“IAM PERSONA” – PERSONA’s integrated Impact Assessement Method explained
The objectives of PERSONA project
The PERSONA project sets out to develop and test a tailored down and integrated impact assessment method (called ‘IAM PERSONA’). The method is meant to be used by public authorities – predominantly border control ones – to appropriately assess the consequences, in terms of personal data protection, privacy, ethics and social acceptance, of new no-gate crossing point solutions (for example, e-gates or smart tunnels) to be deployed at state borders. The objective is to provide these authorities with a means to assure, to the highest extent possible, that border control respects democracy, the rule of law and fundamental human rights.
Basics of impact assessment (in a nutshell)
Generally speaking, impact assessment is an evaluation technique used to analyse the possible future consequences of an initiative for relevant societal concerns (i.e. benchmark), if this initiative could present danger to these concerns, with a view to supporting an informed decision-making on whether to deploy the initiative and under what conditions, and it constitutes – in the first place – a means to protect those concerns.
The ‘architecture’ for impact assessment consists at minimum of three main elements:
- a framework, which concerns the policy for impact assessment, and defines and describes the conditions and principles thereof;
- a method,which delineates the consecutive and/or iterative steps to be undertaken to perform the impact assessment process; and
- a model/template, which is a document to fill-in to prepare a report from the assessment process.
The PERSONA integrated impact assessment method will be called IAM PERSONA. The development of the said method, however, cannot be achieved without developing or adjusting other elements of the ‘architecture’ for impact assessment.
The work of the PERSONA project is conducted in a collaborative manner, in five phases, of which – as of May 2020 – the first two have been completed:
- Building on the framework for impact assessment developed earlier by the d.pia.lab, the development of a generic method for impact assessment;
- Definition of the benchmark for impact assessment, tailored down to the reality and needs of border control (cf. Deliverable D1.3);
- Tailoring down of the generic method to the reality and needs of border control (cf. the first draft in Deliverable D3.1) and developing a corresponding template;
- The testing of the tailored down method and the template through three-partite ‘test studies’ (cf. Deliverable D4.1) and stakeholders’ consultation via the PERSONA’s Community of Stakeholders (CoS) (both foreseen for late 2020), and refining the tailored down method and template with the results of these two (cf. Deliverable D3.2); and
- publication of the method and template in an open access handbook (foreseen for early 2021) (cf. Deliverable D5.3).
The generic method for impact assessment consists of the following ten steps (six consecutive steps, three executed throughout the entire process and one step conducted afterwards), grouped in five phases:
|Phase I: Preparation of the assessment process|
|(1) Screening (threshold analysis)|
|(3) Planning and preparation|
|Phase II: Assessment|
|(5) Appraisal of impacts|
|Phase III: Recommendations|
|Phase IV: On-going steps|
|(7) Stakeholder involvement (public participation) in decision making|
|(9) Quality control of the assessment process|
|Phase V: Revisiting|
The impact assessment method tailored down to the reality and needs of of border control not only integrates multiple societal concerns that are relevant in a given context (i.e. ethics, privacy, personal data, and societal acceptability and acceptance), but also combines several appraisal techniques (e.g. risk assessment, and proportionality and necessity assessment), which are either legal requirements or good practices, into one single process.
IAM PERSONA Training
Between May the 18th and 27th 2020, PERSONA successfully conducted the PERSONA End-user Training stretching over 4 separate sessions. The training comprises a comprehensive introduction into the IAM PERSONA, and all material used has been made publically available. More information about the training sessions which were held in the shape of a webinar can be found HERE, and the presentation slides plus reading list can be viewed in our RESOURCES – PRESENTATION/DEMO section.
Further reference documents:
- Dariusz Kloza, Niels van Dijk, Raphaël Gellert, István Böröcz, Alessia Tanas, Eugenio Mantovani and Paul Quinn (2017) Data protection impact assessments in the European Union: complementing the new legal framework towards a more robust protection of individuals. d.pia.lab Policy Brief 1/2017. VUB: Brussels.
- Dariusz Kloza, Niels van Dijk, Simone Casiraghi, Sergi Vazquez Maymir, Sara Roda, Alessia Tanas and Ioulia Konstantinou (2019) Towards a method for data protection impact assessment: Making sense of GDPR requirements. d.pia.lab Policy Brief No. 1/2019. VUB: Brussels.
- PERSONA Deliverable D3.1: PERSONA assessment method (initial version), Brussels.
- PERSONA Deliverable D4.1: Field deployment planning and preparation, Brussels.