Bugs, Bugs, Bugs

It’s a familiar scenario. You need to print something in a hurry, but the printer isn’t working – and neither is the ticket machine. And the train is has come to a halt somewhere along the tracks, probably due to a software bug. Unfortunately, we still haven’t found a way to get rid of these critters once and for all. In 1977, Caspers Jones estimated that for every 1,000 lines of code, one can expect a specific number of bugs that cause incorrect results or unexpected behaviors in computer programs. So from a compliance point of view, bugs are always to be expected. What does this mean?

Jones’s calculations are less than ideal. For larger programs, one can expect between 4 and 100 errors per KLOC. The Boeing 787 Dreamliner (Mark Wagner, Guy Norris) has around 6,500 KLOC, giving a total of 26,000 to 650,000 errors. It’s surprising that we don’t encounter more software problems. One reason why is that not all bugs occur with equal frequency. Systems that have been used heavily for a long time typically contain fewer frequently occurring bugs than new systems. The fact remains, however, that even in legacy systems, bugs cannot generally be ruled out. From a compliance point of view, one shouldn’t think of something as being “bug-free”, but rather take a risk-based approach in order to reduce the frequency and impact of the bugs.

 

Data Protection Act

The Swiss Data Protection Act underwent a complete revision in 2020, and its new version took effect on September 1, 2023, along with the new Data Protection Ordinance (DPO). The revision itself is complete, but its practical application continues to evolve. The topic of AI is particularly relevant: On May 8, 2025, the FDPIC confirmed that the DPA is technology-neutral and applies directly to all AI applications. In practice, this means, among other things, that users must know whether they are interacting with AI (transparency requirement, Art. 19), and that a data protection impact assessment is mandatory in cases of high risk—such as profiling or facial recognition (Art. 22). The Federal Office of Justice (FOJ) is drafting a consultation document on AI regulation to be completed by the end of 2026. With this, Switzerland will implement the Council of Europe's AI Convention.

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