Can we trust trust-based data governance models?

Abstract Fiduciary agents and trust-based institutions are increasingly proposed and considered in legal, regulatory, and ethical discourse as an alternative or addition to a control-based model of data management. Instead of leaving it up to the citizen to decide what to do with her data and to ensure that her best interests are met, an independent person or organization will act on her behalf, potentially also taking into account the general interest. By ensuring that these interests are protected, the hope is that citizens’ willingness to share data will increase, thereby allowing for more data-driven projects. Thus, trust-based models are presented as a win–win scenario. It is clear, however, that there are also apparent dangers entailed with trust-based approaches. Especially one model, that of data trusts, may have far-reaching consequences.