The DPIA: Clashing Stakeholder Interests in the Smart City?

The development of a Smart City hinges on the collaboration of various stakeholder groups with diverging interests. From a technological perspective, the Smart City is often considered as the pinnacle of urban efficiency. From a business perspective, there is a straight forward financial incentive to subscribe to that narrative. However, from a societal perspective, there is a clear friction regarding several values and norms. Data protection constitutes one such important area of conflict. This chapter focuses on the data protection impact assessment (DPIA) in the context of smart city service development, and identifies and evaluates the various stakeholder interests that feature during this particular data protection interaction. Through 16 data protection expert interviews, we identify eleven pertinent, distinct interests: i. compliance; ii. cost control; iii. data management; iv. efficiency; v. generation of trust; vi. income acquisition; vii. limiting impact on service performance; viii. reputation building; ix. risk management; x. safeguarding competition; and xi. safeguarding data security. The interests can be categorised in a financial, competition/competitiveness, social, and risk theme. Using the analytical hierarchy process (AHP) method, we evaluate the salience of the interests in the context of the DPIA. We find generation of trust, safeguarding data security, and risk management to be the most salient. The relative lack of importance of financial and competition/competitiveness interests is remarkable. The results of this exploratory research support all Smart City stakeholders in clarifying and rationalising their data protection interactions, and serve as indicators for potential DPIA pitfalls. Furthermore, stakeholders can use these findings to maximise their influence on the DPIA through coalition building. Data protection authorities can utilise this explorative study as a starting point to develop participation guidelines. Diligent stakeholder interest consideration is central to sustainable Smart City development, this chapter lays the groundwork for further research.