Page - 577 - in VULNERABLE - The Law, Policy and Ethics of COVID-19

577COVID-19 and Accountable Artificial Intelligence in a Global Context supersede privacy laws.18 Even worse, people already in positions of vulnerability as aid recipients or refugee claimants have very little to control over their own data protection and very few have the actual capacity to consent. Importantly, data used to fight COVID-19 can be subverted for other, more nefarious, purposes. The security firm FireEye has reported that personal data was used in Syria to monitor and target dissidents.19 In the past, data used by humanitarian organizations to distribute aid has been hacked and diverted in this way in a number of other conflict-ridden areas, including Yemen.20 The information col- lected during a pandemic includes health information of populations that are marginalized or even oppressed. Humanitarian organizations are having to prevent the nefarious use and misappropriation of the personal data of the most vulnerable and impoverished persons in the world by actors ranging from militaries to authoritarian regimes to amorphous hacker armies.21 Moreover, the collection and use of population data can also generate risks of racial discrimination based on data concerning vulnerable communities. It is therefore essential to protect sensitive information that concerns not only individual infor- mation but also group-level information. The Centre for Humanitarian Data, a part of the United Nations Centre for the Coordination of Humanitarian Affairs, has published responsible data guidelines, with a focus on countries experiencing humanitarian crisis.22 These guidelines include precautions for ano- nymization, understanding sensitive data, and techniques, such as Statistical Disclosure Control, which may ensure that data is safe to publish. The Centre has also developed a Peer Review Framework, which aims to provide ethical oversight of analytical models 18. “Privacy and the Covid-19 Outbreak” (March 2020), online: Office  of  the  Privacy  Commissioner  of  Canada <https://www.priv.gc.ca/en/privacy-topics/ health-genetic-and-other-body-information/health-emergencies/gd_covid_ 202003/>. 19. FireEye, “Behind the Syrian Conflict’s Digital Frontlines” (February 2015), online (pdf): FireEye <https://www.fireeye.com/content/dam/fireeye-www/global/en/ current-threats/pdfs/rpt-behind-the-syria-conflict.pdf>. 20. “In Search of Better Data Protection for Those Caught in Conflict” (1 February 2019), online: Open Canada <https://www.opencanada.org/features/search-better-data- protection-those-caught-conflict/>. 21. Ibid. 22. Centre for Humanitarian Data, “FAQ on Data Responsibility for Covid-19” (11 May 2020), online: Humanitarian  Data  Exchange <https://data.humdata.org/ faq-data-responsibility-covid-19>.