Making GDPR Usable: A Model to Support Usability Evaluations of Privacy
This work addresses the need for usable privacy evaluations to benefit common users and enable business differentiation beyond GDPR compliance, though it is incremental as it builds on existing frameworks.
The paper tackles the problem of evaluating privacy usability by introducing the Usable Privacy Cube (UP Cube) model, which extends the EuroPriSe certification scheme with usability criteria based on GDPR goals, resulting in measurable outcomes like effectiveness, efficiency, and satisfaction.
We introduce a new model for evaluating privacy that builds on the criteria proposed by the EuroPriSe certification scheme by adding usability criteria. Our model is visually represented through a cube, called Usable Privacy Cube (or UP Cube), where each of its three axes of variability captures, respectively: rights of the data subjects, privacy principles, and usable privacy criteria. We slightly reorganize the criteria of EuroPriSe to fit with the UP Cube model, i.e., we show how EuroPriSe can be viewed as a combination of only rights and principles, forming the two axes at the basis of our UP Cube. In this way we also want to bring out two perspectives on privacy: that of the data subjects and, respectively, that of the controllers/processors. We define usable privacy criteria based on usability goals that we have extracted from the whole text of the General Data Protection Regulation. The criteria are designed to produce measurements of the level of usability with which the goals are reached. Precisely, we measure effectiveness, efficiency, and satisfaction, considering both the objective and the perceived usability outcomes, producing measures of accuracy and completeness, of resource utilization (e.g., time, effort, financial), and measures resulting from satisfaction scales. In the long run, the UP Cube is meant to be the model behind a new certification methodology capable of evaluating the usability of privacy, to the benefit of common users. For industries, considering also the usability of privacy would allow for greater business differentiation, beyond GDPR compliance.