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Guiding principles to maintain public trust in the use of mobile operator data for policy purposes

Published online by Cambridge University Press:  01 October 2021

Ronald Jansen*
Affiliation:
United Nations Statistics Division, New York, USA
Karoly Kovacs
Affiliation:
United Nations Statistics Division, New York, USA
Siim Esko
Affiliation:
Positium, Tartu, Estonia
Erki Saluveer
Affiliation:
Positium, Tartu, Estonia
Kaja Sõstra
Affiliation:
Statistics Estonia, Tallinn, Estonia
Linus Bengtsson
Affiliation:
Flowminder, Stockholm, Sweden
Tracey Li
Affiliation:
Flowminder, Stockholm, Sweden
Wole A. Adewole
Affiliation:
Flowminder, Stockholm, Sweden
Jade Nester
Affiliation:
GSMA, London, United Kingdom
Ayumi Arai
Affiliation:
University of Tokyo, Tokyo, Japan
Esperanza Magpantay
Affiliation:
International Telecommunication Union, Geneva, Switzerland
*
*Corresponding author. E-mail: jansen1@un.org

Abstract

The COVID-19 pandemic has accelerated the use of mobile operator data to support public policy, although without a universal governance framework for its application. This article describes five principles to guide and assist statistical agencies, mobile network operators and intermediary service providers, who are actively working on projects using mobile operator data to support governments in monitoring the effectiveness of its COVID-19 related interventions. These are principles of necessity and proportionality, of professional independence, of privacy protection, of commitment to quality, and of international comparability. Compliance with each of these principles can help maintain public trust in the handling of these sensitive data and their results, and therefore keep citizen support for government policies. Three projects (in Estonia, Ghana, and the Gambia) were described and reviewed with respect to the compliance and applicability of the five principles. Most attention was placed on privacy protection, somewhat at the expense of the quality of the compiled indicators. The necessity and proportionality in the choice of mobile operator data can be very well justified given the need for timely, frequent and granular indicators. Explicitly addressing the five principles in the preparation of a project should give confidence to the statistical agency and its partners, that enough care has been exercised in the set up and implementation of the project, and should convey trust to public and government in the use mobile operator data for policy purposes.

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This is an Open Access article, distributed under the terms of the Creative Commons Attribution licence (http://creativecommons.org/licenses/by/4.0), which permits unrestricted re-use, distribution and reproduction, provided the original article is properly cited.
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© The Author(s), 2021. Published by Cambridge University Press
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Author comment: Guiding principles to maintain public trust in the use of mobile operator data for policy purposes — R0/PR1

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Review: Guiding principles to maintain public trust in the use of mobile operator data for policy purposes — R0/PR2

Conflict of interest statement

Tuulia Karjalainen is employed at Telia Company as a senior legal counsel. She is currently on study leave from Telia, conducting doctoral research at University of Helsinki.

Comments

Comments to Author: Thank you for asking me to review this interesting research article. The article takes on an important mission in developing common ethical principles for telecommunications data analysis. This significant and ambitious initiative can help build trust in mobile data analytics and contribute to the harmonization of the field globally. The article also describes three interesting case studies on the use of mobile data during the Covid-19 crisis in Estonia, Ghana, and The Gambia, and assesses these practical experiences using the principle framework. The comparison between three different cases provides value in understanding the challenges of mobile data analytics. Furthermore, using the five ethical principles in assessing these cases makes their comparison consistent and elucidates the role of the principles. I appreciate the effort to apply the principles to real-life cases.

However, I would like to suggest certain revisions, which could add to the validity of this article.

The article’s biggest strengths are also its weaknesses. While the combination of case studies and principle-based analysis is fruitful, the twofold approach also means that the article only scratches the surface of both the principles and the cases, despite its length. Especially the description of values in the beginning of the article could be more profound, explaining in more detail the argumentation behind the choice of these five particular principles.

Furthermore, the five suggested principles (necessity and proportionality, professional independence, privacy protection, commitment to quality, and international comparability) underline some of the most important concerns in using mobile data to fight Covid-19. I also highly appreciate the authors’ commitment to a global framework and acknowledge the difficulties in creating principles that provide value across cultures. However, some of the principles stem almost entirely from a statistical context, making the principles useful only in use cases that involve statistical agencies. While statistical bodies have played a crucial role in multiple projects worldwide, there are also other initiatives. In my view, these principles could benefit a wider audience if generalized from the statistical context.

I have elaborated my comments on each individual principle in more detail below. In addition, I have added some smaller comments that might prove useful too.

2. Monitoring human mobility to contain the spread of COVID-19

- Anonymization and aggregation are presented as means to limit intrusiveness to individuals. I fully agree with the statement but would also like to note that these measures have a significant effect on the accuracy of data through inevitable data loss, which could also be acknowledged here.

- The possibility to use mobile data to identify neighborhoods that are hotspots for the epidemic can be useful for prevention. However, such findings might also create discriminatory concerns if the identified hotspot areas are mainly inhabited by minorities or other vulnerable groups. How do the five principles contribute to these kinds of concerns?

3.1 Principles of necessity and proportionality (fit-for-purpose)

- I find this first principle well identified and crucial in mobile data analytics.

- “Burden for respondents” is mentioned as a criterion for the choice of data sources. I would gladly hear more about whether the burden refers to efforts required from individuals to provide data (answering surveys etc.), or whether it may also refer to indirect consequences, such as loss of privacy.

- At least in the EU, mobile data analytics is often criticized for its intrusiveness. Mobile phone users cannot choose not to provide their data if they want to use their devices and may not be aware that their data is used for statistical purposes. Furthermore, individual movement and location patterns derived from mobile data can be highly identifiable even without direct identifiers. Do you see that necessity and proportionality should also include a principle of least intrusiveness? How should intrusiveness and usefulness be balanced?

- In terms of proportionality, I would also consider the efforts required from mobile operators to provide statistical data. While mobile data collection may be easy for citizens and governments, it usually requires additional technical and operational effort from operators. Even though operators collect certain data to transmit communications and to provide their services, processing this data into useful location and movement statistics is not necessarily effortless or free.

3.2 Principle of professional independence

- The principle of professional independence and the related purpose limitation in particular seem relevant in the context of mobile data analytics. However, the principle heavily relies on the independence of statistical bodies. In the context of mobile data analytics during Covid-19, where data collection and use often involves partnerships between private telecommunications operators and the public sector, I would suggest reframing this principle to also cover other actors in addition to statistical bodies.

3.3 Principles of privacy protection

- The principle of privacy protection is probably among the most important ones in mobile data analytics, and I welcome the authors’ decision to address it in detail. However, the three principles of privacy protection (statistical system, data protection authority, private sector) seem artificial and difficult to understand. Does this refer to differences in the responsibilities of the parties in privacy protection? Does “privacy protection according to data protection authority” indicate that the authorities should always be consulted in these cases, or does it refer to local data protection legislation in general?

- When it comes to legislation, in a global context I would also suggest mentioning the international treaties protecting privacy, such as the Universal Declaration of Human Rights. In the EU, the General Data Protection Regulation (GDPR) is important, but in the context of mobile data analytics the ePrivacy Directive is probably more impactful, and I would mention it in the main body of the article instead of a footnote.

- The short mention of pseudonymization seems of little relevance in its current form. Although the definition is correct, it is difficult to grasp the importance of pseudonymization without further explanation of how it can be used to protect privacy in mobile data analytics.

- This section could be further improved with a more concrete list of privacy questions related to mobile data analytics, including pseudonymization and anonymization, intrusiveness of mobile location data, and special legal restrictions to the use of mobile data in many countries.

3.3.1 Principle of statistical confidentiality and data security

- The section makes a crucial point about need to consider whether the objectives of mobile data analysis could be achieved with aggregate, non-identifiable data. I believe this is one of the most important privacy questions in this field and could be underlined also as a general principle and not just in relation to statistical confidentiality.

3.3.2 Data protection regulations

- The comment about anonymization is confusing to me. I agree that anonymization is an important measure to consider in mobile data analytics. However, this section only mentions the concept in passing but does not elaborate on the function of anonymization in preserving privacy, or its effect on the accuracy of data. Furthermore, the discussion about anonymization could be combined with pseudonymization which was mentioned earlier in the article.

3.3.3 GSMA privacy principles

- This section introduces two important concepts not previously mentioned: compliance with applicable laws and accountability. I believe that both of these principles could be addressed in more detail.

- Footnote 11 about DPIAs refers to the website of a private consulting company. I would suggest using official sources when referring to the DPIA as an EU legal obligation.

3.4 Principle of commitment to quality

- This section identifies important questions about the selectivity and representativeness of mobile data when collected from individual operators. The argument is well explained but could be deepened by including comparability challenges in combining data from several operators. While projects involving multiple operators may sometimes provide better quality data, this is true only if each participant can provide data that is similar enough to the data provided by other participants. Sometimes, legal or business considerations may prevent such harmonization.

- I acknowledge the importance of verifiability and reproducibility as statistical principles. However, in the context of mobile data analytics there may be practical concerns for operators to share information to fulfill these principles, for example legal restrictions (privacy, competition) or business considerations.

4.1 Estonia

- 4.1.1 This sentence is difficult to understand and requires restructuring for clarity: “On 17 March 2020, preparations began to use mobile operator data to provide essential mobility information on questions like: how did mobility of people change during the emergency situation and did those people, who returned from foreign countries, not move around, but remain in one place.”

- 4.1.3 The point about the Estonian Electronic Communications Act only allowing anonymous data processing is significant as this is the case in most EU countries greatly affecting feasibility of mobile data analytics in the member states. However, later in the section the authors mention lack of time as an explanation for not being able to conclude an agreement about more specific data. This seems contradictory with the statement that Estonian law prevents the use of non-anonymized data.

- 4.1.3 This section presents a good argument about the importance of Statistics Estonia acting as an intermediary due to the operators’ unwillingness to share data with each other. I assume this is a very common practical concern that could be raised also in the context of the general principle about professional independence.

- 4.1.6 The summary section contains good reflection on the project and suggestions for improvement in future projects. What I found particularly interesting was the analysis on differences in data between operators due to each of them anonymizing data on their own terms. The suggested solutions of extensive documentation of methodology, testing, and quality analysis seem effective but may not be fully feasible due to legal restrictions.

- Data availability statement: The linked website contains Covid-related statistics from Estonia but does not provide anything on mobile data or the project described (site visited on 18 December 2020).

4.2 Ghana

- 4.2.1 It is interesting to compare the longer-term projects in Ghana and The Gambia to the expedited implementation in Estonia.

- 4.2.1 The text mentions that the project was conducted in a legally compliant and privacy-preserving manner. It would be interesting to have a short description about the main concerns and solutions in this regard. I also noticed that compliance with the GDPR was mentioned instead of local laws. Was there a particular reason for that?

- 4.2.4 The section states that it was not possible to make statistical inferences about the whole population using only the available dataset (it was previously mentioned that the data came from a single operator). This is an important issue to acknowledge. However, sometimes single-operator data can be statistically extrapolated to the whole population. Were there any particular reasons why this was not possible in this case?

- Data availability statement: Mobility analysis reports available in the linked Ghana Statistics website. A high-level overview of the methodology is available at the linked Flowminder website.

4.3 The Gambia

- 4.3.2 The list of consequences caused by the Covid-19 epidemic traceable with mobile data (job reduction, movement to the countryside etc.) is illustrative and well combined.

- 4.3.2 The list of mobility indicators (population distribution, home location, mobility) is interesting but could be clarified by explaining how this information was derived from mobile data.

- 4.3.3 It is stated that the data was produced from the CDRs by PURA (regulatory authority). This sounds to deviate from the other two projects where I understood that the operators provided the data and no raw CDRs were processed by external parties. If this is correct, how was the Gambian setup decided and did the different implementations affect the final analyses?

- 4.3.3 It is mentioned that the implementation setup eliminates privacy issues. Could you elaborate the privacy concerns and their mitigation especially in the context of exporting CDRs from operators to PURA?

- 4.3.4 The names of the two participating operators are not mentioned unlike in the other two projects. If there is a particular reason for this, such as confidentiality agreements, it could be mentioned for clarity.

- 4.3.5 Principle of professional independence: I welcome the publicity of the project and find it an important feature in building trust to this kind of projects. However, the comment does not seem comparable to how the other two projects assessed this principle.

- 4.3.5 Principle of commitment to quality: The interpretation of data and limitations are well described and sound carefully considered.

- Data availability statement: The methodology and code are available on GitHub through the links provided. I have not reviewed the material provided.

5. Conclusions

- Principles of necessity and proportionality: The differences in implementation between the three projects, most importantly the advantage of existing data pipelines in Ghana and The Gambia, provide a productive starting point for comparisons. I would like to hear more about the concrete features and results the longer implementation timeframe allowed in Ghana and The Gambia as compared to Estonia.

- Principle of privacy protection: I find it surprising that the protection of privacy was similar in all three cases. This sounds contradictory with the project descriptions earlier in this article, from which I understood, for example, that Estonian data was anonymized already by the operators, whereas in The Gambia the data was processed by the authorities. Also, I assume considerable regulatory differences may exist between these three countries. I suggest that the argumentation leading to this conclusion of similar privacy is documented in more detail.

- Principle of commitment to quality: The finding that the input data was different between the Estonian and the two African projects is significant, and probably merits emphasizing in context of other principles too. See my previous comment about privacy.

- Principle of international comparability: The difficulties in international comparison due to different contexts and populations is a relevant finding. I believe this observation could offer more value if it was expanded beyond these three projects. Do you find incomparability a general challenge in this kind of project and how does it affect the relevance of this principle altogether? Was there something special in these three projects that made them incomparable?

- The suggestion that full open access to the data for statistical bodies and their partners could help develop relevant indicators is probably true. However, there could be practical concerns for the operators to open their data, such as regulatory considerations or business sensitivity. Furthermore, broader access to the data could also have a detrimental effect on privacy.

- I fully agree with the comment that balancing between privacy and data quality is important. However, it could also be acknowledged that this is not necessarily just an operational or technical challenge but also heavily affected by the legal restrictions applicable in different jurisdictions.

General stylistic comments

- There are some discrepancies in chapter numbering with some subtitles being numbered while others are not. Please revise for consistency.

- The article refers to some actors without providing an introduction (Flowminder on page 6, Positium on page 13). The text would be easier to follow if the roles of the parties were clearly stated.

Review: Guiding principles to maintain public trust in the use of mobile operator data for policy purposes — R0/PR3

Conflict of interest statement

No.

Comments

Comments to Author: Thank you for the paper. The message is clear, however I would like to suggest some minor revisions for improving it.

- maybe putting schemes for each principles would improve it, it would be great.

- the phrase "Population Census data, for example, should only be used for statistical purposes and for no other purposes."

is not so clear

- when you talk about "GSMA" it is important to put other details

or references for GSMA privacy guidelines to make them more clear or instructive (page 11)

- when you talk about project in each country, are there any plots, or figures, which could help to illustrate your point? this is important to make better communication for the general public.

Recommendation: Guiding principles to maintain public trust in the use of mobile operator data for policy purposes — R0/PR4

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Decision: Guiding principles to maintain public trust in the use of mobile operator data for policy purposes — R0/PR5

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Author comment: Guiding principles to maintain public trust in the use of mobile operator data for policy purposes — R1/PR6

Comments

Dear colleagues,

The manuscript "Guiding principles to maintain public trust in the use of mobile operator data for policy purposes" was submitted in November 2020. Comments from two reviewers were received on 24 April 2021. The revised manuscript is now submitted on 13 July 2021.

We like to thank the reviewers for the detailed comments. This helped greatly in improving the manuscript.

We would like to mention that two of the three country cases referenced and described in the paper have also been separately reported in the first cluster of papers of the "Telco Big Data Analytics for Covid-19 collection".

We thank Data & Policy and the Cambridge University Press for the opportunity to publish our paper.

Best regards,

Ronald Jansen

Corresponding author

Recommendation: Guiding principles to maintain public trust in the use of mobile operator data for policy purposes — R1/PR7

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Decision: Guiding principles to maintain public trust in the use of mobile operator data for policy purposes — R1/PR8

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