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Secure and Privacy-Preserving Authentication for Enforcing Data Subject Rights

Core Concepts
A secure and privacy-preserving architecture for authenticating data subjects to enforce their data rights, utilizing eIDs and attribute-based credentials.
The paper proposes an architecture that combines eIDs and attribute-based credentials to provide a standardized, secure, and privacy-preserving way for data controllers to authenticate data subjects when enforcing their data subject rights (DSRs) under the GDPR. The key highlights are: The architecture includes User Devices (data subjects' eIDs), Service Providers (data controllers), Identity Providers, and Identity Issuers. This aligns with the roles defined in the European data strategy. Two approaches are introduced - a self-sovereign identity (SSI) model and a federated identity management (FIM) model. The SSI model gives more control to the data subject, while the FIM model is better suited for scenarios where the data controller lacks the resources to reliably determine the authentication threshold. The architecture enables data controllers to authenticate data subjects without requiring full ID documents or other insecure methods. Instead, data subjects can present selective attribute claims from their eID wallet, minimizing the data disclosed. The involvement of trusted Identity Providers and Issuers helps ensure secure and reliable authentication, mitigating risks of impersonation and unauthorized access to data subject rights. The proposed solution aligns with the European data strategy, as it can be integrated with data intermediaries to facilitate data subject rights enforcement across different data controllers and data spaces.

Deeper Inquiries

How can the architecture be extended to support non-European data subjects who do not have access to the EU Digital Identity Wallet?

To extend the architecture to support non-European data subjects without access to the EU Digital Identity Wallet, several considerations need to be taken into account. One approach could involve creating a service that facilitates the transformation of non-EU electronic identities into a format compatible with the architecture. This service would essentially act as a bridge between the existing non-EU electronic identities and the authentication framework based on eIDs and attribute-based credentials. Additionally, for non-EU residents who do not possess an electronic identity from their country, a mechanism to provide them with an eID would be necessary. This could involve setting up a process within migration offices or other relevant entities to issue eIDs to non-EU individuals who require authentication within the European data ecosystem. By ensuring that non-EU data subjects have access to a compatible electronic identity, they can participate in the authentication process as required by the architecture.

What are the technical and legal challenges in establishing a reliable and standardized authentication threshold for different data sets and use cases?

Establishing a reliable and standardized authentication threshold for different data sets and use cases presents both technical and legal challenges. From a technical perspective, determining the appropriate combination of credentials to authenticate a data subject accurately without compromising privacy is complex. The threshold must be set at a level that ensures unambiguous identification of the data subject while minimizing the risk of false positives or false negatives. Technical challenges include defining the criteria for selecting the relevant attributes for authentication, ensuring the accuracy and reliability of the authentication process, and addressing potential issues such as data normalization and semantics. Additionally, the implementation of privacy-enhancing technologies to protect against re-identification risks and unauthorized access adds another layer of complexity to the technical aspects of establishing the authentication threshold. On the legal front, compliance with data protection regulations such as the GDPR is paramount. Ensuring that the authentication process adheres to the principles of data minimization, purpose limitation, and security while respecting the data subject's rights is crucial. Legal challenges may arise in determining the appropriate level of authentication required for different types of data sets, especially when dealing with sensitive personal data.

How can the architecture be integrated with emerging data sharing frameworks, such as data spaces and data intermediaries, to enable seamless and secure enforcement of data subject rights across the European data ecosystem?

Integrating the architecture with emerging data sharing frameworks like data spaces and data intermediaries can enhance the enforcement of data subject rights across the European data ecosystem. By aligning the architecture with these frameworks, seamless and secure data sharing practices can be established while ensuring compliance with data protection regulations. One way to integrate the architecture with data sharing frameworks is to establish interoperability standards that allow for the secure exchange of authentication data between different entities within the ecosystem. This could involve developing protocols and APIs that enable seamless communication between the authentication framework, data spaces, and data intermediaries. Furthermore, incorporating privacy-enhancing technologies and encryption mechanisms into the architecture can enhance the security of data sharing processes. By implementing robust data protection measures, such as pseudonymization and access control, the architecture can ensure that data subject rights are upheld while facilitating secure data sharing practices. Overall, the integration of the architecture with emerging data sharing frameworks requires a collaborative effort among stakeholders to establish common standards, protocols, and best practices for data authentication and sharing. By leveraging these frameworks, the architecture can contribute to a more efficient and privacy-preserving data ecosystem in Europe.