The pattern allows obligations relating to data sharing, storing and processing to be transferred and managed when the data is shared between multiple parties.
The developer aims to make sure that multiple parties are aware of and comply with required user/organisational policies as personal and sensitive data are successively shared between a series of parties who store or process that data.
Data may be accessed or handled by multiple parties that share data with an organisation in ways that may not be approved by the data subject.
Service providers use an obligation management system. Obligation management handles information lifecycle management based on individual preferences and organisational policies. The obligation management system manipulates data over time, ensuring data minimization, deletion and notifications to data subjects.
Benefits: privacy preferences and policies are communicated and adhered to among organisations sharing data. Liabilities: additional effort to set obligations.
A service provider subcontracts services, but requires that the data to be deleted after a certain time and that the service provider requires to be notified if there is further subcontracting.
Pretschner et al (2009) provide a framework for evaluating whether a supplier is meeting customer data protection obligations in distributed systems. Researchers at IBM propose Enterprise Privacy Authorization Language (EPAL) (2004) to govern data handling practices according to fine-grained access control. Casassa Mont (2004) discusses various important aspects and technical approaches to deal with privacy obligations. Pretschner, A., Schtz, F., Schaefer, C., and Walter, T.: Policy Evolution in Distributed Usage Control. Electron. Notes Theor. Comput. Sci. 244, 2009 IBM, The Enterprise Privacy Authorization Language (EPAL), EPAL specification, http://www.zurich.ibm.com/security/enterprise-privacy/epal/, 2004 Mont, M. C., Dealing with Privacy Obligations, Important Aspects and Technical Approaches, TrustBus, 2004