Perhaps, however, this study will prompt greater attention to a fundamentally important question for health care reform broadly: how you implement an even simple change in systems that reduces errors and mortality – like a checklist. For there is one thing we know for sure: if you don’t use it, it doesn’t work.
Relating this back to my experiences in deploying and using checklists for privacy is that THEY ARE NOT A TOOL FOR IMPROVING PRIVACY DIRECTLY but a TOOL for organising your workflows, your actions and ensuring that all members of a team are actively cross-checking each other; and even then this is just a small part of the overall effect. Let us for a moment rewrite Gwande's statement a little:
Perhaps, however, this study will prompt greater attention to a fundamentally important question for privacy engineering: how you implement an even simple change in systems that reduces errors and non compliance– like a checklist. For there is one thing we know for sure: if you don’t use it, it doesn’t work.
In the paper [1] (emphasis mine)
The checklist approach to privacy protection has been debated.[24] Checklists have become important safety elements in airplane and medical procedures and are quite common in security auditing. However, their utility for privacy remains questionable. It might be possible to design privacy checklists for frequent and standardized use cases, but the breadth of potential projects makes a standard checklist for everything an unlikely tool.
[24] Ian Oliver, “Safety Systems – Defining Moments” Available at http://ijosblog.blogspot.com/2013/07/systems-safety-defining-moments.html
Indeed the two paragraphs on checklists and privacy impact assessments fails to properly understand the former and compares it against the latter which is a different kind of tool altogether. In fact, a PIA should be done and this would be ensured or reminded by having it included as a point on a checklist for privacy.
Indeed no mention was made, nor has been made of any "standardised checklist". In fact there is a capitalised statement on the bottom of the checklist:
THIS CHECKLIST IS NOT INTENDED TO BE COMPREHENSIVE. ADDITIONS AND MODIFICATIONS TO FIT LOCAL PRACTICE ARE ENCOURAGED.Which can be read about in this article published back in February.
The point here in both cases: surgical and privacy engineering is that the checklist needs to be accompanied by a procedural and "societal" change for it be successful. One only needs to read about Pronovost's work with a simple checklist and the changes surrounding that to understand how checklists work in practice - that and the other experiences presented in Gawande's excellent book on the subject: The Checklist Manifesto. Our experiences can be read about in the presentation Flying Planes, Surgery and Privacy.
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References:
[1] Cavoukian, Cronk, Shapiro (2014) Privacy Engineering: Proactively Embedding Privacy, by Design
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