Will a PPI culture be born from the right to be forgotten?
Will there be a new generation of businesses born dedicated to finding out if your data has actually been removed from all previous business data stores their client may have been associated with?
If so what affect would this have on the businesses having to comply with the number of subject access requests and requests for someones data to be removed from their databases?
Following digital trail to the offending data store could give the "right to be forgotten" subscribing consumers the ability to press legal charges, but this would likely be triggered by an adverse effect to the consumer, if and when the consumer is made aware of it.
A business that tracks these offenses would have to be authorized and paid by the consumer. Else, it would violate the consumer's right to be forgotten by collecting the very data she doesn't want collected.
I do not beleive that consumers would be willing to pay for the service preemptively and without an existing adverse effect, unless regulations dictate punitive damages to be paid to the consumer regardless of any adverse effect. This would be a contradiction to the "no harm, no foul" concept.
There will be a set of digital services that facilitate your Subject Access Request (SAR) to a collection of organisations.
The supplementary services will
- allow you to exercise your rights, such as right to be forgotten (RTBF)
- objections to specific processing (whether by type of processing or by recipients of your personal information (by location)
- rate the responses from the target orgaisation in terms of transparency (with a transparency index score)
- follow up your initial request with a request for compensation, where the target organisation has not complied
- and so on
These services will be delivered by an app, based on conversations I've had with several developers. There will no doubt be legal firms offering the same services, but given the scale of costs I don't expect these to survive long - the services will be commoditised very quickly.