Research
REPORTS
ALL PUBLICATIONS
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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10 October, 2017
Open Rights Group briefing on the Data Protection Bill – HoL Second Reading
Open Rights Group (ORG) is the UK’s only digital campaigning organisation working to protect the rights to privacy and free speech online.
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08 August, 2017
Complete DCMS response on GDPR derogations
The government has sent us a fuller response to their consultation on GDPR derogations.
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06 April, 2017
Annual Report 2016
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 2016
Introduction
This year was dominated by campaigning around the Investigatory Powers Act (IPA), a new and extensive surveillance law that was created in response to three independent inquiries into the Snowden revelations.
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22 May, 2017
Response to Consultation on Regulations of Technical Capability Notices
The Open Rights Group is responding to this consultation despite the fact that we were not consulted directly.
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10 May, 2017
Response to DCMS call for Views on GDPR Derogations
Open Rights Group – Response to DCMS call for views on GDPR derogations
PDF version here
Open Rights Groups welcomes the opportunity to respond to this call for views.
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04 May, 2017
Home Office consultation: Investigatory Powers (Technical Capability) Regulations 2017
The Home Office are consulting on their draft technical capability notices regulation.
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02 May, 2017
Law Commission Consultation on Protection of Official Data 2017
Introduction
The Law Commission is an independent body that reviews UK legislation and identifies where reform is needed.
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07 April, 2017
Open Rights Group response to consultation on the Investigatory Powers Act Codes of Practice
About the Open Rights Group
Open Rights Group is the UK’s only digital campaigning organisation, working to protect the rights to privacy and free speech online.
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14 March, 2017
Digital Economy Bill Briefing to House of Lords Report Stage
This briefing is also available in PDF format.
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27 January, 2017
Digital Economy Bill Briefing to House of Lords Committee Stage
Open Rights Group (ORG) is the UK’s only digital campaigning organisation working to protect the rights to privacy and free speech online.
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09 December, 2016
Digital Economy Bill Briefing to House of Lords
This briefing is also available in PDF format.
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06 December, 2016
Submission to the IPO call for views: Modernising the European copyright framework
This is ORG’s submission to the Intellectual Property Office’s call for views on the European Commission’s draft legislation to “modernise the European copyright framework”.
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29 November, 2016
Digital Economy Bill Briefing to House of Commons at Report stage
This briefing is also available in PDF format.
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11 October, 2016
Written evidence to House of Commons Public Bill Committee on the Digital Economy Bill
Who are we?
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16 September, 2016
Submission to Electoral Commission 15 Year Review
https://ukelectoralcommission.
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12 September, 2016
Digital Economy Bill: Briefing to the House of Commons on Second Reading
This briefing is also available in PDF format.
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18 June, 2016
ORG Response to BEREC consultation on European net neutrality guidelines
ORG responded to the consultation on Draft BEREC Guidelines on implementation by National Regulators of European net neutrality rules.
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14 June, 2016
ORG Response to EU Consultation on Freedom of Panorama and Publishers’ Neighbouring Right
ORG responded to the consultation using the online facilities provided by Copyright 4 Creativity.
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27 April, 2016
ORGs response to EU consultation on the reform of IPRED
Our response is here.
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27 April, 2016
ORG’s response to data sharing consultation
You can donload the PDF VERSION HERE
Consultation Response Data Sharing Open Rights Group
Introduction
Open Rights Group is the UK’s leading digital campaigning organisation, working to protect the rights to privacy and free speech online.
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04 April, 2016
Cashing in on your mobile
In this report, we examine whether mobile phone users are being given enough information to make informed choices about how their data is used.
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15 March, 2016
Investigatory Powers Bill briefing
(1) What is the Investigatory Powers Bill?
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02 December, 2015
Submission to Science and Technology Committee on Investigatory Powers Bill
The Science and Technology Committee exists to ensure that Government policy and decision-making are based on good scientific and engineering advice and evidence.
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14 November, 2015
Annual Report 2015
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 LondonN1 1BQ
Bankers
Cooperative Bank plc PO Box 1011 Balloon Street Manchester
Introduction
This year we campaigned against mass surveillance, and worked on data protection and e-privacy.
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03 November, 2015
Collect it all: GCHQ and mass surveillance
We have revised and republished our report to take account of information from the ISC, Anderson and RUSI review.
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24 July, 2015
Response to IPO consultation on raising jail sentences for online infringement
ORG Response to IPO consultation on online infringement
The Intellectual Property Office is consulting on proposals to increase prison penalties for criminal online copyright infringement to 10 years to bring them to the same levels as those for similar physical copyright infringement.
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03 June, 2015
International Open Data Conference, Ottawa, May 2015: Privacy Session
Sharing Session: Opening data, protecting privacy
International Open Data Conference, Ottawa, May 2015
These notes form a short report of the session based on our preparation notes and the materials collected during the event.
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11 March, 2015
GCHQ and Mass Surveillance
The Intelligence and Security Committee has published the findings of its Privacy and Security Inquiry.
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30 January, 2015
TTIP and digital rights
A PDF of the full collection of articles including this one is available here.
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30 January, 2015
Submission filed by ORG and Privacy International in DRIPA case
We are grateful to barristers Jessica Simor QC and Ravi Mehta as well as Dan Carey at Deighton Pierce Glynn solicitors for preparing the submission.
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22 January, 2015
Abuse of Parliamentary procedure: introducing the Comms Data Bill into the Counter Terrorism and Security Bill
The draft Communications Data Bill, which is inserted by the amendment in nearly identitical form, was scrutinised by a joint committee of the Lords and Commons for a year.
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19 January, 2015
ORG responds to consultation on Communications Data Codes of Practice
Regulation of Investigatory Powers Act Consultation: Acquisition and Disclosure of Communications Data and Retention of Communications Data Codes of Practice
I.
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19 December, 2014
Status of data retention in the EU following the CJEU ruling
We did this using information provided by member organisations of EDRi (European Digital Rights).
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10 December, 2014
Open Rights Group and Privacy International’s DRIPA intervention
The Claimants have been granted permission to proceed to a substantive hearing and ORG and PI have been given permission to make a further written intervention.
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28 November, 2014
Briefing on Counter-Terrorism and Security Bill
Briefing on Counter-Terrorism and Security Bill (“the Bill”)
Introduction
Open Rights Group is the UK’s most prominent voice defending freedom of expression and privacy on the Internet, with expertise gained from nine years of working on data retention issues.
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28 November, 2014
ISC report on Woolwich attack gets its maths wrong
ISC maths lesson: 22 + 4 = 1
UPDATE (26 Feb 2015) The government has published its response to the report stressing the focus on accessing data from foreign communications
The ISC deserves credit for an extensive and thorough investigation that sheds some much needed light on the work of the security and intelligence services.
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14 November, 2014
Annual Report 2014
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 Ltd 14 Thornhill Square LondonN1 1BQ
Bankers
Cooperative Bank plc PO Box 1011 Balloon Street Manchester
Principal activities
The principal activities of Open Rights (which trades as the Open Rights Group or ORG) are:-
● To raise awareness of digital rights matters in the media, with policy makers and with the general public.
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16 September, 2014
Response to survey on raising maximum penalty for breaching online copyright to 10 years in prison
The survey by Inngot centred around the following question:
Today, there is a significant difference between the penalties for offline and online copyright infringement.
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