Governments rarely make their best decisions in a crisis. Crises do not lend themselves to perfect policy making. There is no time for the careful analysis and discussion of unintended consequences that would normally be seen as essential. A pandemic requires us to settle for ‘good enough’, to avoid making perfection the enemy of what works, and get on with whatever saves lives. That is true of vaccine development, drug therapies and testing products, and it is also true of contact tracing technology solutions. But just as we are clear about the safety and efficacy redlines for a vaccine, however willing we may be to fast-track trials and cut through regulatory red tape, we should also be clear about our core principles and redlines for privacy. We should then make sure that we revisit these decisions in quieter time, after the crisis, and adjust accordingly.

1. 10/19/20, 2:19 PMCOVID contact-tracing apps and privacy — Robert Hannigan | by Robert Hannigan | Medium
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Robert Hannigan
12 Followers · About Follow
COVID contact-tracing apps
and privacy — Robert
Hannigan
Robert Hannigan Apr 24 · 4 min read
Governments rarely make their best decisions in a crisis. Crises do
not lend themselves to perfect policy making. There is no time for
the careful analysis and discussion of unintended consequences
that would normally be seen as essential. A pandemic requires us
to settle for ‘good enough’, to avoid making perfection the enemy
of what works, and get on with whatever saves lives. That is true
of vaccine development, drug therapies and testing products, and
it is also true of contact tracing technology solutions. But just as
we are clear about the safety and eCcacy redlines for a vaccine,
however willing we may be to fast-track trials and cut through
regulatory red tape, we should also be clear about our core
principles and redlines for privacy. We should then make sure that
we revisit these decisions in quieter time, after the crisis, and
Get started

2. 10/19/20, 2:19 PMCOVID contact-tracing apps and privacy — Robert Hannigan | by Robert Hannigan | Medium
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adjust accordingly.
Under pressure to Gnd ways of reviving economic activity in
advance of a vaccine or treatment for Covid, many governments
and public health authorities are looking to smartphones to solve
the problem of tracing and alerting. They know, as we all do, that
a traditional human-staHed contact-tracing bureaucracy simply
cannot be scaled up to deal with a very large population at the
necessary speed in the middle of a pandemic. Investigation of
each case takes too long and uses too much resource.
The evidence from countries where a technology Gx has been
tried already, notably in South Korea and Singapore, suggests that
contact tracing apps can be a useful supplement to public health
initiatives but are not a magic solution. They rely on extensive
testing, which many countries are still struggling with, require
wide-spread adoption to be useful, and will always return a
signiGcant number of false positives and false negatives.
Nonetheless, they oHer citizens a rough-and-ready guide to any
likely exposure to someone with Coronavirus and should
therefore help populations to isolate based on risk, rather than as
a blanket precaution for the whole country.
But the practical caveats about how eHective they will be have
been outweighed by legitimate concerns about intrusion on
privacy. At the extremes, a contact tracing app could become a

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remarkably comprehensive surveillance device and could be
misused to discriminate against groups or individuals on a huge
scale. We can avoid this if we ensure tracing apps meet certain
criteria.
First the scope of what information is being ‘collected’ should be
strictly limited. There is a huge variety of useful information that
could be gathered about an individual’s health, but that is for
debate in the future: this should not become a health ‘Gshing trip’,
however well intentioned. Now, the only data that should be
recorded is an individual’s Covid history and their likely contact
with others. The precise geographical location of the person and
their actual identity are also irrelevant, although wider patterns
of Covid exposure in particular regions will be helpful to health
authorities.
Second, who stores and holds this data and who has access to it is
critical. As far as possible data should remain with the individual
and only be aggregated to public health authorities where
necessary. There should be complete transparency about who can
access this data and why. It should be deleted as quickly as
possible.
Finally, the purposes for which this data can be used should be

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limited strictly to the pandemic. The temptation to allow public
authorities or private companies, including advertisers, to do all
sorts of other things with this information, however useful,
should be resisted. The debate about the use of personal data in
healthcare is already lively and needs to be taken much further in
the future, but now is not the time to rush to a conclusion.
As far as possible these principles should be built into the
technology so that the app itself protects privacy by design and as
a key priority. I have avoided being prescriptive about which
technical solution meets these tests, though it will be obvious that
the Apple/Google proposal to enable localised contact tracing by
Bluetooth comes close. But given that any solution which is useful
in public healthterms will have some Raws, rigorous oversight by
an independent body should go alongside this. Most democracies
already have such regulators and will not need to invent them.
Public trust is key to data handling: both big tech companies and
governments have learnt this the hard way in recent years. An app
which citizens believe may be abused by the private sector or
government will not be widely used and will defeat the whole
purpose.
Perhaps most importantly, these contact tracing apps should be
limited in time to the pandemic and not allowed to roll on
seamlessly into the future. As well as helping in the crisis, they
could then become a genuinely useful experiment in mass

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technology solutions for public health. If we can study and learn
the lessons, both on eHectiveness and privacy, we could then have
developed a key tool in the management of future pandemics.
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