Towards a legally-compliant Internet of Things

Lead Research Organisation: University of Cambridge
Department Name: Computer Science and Technology

Abstract

This project is to forge new directions towards the important, but largely unexplored challenge of aligning the Internet of Things (IoT) with legal and regulatory realities.

The broad vision of the IoT is where the physical world comes online. It entails sensors and actuators seamlessly integrated with virtual services, as part of a wide-scale, potentially global systems infrastructure that dynamically reacts and responds to meet various goals.

This vision has captured mainstream imagination. The connected infrastructure, a large-scale distributed system, enables a potentially limitless range of applications, which can be customised to individuals, groups and organisations, in areas including cities, retail, energy, health and lifestyle, transport and agriculture.

However, with this vision comes legal, regulatory and social challenges. The scale and physical nature of this emerging systems environment involves sensors generating data on many detailed aspects of the world, much of it (potentially) highly personal or otherwise sensitive, and where actuation capabilities give systems a real, physical-world effect.

As such, IoT (and more generally, ICT) applications, systems and services are increasingly subject to law and visible to regulators, while consumers, businesses and governments are beginning to demand more transparency and agency. Having the means for managing the associated risks, responsibilities, and obligations of the IoT is crucial for realising its potential, and the significant economic and social benefits it promises.

This project directly targets these issues, by taking an interdisciplinary (tech-legal) approach towards legally-compliant distributed systems. The aim is to develop the conceptual frameworks for considering tech-legal compliance issues as well as the technical means for enabling systems (and therefore, those responsible) to comply with legal and regulatory obligations. By facilitating compliance, we work to improve agency, trust and accountability in the IoT, as well as reducing the overheads of compliance.

As the IoT is data driven, the specific focus is on data flow management. We seek to improve the *control* and *visibility* of data as it moves throughout the IoT, in line with data management policy, reflecting legal obligations. This is so that those who have rights over data (including end-users), and those responsible for data (including service providers), are able to ensure their requirements and obligations are met, even as data moves `out of their hands'.

This entails investigating how law and regulation, reflecting responsibilities and obligations, and personal preferences, can be embodied in policy, which technical mechanisms enforce end-to-end, system-wide. This includes auditing policy enforcement, to assist in demonstrating compliance, apportioning liability and indicating whether policy adequately captures legal responsibilities. This also entails the development of legal-technical frameworks that provide the methodology for investigating, enumerating and aligning compliance concerns across the disciplines, and identifying the mismatches between law and technology.

Addressing such challenges requires an interdisciplinary approach. This project embodies a technical/legal symbiosis: work on the technical mechanisms for system-wide control and audit will be driven by legal and regulatory realities, and at the same time, we consider how the technical work impacts the emerging liability and policy concerns arising from the physical and increasingly pervasive and intrusive nature of the IoT.

In undertaking this work, we seek to build the foundations for a broader area of multidisciplinary research concerning legally compliant systems.

Planned Impact

The IoT is seen by many as the next digital revolution, offering enormous promise to transform society and drive considerable economic growth. The UK Government's Blackett review makes clear the importance of the IoT to the nation, and the potential for the UK to become a world leader in the area. However, significant challenges remain in the path of realising this vision.

This project directly aims at such concerns. By taking a multidisciplinary approach to progress towards a legally-compliant IoT, the goal is to improve levels agency, trust and accountability in the IoT, while fostering innovation through better means for risk mitigation and obligation management.

As such, there is much potential for this work to have significant impact, in a range of areas, to various communities, including:

* Academics - This work will build the foundations for establishing the area of interdisciplinary research on legally-compliant systems, through a range of activities and outputs that better align the technical and legal disciplines. This will ensure that legal developments are technologically aware, and vice-versa. Moreover, this will help drive and consolidate progress on other areas of compliance beyond data management, such as general system availability and reliability.

* Public policy/government - As the IoT matures, a number of societal challenges will arise and require response. This work will provide the means for clarifying technical and legal horizons, and provide the methodologies and results for aligning the disciplines, to ensure that legal and socio-political developments are technology-aware, realistic, socially desirable, and enforceable, and that challenges can be anticipated and addressed with sensitivity.

* The IoT market - The IoT marketplace is evolving. Providing vendors with tools for facilitating compliance with legal obligations will significantly benefit commercial activities in the IoT space, by mitigating risk and liability exposure, while reducing the risks and concerns associated with data sharing. Our work will help shape the direction of the industry, where greater levels of trust and assurance will help encourage innovation.

* UK companies - From the IoT (business) user perspective, issues of compliance and data management represent barriers to adoption. Again, providing the means for better managing compliance and obligations will encourage general technology uptake (both by firms and end-users), thereby improving efficiency and fostering innovation.

* Data researchers/scientists - Big data is driving much academic and industrial research. Improved data management regimes, that entail more compliant systems, assist analytics processes by creating further mechanisms for control beyond the traditional focus on consent and application-specific access controls. This helps mitigate risks and encourage innovation.

* General public - Issues of agency, trust and accountability pervade the IoT. This project directly aims at these concerns, as compliance entails the means for managing rights, bringing transparency and control. As a result, this work will lead to more empowered users - crucial to the evolving digital society.

Publications

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Ball-Burack A (2021) Differential Tweetment

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Cloete R (2021) Auditable Augmented/Mixed/Virtual Reality The Practicalities of Mobile System Transparency in Proceedings of the ACM on Interactive, Mobile, Wearable and Ubiquitous Technologies

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Cobbe J (2020) What lies beneath: transparency in online service supply chains in Journal of Cyber Policy

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Cobbe J (2020) Reviewable Automated Decision-Making in Computer Law & Security Review

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Cobbe J (2019) Regulating Recommending: Motivations, Considerations, and Principles in European Journal of Law and Technology

 
Description Provided interdisciplinary (tech-legal) evidence and ways forward for considering and taking a socio-technical, systems-oriented approach to governing emerging technologies.
Exploitation Route Indicating the need for multi-disciplinary approaches to tech governance challenges; providing practical methods and tools for managing obligations; highlighting grounded analysis/evidence-based background for sound policy interventions.
Sectors Digital/Communication/Information Technologies (including Software),Government, Democracy and Justice

URL http://www.compacctsys.net
 
Description We have been frequently influencing various policy discussions (through engaging policy makers, being cited in policy documents and whitepapres, responding to calls for evidence, etc), and generally, drawing greater attention on the need for interdisciplinary approaches on tech-legal issues. We're also having impact in terms of technical outputs and our work is being increasingly recognised given the increasing public awareness of the issues of technology and society.
Sector Digital/Communication/Information Technologies (including Software),Government, Democracy and Justice
Impact Types Societal,Economic,Policy & public services

 
Description Association for International Privacy Professionals - Advisory Board (Privacy Engineering)
Geographic Reach Multiple continents/international 
Policy Influence Type Participation in a guidance/advisory committee
Impact Association for International Privacy Professionals - Advisory Board (Privacy Engineering)
 
Description Cited in EU Consumer Organisation Report
Geographic Reach Europe 
Policy Influence Type Citation in other policy documents
 
Description Cited in EU Parliament assessment
Geographic Reach Europe 
Policy Influence Type Citation in systematic reviews
 
Description Cited in Global Partnership on AI report
Geographic Reach Multiple continents/international 
Policy Influence Type Influenced training of practitioners or researchers
 
Description Cited in NSW Ombudsman Report -
Geographic Reach Australia 
Policy Influence Type Citation in other policy documents
 
Description Cited in UN IGF Coalition on Platform Responsibility report
Geographic Reach Multiple continents/international 
Policy Influence Type Citation in other policy documents
 
Description Cited in WEF report Advancing Digital Safety:
Geographic Reach Multiple continents/international 
Policy Influence Type Citation in other policy documents
 
Description Cobbe on UK Government's External Advisory Group on Smart Cities and Connected Places
Geographic Reach National 
Policy Influence Type Membership of a guideline committee
 
Description DCMS workshop on online disinformation and harms
Geographic Reach National 
Policy Influence Type Participation in a guidance/advisory committee
Impact Was providing guidance to a DCMS white paper
URL https://www.parliament.uk/business/committees/committees-a-z/commons-select/digital-culture-media-an...
 
Description DCMS workshop re funding research into online disinformation and manipulation
Geographic Reach National 
Policy Influence Type Membership of a guideline committee
 
Description EU-US Tech & Trade Council Working Group
Geographic Reach Multiple continents/international 
Policy Influence Type Citation in other policy documents
 
Description Expert evidence for regulating AI/algs
Geographic Reach Europe 
Policy Influence Type Participation in a guidance/advisory committee
 
Description Financial Conduct Authority - Academic Advisory Council
Geographic Reach National 
Policy Influence Type Membership of a guideline committee
 
Description Janssen cited in EU Report on AI and Fundamental Rights
Geographic Reach Europe 
Policy Influence Type Citation in other policy documents
URL https://fra.europa.eu/en/publication/2020/artificial-intelligence-and-fundamental-rights
 
Description Oral and written evidence for House of Lords Committee (Democracy and Digital Technology)
Geographic Reach National 
Policy Influence Type Contribution to a national consultation/review
URL https://committees.parliament.uk/publications/1634/documents/17731/default/
 
Description Paper incorporated into NSW Ombudsman report
Geographic Reach Australia 
Policy Influence Type Citation in other policy documents
Impact Informed guidance documents for the deployment of systems relating to public administration
 
Description Provided input to DCMS Call for Evidence on Secure by Design - regulating the consumer Internet of Things
Geographic Reach National 
Policy Influence Type Contribution to a national consultation/review
Impact Gave a series of recommendations for proposed policy on regulating the consumer IoT
 
Description Ran 2x training seminars for the Information Privacy Comissioner
Geographic Reach Australia 
Policy Influence Type Influenced training of practitioners or researchers
Impact Two training sessions to highlight educate the regulator's staff on current and emerging issues regarding digital rights, accountability and governance related to data and emerging tech (e.g. AI)
 
Description Technology & Law MPhil Course
Geographic Reach Local/Municipal/Regional 
Policy Influence Type Influenced training of practitioners or researchers
Impact Developed a course for MPhil level computer scientists to equip them with the policy and regulatory considerations surrounding the technologies they build.
 
Description Training for Information & Privacy Commissioner NSW
Geographic Reach Australia 
Policy Influence Type Influenced training of practitioners or researchers
Impact Helped skill staff to think about the way data-driven public services are automated and scrutinised
 
Description Two papers cited by EU assessment report re the proposed Digital Services Act
Geographic Reach Europe 
Policy Influence Type Citation in other policy documents
Impact Our papers were cited in a report that seeks to shape and change the directions of the proposed EU Digital Services Act
URL https://ec.europa.eu/newsroom/dae/document.cfm?doc_id=72160
 
Description Two papers cited in HoL Select Committee on Democracy and Digital Technologies Report: Digital Technology and the Resurrection of Trust
Geographic Reach National 
Policy Influence Type Citation in other policy documents
URL https://committees.parliament.uk/publications/1634/documents/17731/default/
 
Description Aviva PhD Studentship
Amount £183,374 (GBP)
Organisation Aviva 
Sector Private
Country United Kingdom
Start 10/2019 
End 09/2022
 
Description INCLUsive Digital Economy Network+: INCLUDE+
Amount £2,650,000 (GBP)
Funding ID EP/W020548/1 
Organisation Engineering and Physical Sciences Research Council (EPSRC) 
Sector Public
Country United Kingdom
Start 09/2022 
End 09/2027
 
Description Internet of Stings: Data flow auditing for compliance in the consumer Internet of Things
Amount £79,083 (GBP)
Organisation Information Commissioner's Office 
Sector Public
Country United Kingdom
Start 10/2021 
End 01/2023
 
Description Realising Accountable Intelligent Systems (RAInS)
Amount £1,108,000 (GBP)
Funding ID EP/R033501/1 
Organisation Engineering and Physical Sciences Research Council (EPSRC) 
Sector Public
Country United Kingdom
Start 01/2019 
End 04/2021
 
Description Trust and Technology Strategic Research Initiative
Amount £150,000 (GBP)
Organisation University of Cambridge 
Sector Academic/University
Country United Kingdom
Start 09/2017 
End 12/2020
 
Description Alan Turing Institute 
Organisation Alan Turing Institute
Country United Kingdom 
Sector Academic/University 
PI Contribution Collaborated with the ATI on two projects - one exploring issues of Data Justice for the Global Partnership on AI; another on issues of Data Sharing for Tackling Modern Slavery for the Modern Slavery and Human Rights Policy Exchange Centre This will now extend to helping develop the Turing's new programme looking at technology and human rights
Collaborator Contribution Contributed to research undertakings and research outputs
Impact Various outputs in terms of literature reviews, reports, stakeholder analyses, papers, research tools, and so on. A multidisciplinary undertaking across various disciplines.
Start Year 2021
 
Title Droiditor: Auditing toolkit for Android Extended Reality 
Description Drioditor is an Android-based open-source software tool that concerns the auditing of augmented, virtual and mixed reality sysetms. Droiditor enables the passive capture of data relevant to audit, which is flexible and customisable, thus supporting investigation for a range of scenarios (situations of failure, development, etc.). 
Type Of Technology Software 
Year Produced 2021 
Open Source License? Yes  
Impact Raised awareness of the need for XR audit, particularly given the growing consciousness around the metaverse 
 
Title Technical infrastructure for data trusts/intermediaries 
Description The software provides flexible open-source software infrastructure designed to support the deployment of various data intermediary (data trusts, collectives, cooperatives, etc). 
Type Of Technology Software 
Year Produced 2022 
Open Source License? Yes  
Impact Helps conceptualise and make concrete the more abstract discussion in the space. 
 
Description Article in Guardian: Behind Cambridge Analytica lay a bigger threat to our democracy: Facebook 
Form Of Engagement Activity A press release, press conference or response to a media enquiry/interview
Part Of Official Scheme? No
Geographic Reach National
Primary Audience Media (as a channel to the public)
Results and Impact Cobbe invited to write op-ed for Guardian: Behind Cambridge Analytica lay a bigger threat to our democracy: Facebook
Year(s) Of Engagement Activity 2020
 
Description Convened a panel on Privacy Enhancing Technologies and AI at the Computers, Privacy and Data Protection Conference in Brussels 
Form Of Engagement Activity Participation in an activity, workshop or similar
Part Of Official Scheme? No
Geographic Reach International
Primary Audience Professional Practitioners
Results and Impact Hosted a panel on Privacy Enhancing Technologies for a policy maker, academic, industry and civil society forum
Year(s) Of Engagement Activity 2020
URL https://www.cpdpconferences.org/cpdp-panels/privacy-enhancing-technologies-and-ai
 
Description Covenened a workshop on business-to-data sharing 
Form Of Engagement Activity Participation in an activity, workshop or similar
Part Of Official Scheme? No
Geographic Reach Regional
Primary Audience Policymakers/politicians
Results and Impact A workshop about the legal framework as regards B2G data sharing between companies and local government for a study she conducted commissioned by the municipality of Amsterdam
Year(s) Of Engagement Activity 2022
 
Description Cyber 9/12: Atlantic Council hosted student cyber-security challenge 
Form Of Engagement Activity Participation in an activity, workshop or similar
Part Of Official Scheme? No
Geographic Reach National
Primary Audience Postgraduate students
Results and Impact Mentor for a student team for a cyber-security challenge, aimed at policy issues around cyber security.
Our team placed first.
Year(s) Of Engagement Activity 2019
URL https://www.cyber912uk.org/en/
 
Description Discussant on the Encrypted Economy podcast 
Form Of Engagement Activity A broadcast e.g. TV/radio/film/podcast (other than news/press)
Part Of Official Scheme? No
Geographic Reach International
Primary Audience Professional Practitioners
Results and Impact Podcast epsiode 61: Building the Human Network Into the Law - J Cobbe and H Janssen both as discussants as part of the broader podcast, having our research reach a broad audience
Year(s) Of Engagement Activity 2022
 
Description Ditchley Foundation 
Form Of Engagement Activity Participation in an activity, workshop or similar
Part Of Official Scheme? No
Geographic Reach International
Primary Audience Policymakers/politicians
Results and Impact Involved various workshops at the Ditchley site to explore various tech-society issues
Year(s) Of Engagement Activity 2019
URL https://www.ditchley.com/
 
Description Forum for Ethical AI - RSA/Deepmind Citizen Jury 
Form Of Engagement Activity Participation in an activity, workshop or similar
Part Of Official Scheme? No
Geographic Reach National
Primary Audience Public/other audiences
Results and Impact Invited as an expert panelist for a citizens jury on ethical AI issues
Year(s) Of Engagement Activity 2018
 
Description Interview by FT on Personal Data Stores 
Form Of Engagement Activity A press release, press conference or response to a media enquiry/interview
Part Of Official Scheme? No
Geographic Reach National
Primary Audience Industry/Business
Results and Impact Dr Heleen Janssen interviewed by the FT about PDS (Jan 2019)
Year(s) Of Engagement Activity 2019
 
Description Interview/quote/commentary for Wired 
Form Of Engagement Activity A press release, press conference or response to a media enquiry/interview
Part Of Official Scheme? No
Geographic Reach International
Primary Audience Public/other audiences
Results and Impact ''Menswear Guy' Marks a Shift in Twitter's Main Characters', Wired, January 2023
Year(s) Of Engagement Activity 2023
URL https://www.wired.co.uk/article/menswear-guy-twitter-main-character-shift
 
Description Janssen wrote op-ed for Dutch newspaper: De Volkskrant 
Form Of Engagement Activity A press release, press conference or response to a media enquiry/interview
Part Of Official Scheme? No
Geographic Reach National
Primary Audience Public/other audiences
Results and Impact Janssen wrote an Op-ed in De Volkskrant, "Personal data stores will not solve issues with big data".
Year(s) Of Engagement Activity 2022
 
Description PRIVACY PROHIBITION 
Form Of Engagement Activity A talk or presentation
Part Of Official Scheme? No
Geographic Reach National
Primary Audience Industry/Business
Results and Impact A roundtable public debate around issues of privacy.
Year(s) Of Engagement Activity 2019
 
Description Participating on Panels at CPDP 
Form Of Engagement Activity A talk or presentation
Part Of Official Scheme? No
Geographic Reach International
Primary Audience Policymakers/politicians
Results and Impact Cobbe presented on CPDP panels both years on issues of Automated and Algorithmic Decision Making (2020/2021); Janssen presented on regulating tech (2020)
Year(s) Of Engagement Activity 2020,2021
 
Description Presentation part of "Tech solutionism in tackling Covid-19" panel, at Digital Identity and the Digital Person (industry event) 
Form Of Engagement Activity A talk or presentation
Part Of Official Scheme? No
Geographic Reach National
Primary Audience Industry/Business
Results and Impact Janssen, speaker at Hub of All Things/Dataswift conference "Digital Identity and the Digital Person", on Tech solutionism in tackling Covid-19, September 2020
Year(s) Of Engagement Activity 2020
 
Description Public Trust in Future Cities (Heleen) 
Form Of Engagement Activity Participation in an activity, workshop or similar
Part Of Official Scheme? No
Geographic Reach National
Primary Audience Professional Practitioners
Results and Impact Discussion on the use of sensing technologies and AI to collect data about people's activities; Heleen (RA) was an invited discussant and covered issues of private actors developing technologies that public bodies account for. Organised by Future Cities and Digital Catapults.
Year(s) Of Engagement Activity 2019
 
Description Quote for New Scientist 
Form Of Engagement Activity A press release, press conference or response to a media enquiry/interview
Part Of Official Scheme? No
Geographic Reach International
Primary Audience Professional Practitioners
Results and Impact Interview/quote in 'Elon Musk buying Twitter has set him up for a scuffle with the EU', New Scientist, April 2022
Year(s) Of Engagement Activity 2022
 
Description Session on Algorithmic Impact Assessement @ European Digital Rights (ERDi)'s Privacy Camp 2020 
Form Of Engagement Activity A talk or presentation
Part Of Official Scheme? No
Geographic Reach International
Primary Audience Third sector organisations
Results and Impact Janssen featured in a panel on algorithmic impact assessments
Year(s) Of Engagement Activity 2021
 
Description Talking Politics - appearance on two podcasts 
Form Of Engagement Activity A broadcast e.g. TV/radio/film/podcast (other than news/press)
Part Of Official Scheme? No
Geographic Reach International
Primary Audience Public/other audiences
Results and Impact Appeared on three episodes of Talking Politics - one on surveillance capitalism, one on machine learning and the IoT, one on tech democracy
Year(s) Of Engagement Activity 2018,2019,2020
URL https://www.talkingpoliticspodcast.com/
 
Description Workshop with Liberty on personal data in online services 
Form Of Engagement Activity Participation in an activity, workshop or similar
Part Of Official Scheme? No
Geographic Reach Local
Primary Audience Third sector organisations
Results and Impact A presentation and discussion at Liberty (NGO) on issues of personal data and online services
Year(s) Of Engagement Activity 2018