telcome2015_iotregulation
TRANSCRIPT
Collaborating on M2M
and Internet of Things
Regulation
Eamon Holley
Informa Teleco ME 2015
9 December 2015
Today
Bringing together key stakeholders
Big Data, Cloud and Privacy
Cyber security
Devising a framework
2
Next Steps – a suggestion
A regional M2M/IoT working group
DLA Piper established groups in EU, Asia
To develop industry led whitepapers on topics of specific
relevance to the GCC region
Free initiative i.e., no financial cost to join or participate
If interested, please contact me
3
But before we begin…
Why isn't this a regulatory HOT topic?
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M2M and the Internet of (Every)Things
2020 : Globally, 50 billion connected things and a 1 trillion dollar
industry
Humans will largely not even be aware of the work going on
around them : "Ambient networks"
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Sectors : … well, everything!
Transport
Fleet and
inventory
tracking
Health
monitoring
Real time
diagnostics
Smart
grids
Smart
homes
Smart cities
Connectivity : … well, everything!
SIMs
RFID WiFi Bluetooth GPS Fixed Line ???????
WHAT DO WE NEED TO REGULATE?
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Just a few issues to consider…
M2M
IOT
Licensing? for
Permanent Roaming?
Access to Networks
Type Approval /
Importations
Privacy and Data
Protection
(Cyber) security
Liabilities
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Questions from clients…
Could the use of a SIM in a local jurisdiction mean that M2M SP is
providing a telecommunications service in that country?
Does it need a license?
Are there data protection obligations? Are there any rules about
transferring information overseas? Can these apply to M2M?
What about local registration or verification requirements? Even for
machines only?
Are there any type approval rules for these machines, simply
because they have a data only SIM?
Are there any numbering rules?
Are there rules regarding location of equipment?
Is this subject to lawful interception? Can the service be encrypted?
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Statements from regional stakeholders…
"…not on our to do list." – Regional Regulator
"…there is no need for further specific IoT/M2M regulation at the
moment in the region. Permanent roaming though is a concern
which we believe should be discussed at the regional level. The
situation indeed should be monitored." – Incumbent Regional
Operator
"Our thoughts are based on really when is the right time to regulate,
and we don't think the case to develop specific regulation or for
regulatory intervention is there yet. It is also a matter of priorities,
and there are a myriad of more pressing concerns to address here." -
Incumbent Regional Operator
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On the other hand…
"I think it* is a good example of how regulators can facilitate an
approach which joins up the supply side and demand side. This
is essential to IoT (as we know from the experience in
automotive sector)." – European based International operator
*"Definition of a Research and Innovation Policy Leveraging
Cloud Computing and IoT Combination" – Final Report,
European Commission DG Communications Networks, Content
and Technology
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COLLABORATION
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Collaboration - Who are the stakeholders?
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"IoT" Vendors
Big Data Analysts
Cloud Vendors
Telcos Consumers
Regulators
Government
What collaboration?!
TRA UAE consultation – Industry
ITU Research Group – chaired by TRA UAE
Dubai Smart City – Open Data Law
UAE Innovation
EU initiatives
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TRA UAE
2014 – TRA UAE started liaising with UAE industry players
2015 – UAE Communications and Media Industry Group
(UCMIG) provided the TRA with technical guidance on
M2M/IoT. Particularly, M2M/IoT spectrum harmonisation in the
UAE and the region.
Currently TRA UAE position is that M2M can be dealt with
using existing regulatory framework, but is investigating more
specific M2M issues that may be regulated separately at a
later point in time
June 2015 – TRA UAE appointed as chair of a new ITU
research group on IoT
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Dubai Smart City Initiatives
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Dubai Smart Government. See
http://smartdubai.ae/whitepaper/
2014 – "make Dubai the smartest city
in the world by 2017"
66% of world's population expected
to live in cities by 2050
Gulf – 2014 89% of citizens live in
cities; 2050 expect 93% of citizens
living in cities
Smart grid; Smart government; Smart health; Smart transport;
Smart education; Smart water; Smart…
Dubai Smart City Initiatives
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Thousands of free Wi-Fi hotspots offered by du
Airconditioned bus stops with wi-fi hotspots and charging stations
Smart grid – February 2015 120,000 smart meters, by 2017 up to
200,000 smart meters
Smart palms – 6 meter high towers with nine-leaf shaped solar
panes – power wi-fi hotspots, charging stations, contain
touchscreens with information on transport options and local
weather. See http://didea.ae/portfolio/smart-palm/
Dubai Data Law
17 October 2015 – Sh. Mohammed announced passing of
Dubai Data Law
Freely available Data = Innovation
An Open Data Law – and more?
But what is Open Data? "Data that can be freely used, reused and redistributed by anyone - subject only, at most, to the requirement to attribute and sharealike".
See http://opendatahandbook.org/en/what-is-open-data/ and http://opendefinition.org/
"Publicly available data structured in a way that enables the data to be fully discoverable and usable by end users".
See White House Memorandum M-13-13, issued on 9 May 2014, titled "Open Data
Policy-Managing Information as an Asset" -
https://www.whitehouse.gov/sites/default/files/omb/memoranda/2013/m-13-
13.pdf
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Dubai Data Law
Dubai Open Data
"The information available to any entity in the Emirate of Dubai, whether governmental or in private sector, which is made available by such entity in the Emirate to individuals and governmental or non-governmental organizations, to be used or shared with third parties".
Article 2, Resolution No. 2 of 2014 On the Formation of Open Data
Committee in the Emirate of Dubai.
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Dubai Data Law
Freely available Data = Innovation
Collection of Dubai Data
Categorisation of Dubai Data – protection of privacy
Sharing certain data between Dubai government bodies
Making available Open Data to the public
Can be potentially applied to private entities that the Dubai
government deems should provide specific Data Sets
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UAE Innovation
2014 UAE's National Innovation Strategy
7 sectors - renewable energy, transport, education, health, technology,
water and space
4 tracks:
1. New and amended legislation
2. Develop government innovation by new practices, reduce spending
by 1% and use it on research and innovations
3. Encourage private sector innovation to establish research centers,
adopt new tech, develop new products and services
4. Education
2015 – UAE Year of Innovation
November – AED300 billion innovation fund
100 initiatives with major investments in education, health,
energy, transport, space and water
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Europe
"Definition of a Research and Innovation Policy
Leveraging Cloud Computing and IoT Combination"
DG Communications Networks, Content and Technology
Digital Single Market - Data Protection Regulation
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Definition of a Research and Innovation Policy
Leveraging Cloud Computing and IoT Combination
2013 and 2014 study
Desk and primary research
23 expert interviews
stakeholder workshop
development of a market estimating IoT market value by 2020
under 3 alternative scenarios
International analysis/benchmark of main IoT initiatives
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Definition of a Research and Innovation Policy
Leveraging Cloud Computing and IoT Combination
BUT
Those with higher accumulated IT investments and advance
telecom network will grow faster
Market growth could be slower if EU industry does not fully exploit
IoT revolution and opportunities
IF growth is slower than baseline expectations, then potential IoT
market value could be EU976 billion – 18% lower than baseline
IF growth is higher than baseline expectations, then potential IoT
market value could be EU1,128 billion – 5% higher than baseline
Risks from inaction or mismanagement greater than slightly
more than optimistic baseline
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Measure 2013 2020
IoT Connections 1.8 billion 6 billion
IoT Revenues EU 307 billion EU 1,181 billion
Definition of a Research and Innovation Policy
Leveraging Cloud Computing and IoT Combination
RISKS to IoT take up
Inability of EU industry, particularly SMEs, to adopt IoT
innovation on a large scale, due to insufficient investments and
organizational barriers to change
concerns about privacy and data protection
mismanagement of new security risks
lack of standards and interoperability across fragmented European markets preventing economies of scale and scope
Insert GCC here?
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EU Recommendations
13 recommendations around investment, research, encouraging
supply, creating demand uptake, removing regulatory barriers
etc.
#3 – Promote development of broad-based, open horizontal platforms in order
to overcome potential fragmentation of the EU market and support the
development of competitive supply and industry and a balanced ecosystem
#12 – EC should contribute to building trust and confidence in IoT…taking
account of psychological, social and pragmatic issues potentially affecting trust
and confidence of potential users in IoT, Cloud and Big Data an services
#13 – develop the internal single market for IoT services and applications, by
promoting the adoption of open standards and interoperable solutions across
Europ, fostering cooperation between standards bodies, pointing out regulatory
barriers and suggesting remedial actions
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Data Protection Regulation
A new, single Data Protection Regulation in Europe in 2016
Not a Directive and no need for EU member state legislation
To prevent companies dealing with myriad of laws which follow Directive
principles, but which are different
Currently plans to be stricter in catching entities outside of the EU but whose
data processing relate to the offering of goods or services to, or monitoring,
data subjects residing in the EU.
Fines based upon annual worldwide turnover
Data breach notifications
Explicit data subject consent requirements
Do these sit contrary with the DG Comm's recommendations on IoT take-
up?
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Big Data, Cloud Computing, Privacy
If data is the new oil, is privacy the water?
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Cloud Computing and Big Data
Cloud Computing
Happening
Little to no regulation surrounding it per se
Does there need to be?
Big Data
Data collection, data transfer, data storage, data processing
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Current legislative framework
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Data Protection and Privacy
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Currently no comprehensive data protection laws per se
There are laws relating to privacy, often in criminal laws such
as penal codes and cyber crime laws; Certain countries restrict
data transfer in certain sectors – KSA banking information
Generally rely upon consent for use of and transfer of data
But, no clear guidance on personal or sensitive personal data
Concept of "privacy" is stricter in the region than what we may
be used to in other countries;
Not always clear, or certain, how consent can be given, e.g.,
by electronic means
Cyber security - Threat Environment
Cyber Security becoming increasingly prominent in minds of
governments, businesses, citizens and residents in the region.
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Cyber security challenges posed?
All GCC states now have Cyber Crime laws
No GCC state a member of the Council of Europe's Budapest
Convention
GCC states members of the Arab League Convention on
Cyber Crime
No data breach requirements
CERTS in each country, but, according to one insider, little
interaction
Is this enough to reassure consumers and allow for uptake
of IoT and M2M?
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Summary
Huge opportunity, but the longer there is a delay of strategic
implementation the less benefits will be felt
Concerns regarding protecting local operators and security
(i.e., concerns regarding permanent roaming) must be
balanced against these huge opportunities. SIM based
permanent roaming is only one way that M2M and IoT will
work
Some excellent initiatives in the region e.g., Smart Dubai and
UAE's Innovations Policies
BUT a regional approach to investment and innovation policy
and regulation (licensing, roaming, numbering, spectrum)
would appear to be capable of unlocking so much more –
particularly in terms of scale and scope of economies
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Next Steps – a suggestion
A regional M2M/IoT working group
DLA Piper established groups in EU, Asia
To develop industry led whitepapers on topics of specific
relevance to the GCC region
Free initiative i.e., no financial cost to join or participate
If interested, please contact me
34