Serious Privacy

An Open Letter from Open Rights Group

Dr. K Royal, Paul Breitbarth & Ralph O'Brien Season 6 Episode 43

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On this episode of Serious Privacy, Ralph O'Brien  and Dr. K Royal (while Paul Breitbarth is out) connect with Mariano delli Santi of Open Rights Group - a civil society pressure group - regarding an open letter to the UK department of Science Innovation and Technology (DSIT), signed by over 70 organisations and individuals, regarding the industry perceived lack of enforcement action by the UK's Information Commissioner and calling for an enquiry.

You can find the letter here, and further information here.

If you have comments or questions, find us on LinkedIn and Instagram @seriousprivacy, and on BlueSky under @seriousprivacy.eu, @europaulb.seriousprivacy.eu, @heartofprivacy.bsky.app and @igrobrien.seriousprivacy.eu, and email podcast@seriousprivacy.eu. Rate and Review us!

From Season 6, our episodes are edited by Fey O'Brien. Our intro and exit music is Channel Intro 24 by Sascha Ende, licensed under CC BY 4.0. with the voiceover by Tim Foley.

SPEAKER_00

You're listening to Serious Privacy, powered by Trust Art. Here are your hosts, Paul Breitbart, Ralph O'Brien, and Dr. Kay Royal.

Ralph

So hello and welcome to another edition of the Serious Privacy Podcast. You might note that it's me, Ralph O'Brien, leading the intro today because our colleague Paul Breibarth is away doing some very important meetings with his legal counsel. I'm sure there's nothing untoward, and I'm sure it's just his normal, it's normal day-to-day work. But obviously, Her Majesty Kay Royal is with us as well. And actually, today on the Pulp Class, we're joined by Mariano Del Santi as well, who is a legal and policy officer at Open Rights Group. Now, why are we talking to Mariano? It's because this week the Open Rights Group and a coalition of signatories have released a letter that has gone out into the community asking YCO to review its enforcement policy. And in the UK, the Department of Science, Innovation and Technology to carry out an inquiry as to their enforcement functions. Full disclosure, I am one of the signatories, but I will do my best to stay policy neutral as we go through the questioning. But until then, my name is Ralph O'Brien.

K

And I'm Kay Royal, and welcome to Serious Privacy. So, Mariano, thank you so much for joining our podcast. We're absolutely delighted to have you here, and we hope you are ready for the unexpected question.

SPEAKER_01

Hi everyone, and thank you for inviting me and looking forward for the unexpected questions, particularly about and that is on a scale of one to ten, how much of a team player are you? I'd say a seven.

K

A seven? Anything go along with that?

SPEAKER_01

No, sorry, what do you mean?

K

Why a seven? And I have to say, I basically I think I was gonna give her six or seven for myself as well. And the reason being because I think I'm a very independent worker and I do most everything alone, but I have no problem working with the team. My podcast is a team effort, right? So a my reasons for saying a six or a seven, so I'm gonna go with the six point eight two just for the heck of it, is because I am a control freak. I'm sorry, I am a control freak. I delegate very well. Ralph has worked with me, I delegate very well, but I do have expectations that the quality of the product returned will be as high as the quality I would do myself. Doesn't have to be the same way, doesn't have to be the same answer, but it needs to be the same level of quality, right? Unless I'm mentoring someone junior and we're gonna slowly raise up the quality of their work. But that's why I would give myself a 6.82. Do what? Uh-huh.

Ralph

So Kay's always disappointed, is what I'm hearing. Pretty much.

K

I don't. I have a fabulous team and they do fabulous work. So I love to delegate, but I am a control freak. So I would say as a team player, 6.82. So with that kind of context, Mariana, why would you be a seven?

SPEAKER_01

I will say part of the explanation is actually very similar to what you just said. Like my work involves a lot of individual work, also because of the nature of it. I'm basically the legal expert at open rights group, and therefore there are things that I can only do or I can only answer. And there comes the fact that like working alone was nice. On the other hand, yes, I did find myself working a lot in particular with the coalitions or with external organizations.

K

Yeah.

SPEAKER_01

And also internally giving like just advice or generally speaking, uh supplementing like the how to call it, the expertise.

K

I like it. And this letter that we're talking about was teamwork, right? So clearly you're capable of teamwork. I like the seven. Okay, Ralph, what you got for us?

Ralph

I mean, the six or the seven is the safe answer, isn't it? But yeah, everything we do is collaboratives and it involves humans, right? So we have to be somewhat of a team player. We have to morph or mask ourselves to speak to people in multiple environments, whether they're one day we could be walking to a to talking to a C-level board, the next day we could be talking to the new office apprentice who's just arrived. So I do like to think of myself as a person of the people. But that's your number.

K

You have avoided giving a number. What's your number?

Ralph

I haven't even given me a number, haven't I? Um I'm gonna go for an eight. The reason why I go Yeah, I because I'm, you know, I I believe it I believe it it takes a village, it takes village, but then again, I do run a company of one.

K

Yeah. Exactly.

SPEAKER_01

So yes. No, so yes, about the ICO letter. I guess so there are a few things that like that we can start saying about this. The letter was assigned by Open Rights Group together with another 73 among civil society, data protection experts, and academics. It was addressed at the Select Committee for Science, Innovation and Technology of the UK Parliament to ask them to basically open a full inquiry into the performance of the ICL. The triggering factor that led to the, let's say, yeah, the organization and eventually the publication of this letter was the Afghan data breach. For those who maybe are not following too much what's going on in the United Kingdom, there was this long series of data breaches that occurred between 2021 and 2022 in the Ministry of Defense during the British withdrawal from Afghanistan following the takeover from the Taliban's. And those data breaches exposed up to 19,000 people and their family to fundamentally they exposed the identity of the people who were cooperating with the British government at the time. And these therefore exposed their lives to danger. There are some reports that actually suggest that up to 49 people may have died as a result of these data breaches. And this is where the interesting part comes in, which is the ICO decided never to open a formal investigation about the Ministry of Defense and their behavior. And this despite the fact that the data protection failures in this regard were very easy but also like very concerning. Like we have the Ministry of Defense writing email recipients and addresses in the carbon copy of emails instead of the blank carbon copy, typically issues that is going around. Or state about people with the Excel spreadsheet. So it's like the kind of a very baseline data security practices that were not respected. But given the gravity of the situation, these actually had very serious and to a certain extent tragic consequences for the people who were involved.

K

Then, Ralph, after that wonderful introduction from Mariano about the letter and the reasons behind it, I'm gonna let you have the first question.

Ralph

Thank you for that great sort of summary there. So a number of civil society groups and yourself clearly concerned about the fact that the Afghan data breach, especially as a perhaps a trigger, the straw that broke the camel's back, shall we say, is of concern that the ICO um's policy position is certainly one that might, let's say, encourage bad behaviours. And you're asking the Department of Science, Innovation and Technology to perform a review. So I guess my question is, because I don't sign open letters lightly, and I don't necessarily agree with everything that everyone says. You don't like people to speak on your behalf. But I do think it's important that we encourage a regulator to take a very proactive position. So I guess my question is what are you hoping to achieve? What's the result? What are we trying to get out of this? Where how is ORG and its partner organizations planning to move the needle?

SPEAKER_01

That's a very good question, Ralph.

K

And um I'm gonna say, wow, Mariana, that was a really deep question. I wasn't expecting that one, but okay, let's jump in.

SPEAKER_01

Yeah, so part of what is going on in the UK, and of course the Afghan data breach, again, was the triggering factor, but as we actually articulate in the open letter, uh, the Afghan data breach doesn't happen in isolation, but within a context where the SEO has continuously been withdrawing or shying away from using its enforcement powers for upholding the GDPR specifically or information rights more generally. And this is concerning because of the role that the ICO is supposed to play in British society, which is being the data protection watchdog that upholds those rights in the public interest. If we look at how we got to this point, I would say that on the one hand, of course, there have always been concerns about the ICO in the United Kingdom. This is one of the favorite sports of data protection practitioners and professionals in this country. But there was a very turn-of-event in 2020-2021 when, first of all, the government started to ventilate this idea of deregulating data protection in the United Kingdom. Now the idea has gone more international and the European Union is doing something similar. But at the time this was very tied with the Brexit freedoms and the idea of now that we left the European Union, we can get rid of this European Union regulation nonsense and rid the opportunities of Brexit and everything that goes with that. And at the time, together with this, the then Minister for Science, Innovation and Technology for DCMS was when they opened the selection procedure for the new information commissioner, they specifically tied this with the deregulation agenda that the government had in mind at the time. They published a selection notice saying that they were looking for an information commissioner to basically support implementation of the national data strategy. That was the document that outlined part of the idea of withdrawing regulations on data and eventually data new direction. And they called this basically the first step toward this new direction of data protection in the United Kingdom. And eventually the data protection reform came. There is a lot that could be saying about this, but for the time being, I'm gonna withhold myself and myself. But I guess the interesting part here is the government has changed, but the commitment of the information commissioner for following that new direction of data that was shaped at the time has obviously stayed and under the tenure of John Edwards, let's say the enforcement of data protection has definitely become a lot more relaxed, let's put it this way, for reasons that he actually explains and explains very strenuously. He is of the opinion that not enforcing the law is gonna lead people to comply with the law more, and he thinks that this is part of the shape that is given to the organization as part of the ICO 2025 strategy that published. This, of course, emphasizes that the ICO is on a path for continuing to, let's say, behave in this way and to further, let's say, yeah, to make this approach in a way even worse. Part of what we talked about in the last part of what we're talking is exactly that together with what is going on at the moment, there are also now a lot of consultations that the ICO has launched following the UK data protection reform. And each consultation has its own little problems, but they paint a picture of the ICO further deregulating, further deciding not to enforce the law on various grounds. This is where we think that politics needs to turn. This is not a problem that obviously can be solved by talking to the ICO themselves because the ICO believes in what they're doing, and in a way they have said that they are going to continue in this path. But it is up to Parliament to, first of all, they have a duty to scrutinize the ICO and what they're doing, and second of all, Parliament is the United Kingdom the institution that has the power to write the laws.

unknown

Right.

SPEAKER_01

The ICO is the watchdog that is supposed to enforce the laws. So the Parliament needs to take an interest in what is going on here and needs to say whether they are fine or not with the direction of travel that we are witnessing.

Ralph

So let's be clear here. Let's be clear here. And uh, you know, I I want to make sort of a bit of a personal statement here as well. The target isn't really the ICO and the good people that work there. I would I would say people often accuse me of attacking the ICO or being very negative toward white wrong. But actually, I actually believe that 99% of the people who work at the ICO are good, hardworking public servants just trying to do their job. I actually believe that most people who work at the regulator want to do good things and are honestly doing their best to make the world a better place. I think my problem, and I think Mariano, what you're saying there, lies with some of the policy decisions that are being made at a high level. As you say, we've got an ICO that's supposed to be an independent supervisory authority. However, this incarnation of the ICO that we've seen pro post-Brexit has been one shaped by government policy, therefore not quite so independent. And I think that so this open letter, I don't think in any way I want it to be said that we're taking away from the good hard work the people at the ICO are doing, but instead trying to shift the needle in terms of the policy decisions and influences put on the ICO by the government. Is that a sort of fair summary, Mariano?

SPEAKER_01

I think it's definitely fair to say this. Like we try to let as impersonal as possible and to emphasize that the issue we are complaining about is an institutional issue, it's not necessarily a personal issue. And yeah, institutional issues need to be addressed in an institutional way, and this is why we are asking to parliament to step in.

K

Yeah, and I think the letter is presented in a very factual, impartial manner, and of course we'll link the letter for the listeners to be able to look at for themselves. I want to throw in a personal note that uh I met John Edwards once and he left a very bad impression. And I've mentioned this before, it's a factual thing that happened, but at the Global Privacy Assembly in Jersey at the opening cocktail hour the night before, Ralph pointed out John Edwards to me because I've always wanted to meet him. I've wanted to have him on the podcast. And Ralph pointed him out to me. And so I walked up to him and I said, Hi, I just wanted to come meet me. I was told that you're John Edwards, he went no. I'm like, you're not John Edwards. And I looked back over at Ralph and them. I'm like, are y'all yanking my taily or something? And they're like, no, that's John. So I said, seriously? I said, Are you messing with me or are you really not John Edwards? He's, I don't know what you mean by messing with you, but yes, I am John Edwards. I'm like, nice to meet you. Bye. Yeah. And walked away. Something like that.

Ralph

Yeah, it's difficult. We're all people with personalities. As I said, I don't really have a problem with anyone personally who works at the IC.

K

And the Brits have a very dry sense of humor.

Ralph

I get that, but I was like, Jordan's actually from New Zealand, so that's probably even a good one.

K

Well, there you go. I can't blame it on that then.

Ralph

Yeah. In fact, our most recently, our most recent commissioners have been a Canadian and a New Zealand.

K

There you go. And we have what, an American in that's the commissioner of Wales in Australia now, or David White, isn't he an American? I think so. I'd have to go back and look. Anyway, you're right. People are commissioners of other countries, whether they grew up under those laws or not. But yeah, that left that that just left a bad impression. I can't say it made me think bad about what he does professionally, but he is the head of the ICO. Yes, he is pushing these policy decisions.

Ralph

So and I can assure everybody on the podcast that we were not winding up, Kay, and that was genuinely John Edwards who were it really was him.

K

They were not yanking my tail. He was, but it just it wasn't a fangirl moment, but it was a oh, I want to meet you. I wanted you on the podcast. And he just completely said he wasn't John Edwards.

Ralph

So yeah, well when he first started, it was very interesting. He did a listening tour. So he went round the yeah, he started and he went round and he spoke to a load of groups. And I think that he listened I actually think he did, but I don't think but I think the groups he listened to were from business and industry. For example, Mariano, I don't think the listening tour included civil service groups like the open rights group.

SPEAKER_01

The listening tour, yes, there were some instances where he spoke to civic society. Oh, yeah, yeah, let's say contrary to business groups, pro we can't really say that our voices were listened to much. I would say that most of the concerns and the things I were complaining about at the time have, if not materialized, gotten worse.

K

So it's not just important to do a listening tour, it's important to listen to the all the people, not just some of the people. Yeah.

Ralph

I think that's true. Yeah, no, I I think that's true. Yeah, I don't want to turn this podcast into a doubling down on on negativity about the uh about the commissioner. But of course, the next thing to actually consider, Mariano, is we're not going to have an information commissioner. We're going to have an information commission soon under the Data Use and Access Act. As you know, that the Data Use and Access Act is changing UK law. And instead of having a single information commissioner, John Edwards has planned to transition to the chair of the Information Commission. And if you speak to the government that says this modernises the way it works, makes it more corporate. And they have selected a number of people to sit on this new information commission, the job description of which I've read. And the job description talks far more about investing in the digital economy than it does about protecting rights. I'm just wondering your view from the open rights group, what this change of structure, because you're you're submitting comments to an information commissioner's office that essentially isn't going to exist and it's got to be an information commission in a very short order. So what are your views on whether that will lead to perhaps a change positively or a change negatively?

SPEAKER_01

Yes, indeed, this change is already happening. There are some executive directors that have already been nominated. And I think that the from a structural level, the ICO is still undergoing changes, so they haven't completed this passage from solo, let's say, uh single information commissioner to a corporation with a collegial structure. But yeah, that's definitely something which is going to happen, last but not least, because the law dictates that it has to happen. And so we, of course, this was, of course, a point that we have addressed as open rights group during the scrutiny and eventually the passage of the Data Use and Access Act. And per se, we're not necessarily against the change to a corporation, from a soul to a corporation. What we are more concerned about, we used to be more concerned about, was the procedure for the nomination and the appointment of these members that gives a lot of power to the government to basically select the people that they want to be in there. And this comes again at a cost of having the government being able to shape the role of the information commissioner potentially in a way that doesn't necessarily matches the statutory duties and requirements of the information commission. Like in theory, you have a data protection regulator that has a statutory duty to enforce the law. But then you do have the government of the day with all their priorities. At the moment, there is a very strong ethos in the United Kingdom toward the economic growth. And together with this deregulation as a way to attract foreign investments and let US data prote US big tech companies more at ease with the business environment of the United Kingdom. And those two things, of course, split between each other. And the more you give the new information commission, so the government, the power to shape the composition of the information commissioner, the new information commission, the more you run into the risk of the information commissioner, the information commission going further away from the role that they were supposed to play, or that Parliament has designed for them to play in the law. And this is a risk that we think is still there, and of course we will keep uh working on, but that's probably a conversation and maybe an open letter for another time.

Ralph

An open letter for another time. I like that.

K

Oh, I like the way he's looking to the future.

Ralph

Yeah, more open letters coming from the ORG. So moving on then, just looking at ways we can move the needle. One of the other big things that the UK will obviously be concerned about is adequacy from the rest of the EU. Now we've got some opinions from the EU, or certainly some of the draft decisions on UK adequacy that we know expires in December. We were granted that extra six months because the Data Use and Access Act was changing our law. So we've got this sort of now new situation where we were granted an extension for adequacy because they wanted to see how the Data Use and Access Act played out. And we're now starting to see opinions from the European Data Protection Board and the European Commission. My understanding of those adequacy determinations was that the EU doesn't seem too worried that we're going to carry on being adequate. So do you think the EU is doing its job properly in assessing our adequacy if we no longer have an independent supervisory authority?

SPEAKER_01

We all know that when it comes to adequacy decisions, the commission the European Commission has to has been doing, let's say, questionable job, let's put it this way. And like today, of course, there's a I mean, like the yeah, the like the implement the draft implementing decision that will extend the adequate quality decision for the United States. And that they are generally satisfied with the level of protection in the United Kingdom, which to a certain extent is not surprising because so far they are still satisfied about the level of protection that the United States and the data protection framework provides, despite the fact that most of the funding elements of that operate have basically blown up following the entrance of the Trump administration. Having said that, I think that the well it has to be recognized that in this particular moment there is a very unique, let's say, political climate in Europe and in the European Commission. It makes certain decisions more difficult to take. And like notwithstanding that they are saying they want to go on with the UK adequacy, there are however a lot of concerns that are raised some of them in the draft implementing decisions, but most importantly by the opinion of the European Data Protection Board. That is on the one end concern about the general screen inherited powers or delegated legitimate power of a User Access that gives the UK government for further region from European data protection. And lastly, also the performance on some of the calls for views that the ICO has published following the passage of the Data Use and Access Act also made it into the opinion of the European Data Protection Board. And they are in particular concern about issues like the call for views where they are the ICO is considering their appropriate claim for what this will mean for the plane of data subjects. So I would say that in general although we can all expect that the UK data adequacy decision is going to be renewed, but the problems that we have identified when the data using access app was being passed are still there. And European institutions do know that this is a problem, and except for the Commission that right now it's not in attribution certain mood. But those issues are not going away. And there is definitely work that needs to be done inside in the United Kingdom to, let's say, avoid having the government getting too comfortable with their irritate powers and using them in a way that could eventually be the last straw for the European Union and lead to the withdrawal of the UK. Or, like also, let's remember that we talk a lot about what the European Commission is going to do, but uh usually adequacy decisions fall down because the corporate justice gets involved in this. And uh yeah, that's there is no politics that's gonna stop the corporate justice of the European Union from intervening if they are called to intervene. There is definitely a risk there, and risk that I would say right now it's not really felt in the UK political climbing, and that there is a lot of work to be done to make this risk clear and to make this risk understood within the policy circle.

Ralph

That's really interesting. The conversation around more of a personal one. I'm looking at your LinkedIn profile here, and I can see that you've done a number of things, including being at Vault Europe. So there you go. You're obviously You're obviously an Italian living in the UK. So how did you end up open rights group? How did that occur? How did what was your deal?

SPEAKER_01

I was attracted by the amazing weather and food of the United Kingdom.

K

So I came considering that I was there last week, two weeks ago, I'm gonna I'm gonna call you on that one. The food, yes. The weather, not so much.

SPEAKER_01

Not how to say, sorry, say from a professional personal point of view. So I started as a law student and like in particular in law, like with a background in constitutional law and media law, and yeah, from media law, like I eventually went to me get the internet and ended up the data protection at the time became the big thing.

K

Natural move. How long ago was that? I hate to ask.

SPEAKER_01

So I did a law degree in Italy for disclosure, like degrees in law degrees in Italy last five years, like by default, and usually a lot or usually more. For instance, in my case, it was six uh years and a half.

K

Okay.

SPEAKER_01

And let's say so. It was a long, yeah, it took some time, right? It was it took a degree, but it's a long degree. And after that, I did a master of in information technology law in Estonia for a year as well. And yeah, Estonia, other than being very useful for preparing me for the English weather, was also a very interesting experience, both in terms of the country and of course of the digital government and all the things which are going on in there.

K

Some of which you were made for privacy law with the background in constitutional law, media, and IT. I'm not sure what else you would have wound up in except maybe a journalist degree. You were made for privacy.

SPEAKER_01

Possibly. And it's interesting that you mention it because like originally at the very beginning, I started studying law with the idea of becoming a journalist, and eventually I decided to go. Yeah. Eventually my life took a different turn, but yeah, so that was part of it. And I guess that's on the one end, so on the one end, there is there has been this background. On the other hand, I was very involved in student organizations and in advocacy, originally in particular with the Erasmus Student Network concerning the Erasmus Keynes Student Program, and with the European Law Student Association concerning some aspects in there, including a book about Brexit, think what the legal aspects of Brexit. And yes, Open Rights Group eventually became this opportunity for joining my advocacy side that was more about trying to influence institutions to do certain things in a certain way, together with what at the time was my job, which was a data protection officer and generally speaking data protection expert. So this is how I ended up in the UK. They were looking for a legal and policy officer, they published a job post, I answered, and eventually they got me the job. At the time, yes, as Ralph mentioned, I was being the data protection officer of Europa, which was this still is this pan-European political party that was funded actually by some friends of friends with the idea of making European politics more political, let's put it in this way. And because usually so one of the problems with the European politics, I would say, is that usually there is a degree of intermediation where you vote for your national party and then those people go to Brussels and they join a group. And generally speaking, something that you also notice in the and it's actually relevant in my field, the one you advocate in a different way when you are in the UK from when you are in the EU, exactly because uh the union uh has this more policy-heavy and in a way expert-heavy environment, whereas the UK is like a very day-to-day politics with member of parliaments which are written but who are written by their constituents about all sorts of problems. And the political agenda is usually not about big picture issues, like more about more mundane issues, I would say. And this just shapes the way the political discourse goes in a different way. And yeah, I saw for my involvement there apart from that very beginning, contributing to writing the statutes and all this stuff, and that was also the times when the GDPR was starting, you know, was set to force. And I had the idea of going to the founders of Walter Open saying you need a data protection officer, and this is where I got trapped into becoming one of them.

Ralph

Like that, I like that.

SPEAKER_01

Yeah, so that's how I got the job there.

K

That's a team player. That's a team player right there.

Ralph

I have never met a data protection officer who said, Oh, I played for this, I really wanted the role. I had only ever met people who said, I didn't dodge the bullet fast enough. Or it's normally people who were doing something and then got told by the management that they were it and had to work into it. So perhaps my final question before we wrap up, because we like to keep our podcasts fairly short, is perhaps just about the open rights group itself. We've talked about the open rights group as a civil society representative, but perhaps you might just want to tell people who don't know on the podcast who what the ORG is, what they do, and perhaps pitch for support.

K

Yeah, yeah.

SPEAKER_01

I'm glad. The Open Rights Group is a civic society organization based in the United Kingdom and in particular in London. We fight for digital rights in a digital age. And usually we deal with the issues related to freedom of expression and specifically data protection in my case. Why is this important? Because today our lives is more and more intermediated by digital services and digital tools, and whether our interests and our rights are enshrined and represented in the way those tools function makes a big difference into how our lives are affected by those tools and how we can assert our rights in this and our interests in those regards. We are also, I would say, the big campaigning organization with thousands of members across the United Kingdom. And we try to put pressure on politicians, on the government, on all levels of governments to make sure that the regulation, that laws, that policies do represent the interests of individuals, the interests of the British public and the interests of the UK residents. That is, I would say, something which is enshrined in the mission of civil society. Civil society works in an environment which is heavily dominated by industry or business interests. And it is important that in those circles, the opinions of the main industry who don't have the time or don't have the energy or don't have the expertise to join those conversations is represented. And this is what we're trying to do. And yes, of course, as if you are interested in knowing more about what the Open Rights Group is doing or in supporting us in any way, you can visit our website at www.openrightsgroup.org. You can follow up, you can subscribe for updates there, you can donate, or you can become a member and help us shaping a future that is a more friendly future for all of us. This is my pitch for you.

Ralph

And what a perfect way to leave it. Let's have a brighter future for all of us.

K

Thank you.

SPEAKER_03

That was serious privacy. This wraps up our podcast for this week. Please do share the episode with your friends and colleagues because we love to get more listeners. And join conversation on LinkedIn or on Blue Sky. You'll find us under Sirius Privacy on both platforms. You'll find Kay as Heart of Privacy, Ralph as IGR O'Rion, and myself as Europol V. Until next week, goodbye. Goodbye.

K

Bye y'all.