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IAPP CIPT: Is Collecting Citizenship Data Justified for Health Tracking App?

Discover which piece of personal information collected by a health tracking app during a pandemic is least likely to be justified according to privacy by design principles. Prepare for the IAPP CIPT certification exam with this expert analysis.

Table of Contents

Question

SCENARIO –
Please use the following to answer the next questions:

Your company is launching a new track and trace health app during the outbreak of a virus pandemic in the US. The developers claim the app is based on privacy by design because personal data collected was considered to ensure only necessary data is captured, users are presented with a privacy notice, and they are asked to give consent before data is shared. Users can update their consent after logging into an account, through a dedicated privacy and consent hub. This is accessible through the ‘Settings’ icon from any app page then clicking ‘My Preferences’, and selecting ‘Information Sharing and Consent’ where the following choices are displayed:

  • “I consent to receive notifications and infection alerts”;
  • “I consent to receive information on additional features or services and new products”;
  • “I consent to sharing only my risk result and location information for exposure and contact tracing purposes”;
  • “I consent to share my data for medical research purposes”; and
  • “I consent to share my data with healthcare providers affiliated to the company”.

For each choice, an ‘ON’ or ‘OFF’ tab is available The default setting is ‘ON’ for all. Users purchase a virus screening service for US$29.99 for themselves or others using the app. The virus screening service works as follows:

Step 1: A photo of the user’s face is taken

Step 2: The user measures their temperature and adds the reading in the app

Step 3: The user is asked to read sentences so that a voice analysis can detect symptoms

Step 4: The user is asked to answer questions on known symptoms

Step 5: The user can input information on family members (name, date of birth, citizenship, home address, phone number, email and relationship).

The results are displayed as one of the following risk status “Low”, “Medium” or “High”. If the user is deemed at “Medium” or “High” risk an alert may be sent to other users, and the user is invited to seek a medical consultation and diagnostic from a healthcare provider.

A user’s risk status also feeds a world map for contact tracing purposes, where users are able to check if they have been or are in close proximity of an infected person. If a user has come in contact with another individual classified as ‘medium’ or ‘high’ risk, an instant notification also alerts the user of this. The app collects location trails of every user to monitor locations visited by an infected individual. Location is collected using the phone’s GPS functionality, whether the app is in use or not however the exact location of the user is “blurred’ for privacy reasons. Users can only see on the map circles with a 12-feet radius (approximately 4 meters wide), which is double the recommended distance for social distancing.

Which of the following pieces of information collected is the LEAST likely to be justified for the purposes of the app?

A. Relationship of family member.
B. Home address.
C. Date of birth.
D. Citizenship.

Answer

D. Citizenship.

Explanation

Of the pieces of information collected about family members by the health tracking app (name, date of birth, citizenship, home address, phone number, email and relationship), citizenship is the least likely to be justified for the app’s purposes.

The app aims to do contact tracing, exposure alerts, and risk assessments during a virus pandemic. While information like name, date of birth, contact info, address and relationship to the user could all be relevant to identifying and alerting people who may have been exposed, there is no clear reason why citizenship status would be needed for these functions.

Collecting citizenship information raises privacy concerns as it is a sensitive piece of personal data that could enable discrimination, and it does not appear necessary or proportional to the app’s stated purposes of managing the public health response to the pandemic. The other pieces of information have a clearer link to contacting and identifying individuals for exposure notifications and health reasons.

Under data minimization principles, which are key to privacy by design, only the minimum personal information needed to achieve the specific purposes should be collected. Since citizenship does not seem essential to the core contact tracing and risk assessment functions described, collecting it is unlikely to be justified and may violate privacy by design. The app developers should scrutinize if citizenship data is truly needed and remove that collection if not.

Therefore, of the options provided, citizenship is the piece of information that collecting is least likely to be justifiable for this health app scenario, based on the details given. The app should aim to limit data collection to only what is proportional and necessary for its pandemic management purposes.

IAPP CIPT certification exam assessment practice question and answer (Q&A) dump including multiple choice questions (MCQ) and objective type questions, with detail explanation and reference available free, helpful to pass the IAPP CIPT exam and earn IAPP CIPT certification.