2021
PCAG ORG consultation roundtable – Data: a new direction
Privacy and Consumer Advisory Group and Open Rights Group consultation roundtable on Data: a new direction
Data Reform Consultation Roundtable
Focussing on the Privacy and Digital Rights of Individuals
Convened by the Privacy and Consumer Advisory Group (PCAG)1 and the Open Rights Group2
Headline messages
Participants in this roundtable felt that the proposals typically saw data protection in terms of unnecessary burden on organisations (see 1.
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19 November, 2021
Open Rights Group Response to Data: a new direction
Open Rights Group submission to oppose DCMS plans to water down data protection in Data: a new direction
EXECUTIVE SUMMARY
On 10 September 2021, the Department for Digital, Culture, Media and Sport (DCMS) published “Data: a new direction”, a consultation about reforms to the UK data protection framework.
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07 October, 2021
ORG submission to the Information Commissioner’s Office – International Transfers Under the UK GDPR
Open Rights Group (ORG) is a UK-based digital campaigning organisation working to protect fundamental rights to privacy and free speech online.
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01 October, 2021
ORG submission to the DCMS — Plan for Digital Regulation
ORG answer to the DCMS consultation on the Government Plan for Digital Regulation
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23 July, 2021
RESPONSE TO HOME OFFICE LEGISLATION TO COUNTER STATE THREATS CONSULTATION
Open Rights Group (ORG) is a UK-based digital campaigning organisation working to protect fundamental rights to privacy and free speech online.
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09 July, 2021
Submission to the Competition and Markets Authority re: Google Privacy Sandbox
Open Rights Group submission to the Competition and Markets Authority “Notice of intention to accept binding commitments offered by Google in relation to its Privacy Sandbox Proposals” 9 July 2021
Table of Contents
Executive Summary
A.
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15 June, 2021
Computer Misuse Act 1990: Open Rights Group submission to the Home Office
ORG answer to the Home Office call for information regarding the Computer Misuse Act 1990
Computer Misuse Act 1990: call for information
Open Rights Group submission to the Home Office
Context
Q1.
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02 June, 2021
ORG Response to the consultation on the National Fraud Initiative Data Matching Powers proposals
This response is to the Cabinet Office’s National Fraud Initiative (NFI) Data Matching Powers consultation proposals.
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01 June, 2021
ePrivacy Regulation and privacy automation
An Open Letter from 34 civil society organisations, asking for the introduction of automated privacy signals
Dear Member of the European Parliament,
A nuisance is troubling the internet and the digital life of Europeans: the consent or ‘cookie’ banner.
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16 May, 2021
Response to the Joint Committee on Human Rights inquiry into Freedom of Expression
This inquiry focuses on freedom of expression as an essential foundation of democratic society, guaranteed by the common law and by Article 10 of the European Convention on Human Rights.
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21 April, 2021
Briefing on the National Fraud Initiative Data Matching Powers consultation proposals
This briefing summarises our main concerns with the Cabinet Office’s National Fraud Initiative Data Matching Powers consultation proposals.
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14 April, 2021
Adtech Open Letter to the European Parliament
The Open Rights Group has teamed up with 30 human & digital rights organisations to ask Members of the European Parliament to ban unlawful tracking & surveillance in online advertising.
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14 April, 2021
ePrivacy Regulation – an open letter from 30 civil society organisations
Our letter to the European Parliament asking them to stand up against online tracking
Dear Members of the European Parliament,
The undersigned organisations urge the European Parliament to ensure a high level of protection of privacy and confidentiality in the upcoming ePrivacy Regulation and to address the weakness in the current Council position during trilogue negotiations.
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29 March, 2021
Open Rights Group Response to the Cabinet Office “COVID-Status Certification Review – Call for evidence”
Our response to Government plans to introduce vaccine passports
Table of Contents
Question 1
Question 2
0.
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11 March, 2021
Joint letter to National Fraud Initiative re: Consultation extension
Joint letter to Head of National Fraud Initiative (NFI) Team requesting that deadline for NFI Data Matching Powers consultation be extended until May 2021.
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08 March, 2021
DATA FLOWS AND TRADE AGREEMENTS
Briefing to Department for International Trade
1 Risks to adequacy systems and data protection in UK-Japan and CPTPP
1.
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02 March, 2021
The UK’s Immigration Exemption in the Data Protection Act 2018 and data adequacy
A submission to the European Commission and the European Data Protection Board on the operation of the UK’s operation Immigration Exemption in the Data Protection Act 2018 and its effect on standards of data protection in the United Kingdom
This submission to the European Commission and European Data Protection Board seeks to assist your respective duties in relation to the assessment of the United Kingdom to determine whether it provides adequate protection under Article 45 of the General Data Protection Regulation.
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25 January, 2021
ICO enforcement overview – supporting data
Overview of ICO enforcement action, based on their transparency information
In this overview, we took stock of ICO enforcement and penalty notices that were released following the entry into force of the GDPR (2018).
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15 January, 2021
Response to the Lords Communications Committee enquiry into freedom of expression online
Open Rights Group are grateful for the opportunity to provide our input to the Lords Communications Committee enquiry into freedom of expression online.
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12 January, 2021
Open Rights Group: Response to the Law Commission Reform of the Communications Offences
Joint submission of the Open Rights Group and Preiskel & Co LLP
Harmful Online CommunicationsJoint submission of the Open Rights Group and Preiskel & Co LLP
This is a short joint submission to the Law Commission’s Harmful Online Offences consultation.
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11 January, 2021
Open Rights Group: Response to the Consultation on the Digital Strategy for Scotland
Open Rights Group welcomes the publication of the discussion document, and is grateful for the Scottish Government’s continuing engagement with us as the strategy has developed.
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10 December, 2020
Open Letter: Impact of the National Data Strategy on migrants and refugees
Open letter to the Secretary of State for Digital, Culture, Media and Sports on the impact of the National Data Strategy on migrants and refugees.
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09 December, 2020
Open Rights Group: Consultation response to the National Data Strategy
Open Rights Group are grateful for the opportunity to provide our input on the National Data Strategy consultation.
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02 December, 2020
Japan Trade deal letter from MPs
Dear Minister Liz Truss,
We are writing as a cross-party group of MPs who are deeply concerned by the lack of time, information and analysis available given to us and Parliament to consider the impact of the digital trade clauses in the UK-Japan Comprehensive Economic Partnership Agreement.
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02 December, 2020
Immigration, Data and Technology: Needs and Capacities of the Immigration Sector
This report is based on the findings of a survey launched earlier this year with Privacy International to identify the needs and capacities of migrants’ rights organisations to respond to data, privacy and the use of new technologies.
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16 November, 2020
Consumer and Digital Rights Groups Call on the International Joint Initiative on E-Commerce to Safeguard Data Protection and Privacy
Since January 2019, more than 80 countries of the World Trade Organization (WTO) have been negotiating a new rule book for digital trade.
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06 November, 2020
Briefing: how the UK-Japan trade deal severs post-Brexit data adequacy
WHAT THE UK-JAPAN TRADE DEAL MEANS FOR DIGITAL RIGHTS
5 November 2020 Javier Ruiz
INTRODUCTION
The UK has just signed its first new free trade agreement independently from the EU, with Japan.
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23 October, 2020
Response to DCMS call for views and evidence Section 189 Data Protection Act 2018
Response to Department for Digital, Culture, Media and Sport Call for views and evidence – Review of Representative Action Provisions, Section 189 Data Protection Act 2018
22 October 2020
Open Rights Group would like to thank the Department for Digital, Culture, Media and Sport for the opportunity to respond to the consultation on representative action provisions in the Data Protection Act 2018.
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09 September, 2020
Open Rights Group response to LEDS Code of Practice consultation
Response to the Law Enforcement Data Service Code of Practice consultation from the Royal College of Policing
Thinking about the proposed layout, structure and language used for the Code and guidance document, do you feel it is clear and understandable?
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01 September, 2020
Annual Report 2019
Open Rights
Report and Accounts 31 October 2019
About ORG
Open Rights Group (ORG) is a UK based digital campaigning organisation working to protect fundamental rights to privacy and free speech online.
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31 July, 2020
Test and Trace briefing for JCHR
Our take on Government failing to tun Test and Trace in compliance with the law.
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01 June, 2020
Response to the JCHR draft Digital Contact Tracing (Data Protection) Bill
We wrote to the JCHR to support and strenghten legal safeguards for digital contact tracing.
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30 June, 2020
Response to the “Science of Covid” consultation of the Lords’ Science and Technology Committee
We highlighted the role of data protection in ensuring an effective Government response to pandemics.
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15 July, 2020
Response to the call for evidence on the “Impact of Covid-19 on DCMS sectors”
We asked the DCMS Committee to hold the ICO accountable for their failure to enforce the law during the Coronavirus crisis.
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04 August, 2020
Data and Democracy
Democratic Innovations: Polis and the political process
Open Rights Group and Demos yesterday published an exciting new report that provides insight on public attitudes towards data driven campaigning.
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23 June, 2020
Data and Democracy
Who Do They Think We Are?
Political Parties, Political Profiling, and The Law.
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28 May, 2020
Open letter: NHSX App Safeguards For Marginalised Groups
Open letter to the UK government on the NHSX app safeguards for marginalised groups.
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29 April, 2020
ORG Response to the DCMS Call for Evidence on Online Advertising
We made the case for reform of the adtech industry to the DCMS.
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29 April, 2020
ORG Response to the European Commission Review of the GDPR
We suggested changes to the mechanism which governs cross-border complaints to the European Commission, based on our experience with adtech complaints.
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07 April, 2020
COVID-19 and personal data: April briefing
This briefing provides an overview of Open Rights Group’s concerns about the Government’s response to the Covid-19 pandemic.
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02 April, 2020
Joint civil society statement: States use of digital surveillance technologies to fight pandemic must respect human rights
2 April 2020
The COVID-19 pandemic is a global public health emergency that requires a coordinated and large-scale response by governments worldwide.
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26 March, 2020
Joint Letter to PM and SoS for International Trade on US talks and Covid-19 epidemic
Dear Prime Minister and Secretary of State for International Trade,
The United States Trade Representative announced on 23 March 2020 that “both the United States and the United Kingdom are committed to starting trade negotiations as soon as possible”, and the UK government has similarly signaled its desire to begin and conclude negotiations soon.
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25 February, 2020
ICO consultation on Right of Access Guidance
Open Rights Group (ORG) is a UK-based digital campaigning organisation working to protect fundamental rights to privacy and free speech online.
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28 January, 2020
Data Protection Day letter to Members of Parliament
Dear Members of Parliament,
Save Data Protection
Today, Tuesday 28 January 2020 is Data Protection Day.
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14 January, 2020
Letter to ICO re Out Of Control report
Information Commissioner Wycliffe HouseWater Lane, Wilmslow
Dear Elizabeth Denham,
Re: The adtech industry is not respecting consumers’ privacy
We would like to bring to your attention a report published on January 14th by the Norwegian Consumer Council, which looks into the hidden side of the data economy.
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17 December, 2019
Response to 2019 Nominet consultation
INTRODUCTION
Open Rights Group (ORG) is a UK-based digital campaigning organisation working to protect fundamental rights to privacy and free speech online.
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16 December, 2019
General Election 2019 – Digital disruption by the political parties, and the need for new rules
Evidence from the 2019 General Election shows that the need to overhaul the system of electoral administration has gone from urgent to critical.
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15 October, 2019
Response to the Consultation of the House of Lords Democracy and Digital Technologies Committee
Response to the Consultation of the House of Lords’ Democracy and Digital Technologies Committee
14th October 2019
Contents
0.
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04 October, 2019
ORG response to ICO consultation on draft framework code of practice for use of personal data in political campaigning
ICO consultation on the draft framework code of practice for the use of personal data in political campaigning
It is vital in any democratic society that political parties, candidates and campaigners are able to communicate effectively with voters.
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20 September, 2019
Response to DCMS call for evidence on digital identity September 2019
Open Rights Group (ORG) is a UK-based digital campaigning organisation working to protect fundamental rights to privacy and free speech online.
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16 September, 2019
Open Rights Group open letter to UK Gov on data flows in No Deal Brexit
16 September 2019
To: The Prime Minister, Minister in Charge of Exiting the European Union, Duchy of Lancaster (Minister in charge of No Deal planning), Secretary of State for DCMS
Re: UK-EU data flows in the event of a no deal Brexit
We are writing further to the publication of the “Operation Yellowhammer” documents to express our concerns about the Government’s lack of preparedness for continuation of cross-border data flows in the event of a no deal exit from the European Union on 31 October 2019 or any other date.
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31 July, 2019
Response to the Competition & Markets Authority study into the digital advertising market
Open Rights Group (ORG) is a UK-based digital campaigning organisation working to protect fundamental rights to privacy and free speech online.
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29 July, 2019
Annual Report 2018
Contents
Directors’ Report Accountants’ Report
Income and Expenditure Account Balance Sheet
Notes to the Report of the Board of Directors
Financial Statements
Company Information
Directors
Owen BlackerJames Cronin (Chair)Tom De Grunwald (appointed 6 August 2018) John ElliottMaria Farrell (retired 6 August 2018)Ben Laurie (retired 6 August 2018)Harry Metcalfe (retired 6 August 2018)Alec MuffettBrian Parkinson (appointed 6 August 2018) Simon PhippsMilena Popova (retired 6 August 2018)Christi Scarborough (appointed 6 August 2018)
Secretary
James Cronin
Executive Staff
Jim Killock Executive DirectorMartha Dark Chief Operating Officer (appointed 23 March 2018)
Accountants
Urban Ledgers Limited
14 Thornhill Square
London N1 1BQ
Bankers
Cooperative Bank plc
PO Box 1011 Balloon Street Manchester
Registered company number
05581537
Report of the Board of Directors for the year ended 31 October 2018
The Directors of the company present their annual report for the year ending 31 October 2018.
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15 July, 2019
Response to National Data Strategy open call for evidence July 2019
Response to National Data Strategy open call for evidence July 2019
Contents
INTRODUCTION 1 KEY CONCERNS 1 PERSONAL DATA AND PRIVACY 2 PERSONAL DATA AND COMPETITION 3 PROCUREMENT, OPEN SOURCE AND OPEN STANDARDS 3 OPEN DATA 4 THE PUBLIC DOMAIN 5 INTELLECTUAL PROPERTY POLICIES 6
1.
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15 July, 2019
Open letter to DCMS – BBFC Age Verification Privacy Certification Scheme
The Rt Hon Jeremy Wright QC MPSecretary of State for Digital, Culture, Media and Sport100 Parliament StreetLondon SW1A2BQ15
July 2019
Re: BBFC Age Verification Privacy Certification Scheme
Dear Secretary of State,
We write to ask you to legislate without delay to place a statutory requirement on the British Board of Film Classification (BBFC) to make their privacy certification scheme for age verification providers mandatory.
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01 July, 2019
Open Letter to The Rt Hon Jeremy Wright QC MP Secretary of State for Digital, Culture, Media and Sport
1 July 2019
Re: Online Harms White Paper
Dear Secretary of State,
We write as a group of organisations keenly interested in the government’s proposals for Internet regulation.
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24 June, 2019
DNS Security – Getting it Right
Executive Summary
This paper addresses the privacy implications of two new Domain Name System (DNS) encryption protocols: DNS-over-TLS (DoT) and DNS-over-HTTPS (DoH).
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17 June, 2019
ORG Regulation Report II
This report follows our research into current Internet content regulation efforts, which found a lack of accountable, balanced and independent procedures governing content removal, both formally and informally by the state.
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14 June, 2019
Response to the Centre for Data Ethics and Innovation consultation on online targeting
Response to the Centre for Data Ethics and Innovation Call for Evidence Consultation on online targeting
Open Rights Group (ORG) is a UK-based digital campaigning organisation working to protect fundamental rights to privacy and free speech online.
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13 June, 2019
Analysis of BBFC Age Verification Certificate Standard June 2019
About Open Rights Group
Open Rights Group (ORG) is a UK-based digital campaigning organisation working to protect fundamental rights to privacy and free speech online.
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10 June, 2019
Response to the Consultation on the Government’s regulatory proposals regarding consumer Internet of Things (IoT) security
Open Rights Group (ORG) is a UK-based digital campaigning organisation working to protect fundamental rights to privacy and free speech online.
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31 May, 2019
Comments on the ICO draft Age Appropriate Design Code of Practice – May 2019
Open Rights Group (ORG) is a UK-based digital campaigning organisation working to protect fundamental rights to privacy and free speech online.
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30 May, 2019
Joint Letter to ICO on Age Appropriate Design
Elizabeth DenhamInformation Commissioner Information Commissioner’s Office Wycliffe HouseWilmslowCheshire SK9 5AF
30 May 2019
Dear Commissioner Denham,
Re: The Draft Age Appropriate Design Code for Online Services
We write to you as civil society organisations who work to promote human rights, both offline and online.
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30 May, 2019
Collateral Damage in the War Against Online Harms
A summary of this report is also available on Top10 VPN’s website here.
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23 May, 2019
ORG policy responses to Online Harms White Paper
Open Rights Group (ORG) is a UK-based digital campaigning organisation working to protect fundamental rights to privacy and free speech online.
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13 May, 2019
Freedom of Expression and Brexit
Freedom of Expression and Brexit
Issue
The freedom to access and share information and to hold and express personal ideas and opinions has particular resonance in the digital age.
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13 May, 2019
Surveillance and Brexit
Issue
The practice of mass surveillance made headlines in 2013 when Edward Snowden exposed the widespread scale on which the UK security agency GCHQ was covertly intercepting and monitoring citizens’ private communications data.
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13 May, 2019
Privacy and Brexit
Privacy and Brexit
Issue
The right to privacy has become a key part of all our lives.
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13 May, 2019
Beyond Brexit – A briefing on Europe’s Digital Agenda
Beyond Brexit
A Briefing on Europe’s Digital Agenda
The European Parliamentary term of 2019-2024 will be critical for shaping the European digital agenda.
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25 March, 2019
GDPR Today Volume 3
Open Rights Group guest edited volume 3 of GDPR Today.
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