One of the fundamental issues in the development of an ICT technology is that it must avoid reaching exclusionary results for a part of the population. This is especially true when we are talking about vulnerable populations, such as people with disabilities, people with low purchasing power or people with difficulties interacting with electronic devices (see the materials produced on vulnerable populations by the PANELFIT project, available in: panelfit.eu). In the case of devices designed for traceability or location purposes, this implies, among other things:
- Developing products that can be used through different types of devices, smartphones, tokens, etc., so that those who do not have one of the devices can acquire another.
- Introducing adapted operating options for people with disabilities, so that these do not prevent them from using the designed tools.
- Simplify as much as possible the functioning of their basic operations, so that any person can use them without making an excessive effort in relation to their capabilities.
- Privacy policies must be redacted in a user-friendly style, so that everyone can understand them.
- If the device is specifically targeted at vulnerable people (for instance, a location device to prevent sight impaired people from getting lost) or under aged users, privacy policies must be adapted to that specific target group. This can mean being accessible through voice rather than only in text, images rather than long texts, or that the language is adapted, for instance, to an average teenager’s understanding.
The case of children is particularly important. According to Recital 38 of the GDPR, “children merit specific protection with regard to their personal data, as they may be less aware of the risks, consequences and safeguards concerned and their rights in relation to the processing”. The ICO has developed some extremely useful recommendations for this purpose[1].
| Checklist: Protecting the vulnerable
The controllers have additional checks in place for their profiling/automated decision-making systems to protect any vulnerable groups (including children). Information and privacy policies should be accessible through different means (from voice, images, video or in an easy-to-understand language). This is especially important if the location device is targeted at a specific users group. Consent is adapted to vulnerable populations and childrens’ needs. Use options facilitating the use of the device by vulnerable populations have been considered. If the controller is willing to use the data for a purpose other than that initially requested, the tool is designed to ask vulnerable users for permission in a way that is compatible with their personal conditions. |
References
1https://ico.org.uk/for-organisations/guide-to-data-protection/key-data-protection-themes/age-appropriate-design-a-code-of-practice-for-online-services/10-geolocation/. ↑