The board and members of the Royal Institute of Engineers (KIVI) analyse current political developments during the corona crisis. We provide facts and interpretation from the technological knowledge and experience of engineers.
The Kamerbrief regarding the national introduction of the CoronaMelder App of 17 August 2020 prompts the questions and comments below.
In an annex to the parliamentary letter, the Minister of Health, Welfare and Sport responds to our questions and comments of 9 August. Many of our questions were answered in it. However, three of them remain in whole or in part. (The numbering refers to our message of 9 August 2020).
Question 1. Too many false notifications.
Unjustified notifications(false positives) or, on the contrary, their absence(false negatives) undermine the effectiveness of the CoronaMelder App and/or user confidence. We fully understand that it is technically difficult to improve this accuracy, but 27% false positives and as many false negatives is very high.
However, after studying the GGD requirements to which the VWS response refers, it does not seem objectionable to us to slightly increase the number of false positives compared to the 1.5m standard if the number of false negatives can thereby be reduced. We recommend investigating how the sensitivity (sensitivity) of the Bluetooth signalling can be set optimally.
Clarification:
According to the VWS response, 90% of contact notifications were within 3 metres and 100% within 10 metres. So completely wrong is not such a notification outside the 1.5m limit. In this context, contact definition 3 of the GGD LCI-BCO protocol is also relevant alongside the contact definition 2a used. This refers to persons 'who had prolonged contact (longer than 15 minutes) at more than 1.5m distance in the same room, e.g. in the office, in the classroom or during meetings'.
The percentage of false negatives can easily be reduced by increasing sensitivity, writes VWS. However, this further increases the number of false positives compared to contact definition 2a (15 min within 1.5m.). However, these then still fall within contact definition 3 and are therefore also high-risk contacts according to that definition. Therefore, increasing sensitivity is still worth considering.
Determining the desired optimisation is technically possible by simulation on the basis of technical measurements or practical tests such as those conducted at the Ministry of Defence in Vught. In part, the effectiveness analysis announced by VWS can also contribute.
Question 6 . DPIA
Several previously reported points have been resolved in the 17 August parliamentary letter following the opinion of the Personal Data Authority (AP). In the latest parliamentary letter, VWS promised an updated DPIA and an independent second opinion. From our perspective, the following aspects are still important in this regard:
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Role of Google and Apple
The AP's demand to impose requirements on Google and Apple should be viewed with some realism. The GAEN customisation of Android and iOS have been an unprecedentedly positive move by Google and Apple. This adaptation has been rolled out globally and is also available in the Netherlands, among other countries. The Dutch government has no thus strong bargaining power.
In addition, in almost all cases, both companies already have more personal information from users than will become available with the CoronaMelder App. Among other things, almost every user consciously or unconsciously makes location data and other personal data available for use by Google and other companies.
Our advice is to work with the European Commission and EU Member States to reach the best possible agreements with Google and Apple. The specialist engaged by VWS on our recommendation can support this -
Transparency, users' interests and rights
Our advice is to take the AP's comments to heart in the new DPIA. In doing so, the review by the privacy specialist in our technical team offers some more practical starting points. In particular, the consent management in detail points A10 and B11(2) and the conclusions on transparency in main point 5 and detail point B15.
This can increase citizens' trust in the CoronaMelder App. This is very important for the highest possible acceptance rate and mass use of the App.
Question 7.European interoperability.
It is important that foreign visitors to the Netherlands are notified if they have been in contact with an infectious person and the same applies to Dutch citizens abroad. It is unfortunate that in the answers from VWS no indication was given as to whether and when this European interoperability will actually be introduced. And for which countries this will be possible.
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The Hague, 21 August 2020
Do you have any further questions? If so, please contact us at E: jan.wind@kivi.nl
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