[LINK] Absence of evidence to support contact-tracing apps

[Roger Clarke]

[ Ada Lovelace (these days an Australian) strikes again ]


‘Absence of evidence’ for Covid-19 contact-tracing apps, review finds
https://www.digitalhealth.net/2020/04/absence-of-evidence-for-covid-19-contact-tracing-apps-review-finds/

*An “absence of evidence” to support the immediate deployment of a 
Covid-19 contact-tracing app risks “undermining public trust”, a 
research institute has warned.*

Andrea Downey 22 April, 2020

The independent Ada Lovelace Institute has published a rapid review of 
the technical, social and public health evidence for contact-tracing 
apps, finding the current “technical limitations” and “social impacts” 
outweigh the potential benefits of an app.

To avoid the loss of public trust, the institute called for the 
introduction of legislation to regulate the development of apps and data 
processing, including strict purpose access to data and time limitations 
on its use.

Deployment of technologies should be subject to sign-off from a new 
Group of Advisors on Technology in Emergencies (GATE), established to 
oversee the development and testing of any digital tracing application, 
the review said.

The review found: “The rapid review finds that NHS plans to use 
technology to help reduce the spread of Covid-19 will not be effective 
unless the Government takes action to address the technical limitations, 
barriers to effective deployment and social impacts of the technology.

“Premature deployment of ineffective apps could undermine public trust 
and confidence in the long-term, hampering the widespread uptake of 
tracking technologies which may be critical to their eventual success.”

Given the lack of evidence, the review warned making use of the 
technology mandatory would “likely fall foul of the human rights standards”.

NHSX is set to trial a Covid-19 contact-tracing app 
<https://www.digitalhealth.net/2020/03/nhsx-coronavirus-contact-tracking-app/> 
in the North of England, but has remained tight-lipped about how the app 
will work and when they expect the pilot to be rolled-out across the 
country.

Privacy group medConfidential has called on the organisation to be 
“upfront” about their plans for the app 
<https://www.digitalhealth.net/2020/04/nhsx-must-be-upfront-about-contact-tracing-app-privacy-group-says/> 
and how it will be used. A call that was echoed in the independent review.

“Government must be transparent about the technical solutions under 
development. Technological solutions must complement, rather than 
replace, ongoing public health surveillance and pandemic response 
initiatives,” it found.

“They must be grounded in a comprehensive strategy for the UK’s 
transition out of the crisis, for which Government should develop, 
publish and invite public scrutiny.”

Carly Kind, director of the Ada Lovelace Institute, said: “Bad uses of 
data and technology can do more harm than good. They can obscure 
accurate analyses, hide abuses of power and exacerbate the position of 
people already suffering from digital exclusion, who – evidence is 
beginning to show – are the same people who are most vulnerable to Covid-19.

“Premature deployment of a digital contact tracing app, which will 
ultimately rely on widespread public uptake to be effective, risks 
tarnishing public trust and confidence in technologies that could assist 
a transition out of the crisis.

“While we have seen that the public will support emergency or extreme 
measures that require curtailment of liberty or agency, or the increase 
of surveillance, if they appeal to a common sense of solidarity and are 
clearly justified for public good, there needs to be cast-iron ‘sunset’ 
clauses to dismantle any data tracking and surveillance architecture, as 
definitively and transparently as lifting restrictions on physical 
movement.”


           Digital immunity certificates

The review also examined the evidence for digital immunity certificates, 
again finding a lack of evidence to support their introduction.

It found while there is “broad agreement” that widespread testing is the 
only route through which the UK can exit the crisis, “there is currently 
insufficient understanding of immunity, no robust scientific means of 
testing for immunity and therefore no credible basis for establishing a 
comprehensive regime of immunity certification at this time”.

The institute called for a comprehensive government strategy around 
immunity that takes into account the social implications of any 
certification, including when, why and under what conditions individuals 
are required to be tested for and disclose their immunity status.

“It may lead to arbitrary and unfair restrictions on individuals’ access 
to transport, services, employment, movement and other rights and 
freedoms on the basis of their immunity status,” the report found.

“Discrimination and stigmatisation may become commonplace if immunity 
becomes an element of identity as we transition from the crisis. The 
public will need to trust and support any government strategy that 
centres on immunity certification.”

Public authorities and private companies should be prevented from 
requesting or requiring disclosure of immunity status outside of defined 
circumstances, it added.

NHSX has been contacted for comment.

https://www.digitalhealth.net/2020/04/imperial-white-paper-outlines-key-data-questions-for-contact-tracing-tech/


     Imperial white paper outlines key data questions for contact-tracing
     tech

*The NHS “cannot afford” to not use a contact-tracing app but special 
measures need to be taken to limit the risk a user could be identified, 
according to a new paper.*

Andrea Downey 23 April, 2020

Imperial College London has published a white paper outlining the eight 
questions governments, public health authorities and developers should 
consider when developing contact-tracing apps.

Such apps could prove useful in avoiding long-term confinement measures, 
the college said, but as they collect sensitive information like 
location data, Bluetooth-enabled proximity information, and whether 
individuals are infected, caution needs to be exercised to protect privacy.

Dr Yves-Alexandre de Montjoye, of Imperial’s department of computing and 
author of the paper, said: “We need to do everything we can to help slow 
the outbreak. Contact tracing requires handling very sensitive data at 
scale, and solid and proven techniques exist to help us do it while 
protecting our fundamental right to privacy. We cannot afford to not use 
them.

“Our questions are intended for governments and citizens to help 
evaluate the privacy of apps. They could also for app developers when 
planning and evaluating their work.”

Dr de Montjoye answered the questions below:


             1. How do you limit personal data gathered by the app
             developers?

“Large-scale collection of personal data can quickly lead to mass 
surveillance. We should ask how much data the app gathers – like the 
whole disease trajectory and real-life social network of infected users.”


             2. How do you protect the anonymity of every user?

“Special measures should be put in place to limit the risk that users 
can be re-identified by app developers, other users, or external 
parties. Because location traces are unique, they might easily be linked 
back to a person.”


             3. Does the app reveal to its developers the identity of
             users who are at risk?

“The goal of contact tracing is to warn people who are at risk, so 
there’s no need for app developers to know who these people are.”


             4. Could the app be used by users to learn who is infected
             or at risk, even in their social circle?

“Personal health data is very sensitive. Digital contact tracing should 
warn those who are at risk without revealing who might have infected them.”


             5. Does the app allow users to learn any personal
             information about other users?

“Having access to small amounts of information could help users identify 
who is infected, so apps shouldn’t disclose information on a user’s 
location or social networks to other users.”


             6. Could external parties exploit the app to track users or
             find out who’s infected?

“Apps should consider the risk of external adversaries, including 
well-resourced ones. External entities could install Bluetooth trackers 
to cover a city, or install malicious code on phones, and record the 
identifiers that they observe in specific locations. This can be avoided 
by regularly changing and re-anonymising identifiers like location data.”


             7. Do you put in place additional measures to protect the
             personal data of infected and at-risk users?

“The app design may require revealing more personal information about 
users who are infected or exposed, but these are often the people who 
are more vulnerable and at risk. It’s important to consider what 
additional measures can be taken to protect their information.”


             8. How can users verify that the system does what it says?

“Large-scale contact tracing is too sensitive an issue to rely on blind 
trust. Technical measures should be used to guarantee public scrutiny on 
the functioning of the app. Transparency of the system (app code, 
protocol, what is being broadcast, etc) is fundamental to guarantee privacy.

“This requires that the app be open source and app versions distributed 
on mobile app stores be verifiable, enabling developers to confirm that 
they’re running the public, auditable code.”


           Privacy and effectiveness

It comes at a time when the technology is attracting questions over 
privacy and effectiveness.

An open letter from hundreds of academics from 26 countries urged 
governments and public health authorities to evaluate the potential 
dangers of developing contact-tracing apps, which could 
“catastrophically hamper trust” 
<https://www.digitalhealth.net/2020/04/contact-tracing-apps-could-catastrophically-hamper-trust-academics-warn/> 
if they become a tool for “large scale data collection on the population”.

A similar tone was struck in an Ada Lovelace Institute rapid review of 
the technical, social and public health evidence for contact-tracing 
apps, which found “absence of evidence” for their deployment. 
<https://www.digitalhealth.net/2020/04/absence-of-evidence-for-covid-19-contact-tracing-apps-review-finds/>

Privacy group medConfidential has also called on NHSX to be “upfront” 
<https://www.digitalhealth.net/2020/04/nhsx-must-be-upfront-about-contact-tracing-app-privacy-group-says/> 
about their plans for a contact-tracing app. 
<https://www.digitalhealth.net/2020/03/nhsx-coronavirus-contact-tracking-app/>

The app, understood to be using Bluetooth to trace users, allowing 
people to input their own symptoms, alerting anyone they have come into 
contact with that they may have been exposed to the virus. NHSX has not 
provided further information.

Recent research from Oxford University, which is advising NHSX on its 
development of an app, found an app could help stop the pandemic but 
only if 60% of the population used it.

The team simulated coronavirus in a model city of one million people and 
found a “digital contact tracing app, if carefully implemented alongside 
other measures, has the potential to substantially reduce the number of 
new coronavirus cases, hospitalisations and ICU admissions”.

The same team has previously suggested current contact-tracing methods 
are too slow to keep up with Covid-19.

But Ross Anderson, a professor at Cambridge University, has suggested 
the use of such apps could be unreliable as they require large numbers 
of the population to use them and to input their symptoms correctly.

“Anyone who’s worked on abuse will instantly realise that a voluntary 
app operated by anonymous actors is wide open to trolling,” he wrote.

https://www.digitalhealth.net/2020/04/contact-tracing-apps-could-catastrophically-hamper-trust-academics-warn/


     Contact-tracing apps could ‘catastrophically’ hamper trust,
     academics warn

*Contact-tracing apps could “catastrophically hamper trust” if they 
become a tool for “large scale data collection on the population”, 
hundreds of academics have warned.*

Andrea Downey – 23 April, 2020

An open letter, published on 19 April and signed by professors from 26 
countries, urges governments and public health authorities to evaluate 
the potential dangers of developing contact-tracing technology before 
releasing an app to market.

They warned of risks to accuracy and privacy in using GPS-based apps, 
instead recommending the use of Bluetooth to trace users. But, they 
added, that could also come with risks.

“Some of the Bluetooth-based proposals respect the individual’s right to 
privacy, whilst others would enable (via mission creep) a form of 
government or private sector surveillance that would catastrophically 
hamper trust in and acceptance of such an application by society at 
large,” they wrote.

“It is crucial that citizens trust the applications in order to produce 
sufficient uptake to make a difference in tackling the crisis. It is 
vital that, in coming out of the current crisis, we do not create a tool 
that enables large scale data collection on the population, either now 
or at a later time.”

Several contact-tracing apps are under development, including from NHSX, 
which would be designed to help trace the virus by collecting data on 
those who report symptoms.

The NHSX app 
<https://www.digitalhealth.net/2020/03/nhsx-coronavirus-contact-tracking-app/> 
is set to be trialled in the North of England. It would allow people to 
input their own symptoms, alerting anyone they have come into contact 
with that they may have been exposed to the virus. NHSX has not provided 
further detail on the pilot.

Digital Health News understands the app is based on Bluetooth 
technology, but NHSX has not officially confirmed.

The letter points to Apple and Google’s newly announced partnership 
<https://www.digitalhealth.net/2020/04/apple-and-google-join-forces-in-fight-against-covid-19/> 
to develop Bluetooth-based contact tracing technology, saying the 
academics “fully support” the initiative as it “simplifies – and thus 
speeds up – the ability to develop such apps”.

But warns solutions that involve “reconstructing invasive information” 
should be “rejected without further discussion” to prevent the risk of 
data being exploited.

It comes the Ada Lovelace Institute published a rapid review of the 
technical, social and public health evidence for contact-tracing apps, 
finding an “absence of evidence” for their deployment. 
<https://www.digitalhealth.net/2020/04/absence-of-evidence-for-covid-19-contact-tracing-apps-review-finds/>

The review found current “technical limitations” and “social impacts” of 
an app outweigh the potential benefits and called on the government to 
be transparent about the solutions under development.

Privacy group medConfidential has also called on NHSX to be “upfront” 
about their plans for the app 
<https://www.digitalhealth.net/2020/04/nhsx-must-be-upfront-about-contact-tracing-app-privacy-group-says/> 
and how it will be used.

An NHSX spokesperson said: “Users’ privacy is crucial, which is why we 
are working with other countries, a range of experts, stakeholders and 
industry to ensure the app under development is led by the best 
scientific and clinical advice to reduce transmission of the virus 
whilst protecting user privacy.”

*Key recommendations outlined in the letter:*

   * Contact tracing apps must only be used to support public health
     measures for the containment of Covid-19
   * Any considered solution must be fully transparent. The protocols and
     their implementations, including any sub-components provided by
     companies, must be available for public analysis
   * When multiple possible options to implement a certain component or
     functionality of the app exist, then the most privacy-preserving
     option must be chosen
   * The use of contact tracing apps and the systems that support them
     must be voluntary, used with the explicit consent of the user and
     the systems must be designed to be able to be switched off, and all
     data deleted, when the current crisis is over

-- 
Roger Clarke                            mailto:Roger.Clarke at xamax.com.au
T: +61 2 6288 6916   http://www.xamax.com.au  http://www.rogerclarke.com

Xamax Consultancy Pty Ltd      78 Sidaway St, Chapman ACT 2611 AUSTRALIA 

Visiting Professor in the Faculty of Law            University of N.S.W.
Visiting Professor in Computer Science    Australian National University