AI-enabled Automation for Completeness Checking of Privacy Policies

Orlando Amaral, Sallam Abualhaija, Damiano Torre, Mehrdad Sabetzadeh, Lionel C. Briand

Technological advances in information sharing have raised concerns about data protection. Privacy policies contain privacy-related requirements about how the personal data of individuals will be handled by an organization or a software system (e.g., a web service or an app). In Europe, privacy policies are subject to compliance with the General Data Protection Regulation (GDPR). A prerequisite for GDPR compliance checking is to verify whether the content of a privacy policy is complete according to the provisions of GDPR. Incomplete privacy policies might result in large fines on violating organization as well as incomplete privacy-related software specifications. Manual completeness checking is both time-consuming and error-prone. In this paper, we propose AI-based automation for the completeness checking of privacy policies. Through systematic qualitative methods, we first build two artifacts to characterize the privacy-related provisions of GDPR, namely a conceptual model and a set of completeness criteria. Then, we develop an automated solution on top of these artifacts by leveraging a combination of natural language processing and supervised machine learning. Specifically, we identify the GDPR-relevant information content in privacy policies and subsequently check them against the completeness criteria. To evaluate our approach, we collected 234 real privacy policies from the fund industry. Over a set of 48 unseen privacy policies, our approach detected 300 of the total of 334 violations of some completeness criteria correctly, while producing 23 false positives. The approach thus has a precision of 92.9% and recall of 89.8%. Compared to a baseline that applies keyword search only, our approach results in an improvement of 24.5% in precision and 38% in recall.

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