The contact tracing app built by the Singapore Government, TraceTogether, seemed built for the epidemic. Everyone has a phone with Bluetooth and we need to know who the infected have contact with in order to stop its spread. However, its take-up rate is around 25%, far from its target of 75%.

Since everyone has (inexplicably) failed to download TraceTogether voluntarily, many are now trying to explain why it has failed. There’s a common culprit: data protection.

AP Warren Chik (who has a new book on IT laws coming up) argues that in times of national crises, novel solutions should be exempted from the PDPA.

… a main issue is the public and private use of personal data and how the personal data regime may require the above to operate, or otherwise exempt data management from the Personal Data Protection Act (PDPA). In fact, many data protection laws have already put in place exemptions that can and should apply in a situation involving a pandemic of such proportions as the COVID-19 situation that we are facing today.

AP Warren Chik, Coronavirus: Pandemics, Artificial Intelligence and Personal Data

This echoes a similar call I noted in my previous post which argued that the government should take advantage of its exclusion under the PDPA.

Oddly enough, others claim that we should ignore the Government’s not-so-stellar data protection record and give it a fresh start. Maybe as long we are in charge, we should forget about our data protection fears and look at the benefits.

Others advocate that the government should just make TraceTogether compulsory.

Give Data Protection a Break

I get the impression from these articles that data protection is a hindrance or is being given more attention than it deserves. This is despite my opinion that the people who did TraceTogether took data protection very seriously. Having failed to quelch our fears, does it mean that their efforts were wasted or that data protection failed?

Coming from a compliance background, I am well aware of its limits. These limits also apply to data protection. People rarely buy a product for the sole reason that it offers the “best” data protection. If this was the case, everyone would stop using Facebook. You can’t expect data protection to sell your product.

Conversely, think about this counterfactual. If the TraceTogether completely ignored data protection, what would happen? They would have lost their shot. Everyone would have the impression that the Government does not care about personal data. The team might rectify their mistakes, but this just adds to a long line of examples of the government’s failure to protect our data. Time to make the app compulsory!

Data protection tries to prevent the worse outcomes, but it’s not in charge of selling your App.

A closely connected idea is that data protection builds trust, and I agree it’s sexy and I would use it from time to time. However, this idea views data protection as a tool. It doesn’t promise an outcome. A 200-page data protection policy doesn’t guarantee you trust, or users for that matter.

It’s important for data protection and data protection officers not to oversell or make promises it can’t keep.

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Can we save TraceTogether?

I don’t have much of a business background, so I can’t really comment much in this regard.

I do have some experience encouraging others (my wife) to use new technology. It ain’t enough to have a great idea which is easy to use, we have to use or will improve your life 1000%. Getting commitment from user, like asking them to turn on their Bluetooth, needs a lot more effort than just releasing your App in the wild.

I have been disappointed with how the Government has rolled out this App. I don’t have any real complaints about the technology. The Government can mobilise people to distribute masks and hand sanitisers at community centres and even complain on their neighbours. Why can’t it get boots on the ground, get to every door and explain TraceTogether to everyone at home? Having someone in your community tell you personally that they downloaded the app and would like you to do so too is a powerful image.

It turns out that releasing an app is not as easy as it looks.

COVID-19 is the challenge of our times. Check out my writing on the data protection and other issues in this area:

Update: 5 June 2020

It’s been announced in Parliament that a “portable and wearable contact tracing device” which will “achieve the same objectives” as TraceTogether. Did the government give up on TraceTogether? Distributing a device might be more up the Government’s alley than distributing an App. I also think it was one of the more obvious solutions that should have explored in the first place. Would it turn out to be worse for privacy than TraceTogether? The devil is in the details…

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