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Data protection and digital ID


Our work includes:

Macmillan Keck’s partners have had an influential role in developing laws on data protection and digital ID in the United States and Europe since the 1990s. More recently, while continuing to work in the United States and Europe, the firm has brought this expertise to many developing countries. The firm has recently advised governments, regulators and private sector clients in Europe, Asia and Africa on legal, regulatory and policy matters relating to data protection and digital ID.

Recent activities include:

Advising the World Bank’s ID4D program to guide its assessment of data protection legal and regulatory frameworks in developing countries and their readiness to support national ID programs. The toolkit comprises over 100 questions along with explanatory text on key issues and examples from evolving international practice.

Advising a US cloud-based healthcare records data hosting provider on compliance with federal and state privacy and information security laws and regulations governing transmission, maintenance, storage and access to protected patient health information and confidential data.

Advising Facebook in six countries on the laws and regulations relating to social media content, including privacy, security, and censorship, and access to telecommunications operators’ consumer data.

Reviewing and assessing a data protection bill under consideration by Nigeria’s Parliament as part of the World Bank’s evaluation of the country’s legal and regulatory readiness for development of its national ID program.

Assessing data protection and privacy provisions included in the Philippines’ recently enacted national ID framework, including legislation and draft implementing rules and regulations, for the World Bank.

Assessing Somalia’s data protection legal and regulatory framework as part of the World Bank’s evaluation of its readiness to implement a national ID program.


Since 2017, Rory has served as co-chair of the Security, Infrastructure and Trust Working Group of the ITU, World Bank and Bill & Melinda Gates Foundation Financial Inclusion Global Initiative (FIGI), including drafting the group’s 50-page paper on Data Privacy, Big Data, Machine Learning, Consumer Protection and Data Privacy.

In 2016, Rory co-authored the GSMA paper, Regulatory and policy trends impacting Digital Identity and the role of mobile, which examines regulatory issues related to digital identity, including data protection and privacy.





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