Publications
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
Open Rights Group 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
Open Rights Group submission to the Department of Digital, Culture, Media and Sport — Plan for Digital Regulation
ORG answer to the DCMS consultation on the Government Plan for Digital Regulation
0.
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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
Open Rights Group: 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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06 March, 2019
Exiting the European Union Committee – Role of Parliament submission
Exiting the European Union Committee
Role of Parliament InquirySubmission by Open Rights Group
1.
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19 February, 2019
EU Settled Status Automated Data Checks: Proposed outcomes, concerns and questions
Issue
This briefing addresses the automated data checks within the EU Settlement Scheme (“the scheme”), the application route through which EU nationals must apply for settled status post-Brexit.
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28 January, 2019
Public Understanding of GDPR
Introduction
Research methods
Section 1: How people understand data protection and their rights
Key points
Awareness of data protection rights is low
High awareness but low understanding of consent in GDPR
Data protection rights and everyday life
Section 2: Making data protection relevant to people
Key points
Contextualise and provide examples of data protection rights in action
Provide problem-focussed tools and services
Make time to carry out user-centred research to understand your audience
Section 3: How organisations can communicate well about data protection rights
Key points
Providing electronic means to use data protection rights
Explaining how data protection rights work in context
Communicating how data is used in “clear and plain language”
Asking for consent using granular, not bundled, approaches
Being clear about what data will be used for each purpose
Considering whether ‘privacy policy’ is the best label for privacy-related information
Contributing to machine-readable standards about how organisations use data
Introduction
Debate and guidance about data protection and the General Data Protection Regulation (GDPR) has focussed on helping businesses achieve compliance.
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08 January, 2019
House of Lords Committee on Internet Regulation: oral evidence
The Internet: to regulate or not to regulate?
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19 December, 2018
Code of Practice for the use of personal information in political campaigns: ORG response
Q1 Do you agree with our understanding of ‘political campaigning’ and what processing should be covered by the code?
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11 December, 2018
E-Privacy Regulation – Areas of Concern for the Open Rights Group
E-Privacy Regulation: Areas of Concern for Open Rights Group
These notes outline our main concerns with the current discussions in Brussels around the proposed E-Privacy Regulation, and have been presented ot the DCMS team responsible for the UK side of the negotiations.
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23 November, 2018
Response to consultation on the UK joining the CPTPP
We have general concerns about the process of trade policy, shared with much of civil society.
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23 November, 2018
Response to consultation on a new Free Trade Agreement with Australia
We have general concerns about the process of trade policy, shared with much of civil society.
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23 November, 2018
Response to consultation on a new Free Trade Agreement with New Zealand
We have general concerns about the process of trade policy, shared with much of civil society.
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23 November, 2018
Digital Privacy
Response to consultation on a new Free Trade Agreement with the United States
We have general concerns about the process of trade policy, shared with much of civil society.
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07 November, 2018
Analysis of BBFC’s Post-Consultation Guidance
Printable PDF version
Summary
The new code has some important improvements, notably the introduction of a voluntary scheme for privacy, close to or based on a GDPR Code of Conduct.
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25 September, 2018
Age-Appropriate Design Code
Summary
Open Rights Group supports higher default privacy settings for children, in particular a restriction on behavioral advertising and data processing that leads to extended user engagement.
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18 September, 2018
Digital Handcuffs
Written by Slavka Bielikova and Javier Ruiz Diaz
Read the full report here.
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13 August, 2018
Annual Report 2017
Contents
Company Information
Directors’ Report
Accountants’ Report
Income and Expenditure Account Balance Sheet
Notes to Financial Statements
Company Information
Directors
James Cronin
Simon Phipps
Alec Muffett
Maria Farrell
Harry Metcalfe
Ben Laurie
Milena Popova
Owen Blacker
John Elliott
Secretary
James Cronin
Accountants
Urban Ledgers Limited
14 Thornhill Square
London N1 1BQ
Bankers
Cooperative Bank plc
PO Box 1011 Balloon Street Manchester
Company number 5581537
Report of the Board of Directors for the year ended 31 October 2017
The Directors of the company present their annual report for the year ending 31 October 2017.
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23 July, 2018
Submission to the IPCO request for comments on bulk warrants
Submission by Open Rights Group to the IPCO request for comments on bulk warrants
Disclaimer: the arguments presented here are based to an extent on partial, leaked and incomplete information.
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10 July, 2018
Debates, awareness, and projects about GDPR and data protection
Debates, awareness, and projects about GDPR and data protection
Interim Report for the Information Commissioner’s Office for the project: “Making new privacy rights protect and enable people’s financial futures”
Javier Ruiz and Ed Johnson-WilliamsOpen Rights GroupJune 2018
This report is also available to download as a PDF.
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25 May, 2018
Written Submission to House of Lords Communications Committee enquiry on Internet regulation
Click here to see video and transcript of oral evidence session
The Internet: to regulate or not to regulate?
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25 May, 2018
Evidence to UK Parliament on proposed EU-UK Security Treaty after Brexit
QUESTIONS
1.
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25 April, 2018
Response to BBFC Age Verification Consultation
On the 23rd April 2018, the British Board of Film Classification (BBFC) closed their consultation on their age verification guidelines for online pornography.
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16 April, 2018
Oral evidence to House of Lords Select Committee on Artificial Intelligence by Javier Ruiz
Javier Ruiz, our Policy Director, gave oral evidence to the House of Lords Select Committee on Artificial Intelligence.
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16 April, 2018
Brief for oral evidence to the House of Lords Select Committee on Artificial Intelligence
Brief for oral evidence to the House of Lords Select Committee on Artificial Intelligence
ORG’s Policy Director, Javier Ruiz, gave evidence to the House of Lords Select Committee on Artificial Intelligence.
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28 February, 2018
Open Rights Group and the3million Joint Briefing for Second Reading of the Data Protection Bill in the House of Commons
Joint Briefing1: Second Reading of the Data Protection Bill in the House of Commons
The briefing is also available in pdf format.
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11 December, 2017
Collective Redress: Government Position – Open Rights Group Response
Government’s position is in bold.
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11 December, 2017
Amendment to Clause 173 : Supporting Consumer Rights for All
Need for implementation of collective redress mechanism
Research from consumer group Which?
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07 December, 2017
Immigration Exemptions: Government Position – Open Rights Group Response
This briefing is a breakdown of the Government’s response in Committee to the debate on Schedule 2 Paragraph 4 which would create an exemption from GDPR provisions to personal data processed for the purposes of “the maintenance of effective immigration control”, or “the investigation or detection of activities that would undermine the maintenance of effective immigration control”.
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07 December, 2017
Joint Briefing: Immigration Exemptions in the Data Protection Bill Need To Be Removed
Open Rights Group and the3million
JOINT BRIEFING: IMMIGRATION EXEMPTIONS IN THE DATA PROTECTION BILL NEED TO BE REMOVED.
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