Protecting Your Private Parts
Tracy Ann Kosa
Protecting Your Private PartsTASK Meeting, 27 February 2008
Objectives Terminology
Privacy & Security
Privacy Design Requirements
Protecting Your Private PartsTASK Meeting, 27 February 2008
Types of Privacy 3 Dimensions of Privacy:
– Territorial– Physical– Informational
Protecting Your Private PartsTASK Meeting, 27 February 2008
Informational Privacy “Privacy is the claim of individuals,
groups and institutions to determine for themselves, when, how and to what extent information about them is communicated to others”
(Westin 1967)
Protecting Your Private PartsTASK Meeting, 27 February 2008
Personal Information Any information concerning the
personal or material circumstances of an identified or identifiable person
Protecting Your Private PartsTASK Meeting, 27 February 2008
The Case for Privacy Technology amplifies the possibility of
surveillance and misuse of PI “Privacy legislation plays an important
role in designing, implementing, and using privacy-enhancing systems”
(Fisher-Hubner 2001)
Protecting Your Private PartsTASK Meeting, 27 February 2008
Security & Privacy"I think of privacy as the use of the data by
somebody you gave it to, and security as the theft of the data or the interception of the data by the unknown third party. If I buy a
ticket from Travelocity, what Travelocity does with my data is a privacy issue. If
somebody hacks into Travelocity and steals that data, that’s a security issue.”
(Cate 2008)
Protecting Your Private PartsTASK Meeting, 27 February 2008
Security Impacts PrivacySecurity
techniques can help protect
personal information
Security techniques can
affect the privacy of a data subject
Protecting Your Private PartsTASK Meeting, 27 February 2008
Security Models Bell LaPadula Lattice Model of Information Flow Biba Model Clark Wilson Model Chinese Wall Model RBAC Model Task Based Authorization Model Object-Oriented Security Model (Fischer-Hubner, 2001)
Protecting Your Private PartsTASK Meeting, 27 February 2008
Protecting Your Private PartsTASK Meeting, 27 February 2008
Security Criteria Trusted Computer System Evaluation
Criteria (TCSEC), European IT Security Evaluation Criteria (ITSEC), Canadian Trusted Computer Evaluation Criteria (CTCPEC)
Focus on protecting the system and the organization, not the users and the data subjects
Protecting Your Private PartsTASK Meeting, 27 February 2008
Privacy Criteriafor Security
Protecting the confidentiality, integrity and availability of PI– Protect PI from unauthorized collection, use and
disclosure, including theft– Protect PI from accidental or unlawful destruction– Protect PI from alteration– Ensure availability of PI
Protect data subjects (as system users)– Enable anonymous/pseudonymous use– Support informational self-determination
Protecting Your Private PartsTASK Meeting, 27 February 2008
Example Access control mechanisms to protect
confidentiality and integrity of PI– Enforcing purpose binding– Separation of duties based on roles– Well-formed transactions
Protecting Your Private PartsTASK Meeting, 27 February 2008
Expectations
Protecting Your Private PartsTASK Meeting, 27 February 2008
Reality
Protecting Your Private PartsTASK Meeting, 27 February 2008
Privacy Design Requirements
Timing– Day 1, or when a project feasibility
activities are completed and approved– Some random point during a project– After implementation– 5 years after implementation
Protecting Your Private PartsTASK Meeting, 27 February 2008
Privacy Design Requirements
Process– Identify a benchmark– Read it (really)– Create the requirement– Classify it (people, process, technology)
Protecting Your Private PartsTASK Meeting, 27 February 2008
Privacy Design Requirements
The Case Study– No specific project, creating static
requirements for the enterprise– Using the privacy principles (found in the
private sector privacy legislation, PIPEDA) as a benchmark
Protecting Your Private PartsTASK Meeting, 27 February 2008
CSA1: Accountability An organization is responsible for
personal information under its control and shall designate an individual or individuals who are accountable for the organization's compliance with the following principles.
Protecting Your Private PartsTASK Meeting, 27 February 2008
Privacy Design Requirements
IT systems should: – Be capable of providing access to PI on request
and have the capacity to record who has/had access to the PI and for what purpose
– Be transparent and documented so that data subjects can be informed about how their PI is collected, used and disclosed
– Include consideration of privacy in change management practices
– Retain a history of corrective transactions relative to each data subject
Protecting Your Private PartsTASK Meeting, 27 February 2008
CSA2: Identifying Purpose The purposes for which personal
information is collected shall be identified by the organization at or before the time the information is collected.
Protecting Your Private PartsTASK Meeting, 27 February 2008
Privacy Design Requirements
IT systems should:– Record the date, time and retention period of PI
when it is collected, compiled or obtained– Limit the use of free text areas to collect PI– Limit the ability of using already collected PI for a
new purpose– Include monitoring and enforcement
mechanisms to limit the collection of PI– Possess audit trail functionality and transaction
validation– Separate PI in databases so that queries do not
retrieve data recorded for a different purpose
Protecting Your Private PartsTASK Meeting, 27 February 2008
CSA3: Consent The knowledge and consent of the
individual are required for the use, or disclosure of personal information, except where inappropriate.
Protecting Your Private PartsTASK Meeting, 27 February 2008
Privacy Design Requirements
IT systems should:– manage a data subject’s consent preferences– serve a consent statement to the data subject prior to
collection– record the terms of consent and timestamp when a data
subject agrees– support serving new consent notices to data subjects’
when the notice of collection is changed– allow data subjects to revoke consent for collection and /
or use– timestamp revocations of consent from data subjects– serve explanatory notices of the ramifications of consent
revocation before purging PI
Protecting Your Private PartsTASK Meeting, 27 February 2008
CSA4: Limiting Collection The collection of personal information
shall be limited to that which is necessary for the purposes identified by the organization. Information shall be collected by fair and lawful means.
Protecting Your Private PartsTASK Meeting, 27 February 2008
Technology Requirements
IT systems should:– Identify and document all PI data elements required to
provide a service (including physical location)– Restrict use of PI beyond the initial purpose for collection– Record logging information for each collection, use and
disclosure of PI– Document the source for all PI collected– Anonymize PI when used for planning, forecasting or
evaluation purposes– Limit access to PI to authorized and accountable
personnel
Protecting Your Private PartsTASK Meeting, 27 February 2008
CSA5: Limiting Use, Disclosure & Retention
Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
Protecting Your Private PartsTASK Meeting, 27 February 2008
Technology Requirements
IT systems should:– Enforce maximum retention periods for PI– Apply retention periods to backups and archives– Anonymize PI no longer necessary for service delivery– Utilize secure electronic disposal methods– Apply safeguards to ensure that PI cannot be used or disclosed
for unauthorized purposes– Support linkage functionality when a data subject’s PI and
documented circumstances where use or disclosure has occurred outside the notice of collection
– Not allow PI to be cached locally– Delete all PI prior to being decommissioned– Prevent linkages of PI across multiple databases outside of initial
service delivery requirements– Where necessary, utilize only internal identifiers (not SIN or DL)
Protecting Your Private PartsTASK Meeting, 27 February 2008
CSA6: Accuracy Personal information shall be as
accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
Protecting Your Private PartsTASK Meeting, 27 February 2008
Technology Requirements
IT systems should:– Be audited regularly to ensure controls are in place and working– Ensure that PI can be easily access and corrected upon request– Have the ability to identify when PI has been changed or modified, by
whom, and for what reason– Designed so that historical PI and any inaccurate PI is not routinely
disclosed to persons other than the data subject– Designed so that anyone who has accessed inaccurate or historical PI
that has changed is informed of these changes in a timely manner– Include validity checks at the point of data entry– Specify the date the data subject’s PI was collected and / or updated– Specify when and how data subject’s PI is to be updated and the source
for the update– Specify how to verify the accuracy and completeness of information
disclosed to or received from a third party– Include record keeping for each data subject’s request for a review for
accuracy, corrections and / or decisions not to correct
Protecting Your Private PartsTASK Meeting, 27 February 2008
CSA7: Safeguards Personal information shall be
protected by security safeguards appropriate to the sensitivity of the information.
Protecting Your Private PartsTASK Meeting, 27 February 2008
Technology Requirements
IT systems should:– Support the immediate revocation of access
privileges to PI– Have controls in place over the process to grant
authorization to add, change or delete information from records
– Be designed so that access and changes to PI can be audited by date and by user identification
– Labelled, transmit and store PI in accordance with classification
Protecting Your Private PartsTASK Meeting, 27 February 2008
CSA8: Openness An organization shall make readily
available to individuals specific information about its policies and practices relating to the management of personal information.
Protecting Your Private PartsTASK Meeting, 27 February 2008
Technology Requirements
IT systems should: – Clearly identify transaction types to data
subjects and system users– Clearly identify data flows to the data
subject and system users– Clearly identify system linkages to data
subjects and system users
Protecting Your Private PartsTASK Meeting, 27 February 2008
CSA9: Individual Access Upon request, an individual shall be
informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Protecting Your Private PartsTASK Meeting, 27 February 2008
Technology Requirements
IT systems should:– Be able to provide a data subject with access to and copies of their PI on
a routine basis (as permitted by law)– Be designed to provide PI at the least cost possible to the data subject– Be able to amend and / or annotate any PI subject to disagreement
regarding accuracy– Have the capacity to notify third parties to whom incorrect PI has been
disclosed within the year preceding the correction of the changes to information or the letter of disagreement
– Provide PI in multiple formats (electronic, audio)– Support multiple format queries for PI (e.g. one query should return all PI
held about a given data subject across different application where necessary for service delivery)
– Support severing of PI of other data subject’s contained in records provided in response to another data subject’s request for access
Protecting Your Private PartsTASK Meeting, 27 February 2008
CSA10: Challenging Compliance
An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the organization's compliance.
Protecting Your Private PartsTASK Meeting, 27 February 2008
Technology Requirements
IT systems should:– Record complaint related information, including the date
on which complaints are received– Record all complaint outcomes, the date when made and
the parties involved and make the decisions available (where relevant to ensure consistency)
– Trace all transactions made on a data subject's record, including who made changes to a record, date of change, and purposes for change
– Log transaction history for audit purposes, to respond to privacy complaints and / or to support requests for information from a data subject
Protecting Your Private PartsTASK Meeting, 27 February 2008
Privacy & Security