ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISSIONERS

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1 ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

2 Terra Incognita Auditing for Privacy Workshop: Chairman s Remarks 2007 International Data Protection and Privacy Commissioner s Conference Montreal, Quebec, Canada Workshop # 3 Audit Wednesday, September 26, :30 4:00 pm ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS Dr. Artemi Rallo Lombarte Director, Spanish Data Protection Agency

3 What is Auditing? Audit vs. Inspection Audit initiated by DPA or data controller proactive overview to establish general compliance, usually results in recommendations Inspection in response to a complaint or DPA concern investigation of a specific area of suspected breach, can result in sanctions Effective enforcement requires both proactive and reactive components In the context of this panel, we ll refer generally to auditing an inclusive idea ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

4 Spanish Auditing Process 20% Preventive Enforcement Systematic audits public and private sectors Results in recommendations, but issue a Resolution too Includes non-audit actions: guidelines, consultations, publicity 80% Reactive Enforcement Law mandates AEPD to resolve every citizen complaint Usually resolved with request for voluntary information submission can search in situ or issue subpoenas fines assessed for violations based on nature of infraction as minor, serious, or very serious as defined by law Inspection by IT experts - submit factual report to Legal Department Legal Department analyzes report, initiates sanction procedures if needed, makes recommendation for Resolution Director approves Resolution; appealable in court ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

5 Collaborative Enforcement: Bilateral Cooperation in the EU 2000 AEPD fines a content provider for posting personal data of police officers on its website No fine to ISP content removed immediately upon injunction 2006 notification that content still exists on a Dutch mirror site Collaboration with NL DPA (CBP) to remove content CBP sent an information request to the Dutch ISP, with attached AEPD Resolution on illegality of data Immediate removal of content by ISP Cooperative strategy and tools Exchange of information on Spanish action and outcomes Investigation of site by CBP, factual (whois) and legal analysis Collaborative development of enforcement strategy Consistent communication of actions and status ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

6 Collaborative Enforcement: Why Synchronized Auditing? Enforcement s goal is to increase compliance Biggest enforcement obstacle is resource limitations Synchronized enforcement can harmonize DP practices Information sharing and cooperation to reduce divergence in MS simplify enforcement, use best practices, more efficient enforcement Unified practices to permit self-regulation like BCR diminish enforcement burdens improve compliance sector-wide Vital to refine approach and pursue joint action ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

7 Collaborative Enforcement: Multilateral Cooperation in the EU Overall positive compliance, with some areas of concern Moving forward: Recommendations to correct gaps in compliance Non-participant data controllers should note findings Analyze and refine methodology for future actions Continue to coordinate joint enforcement with representative organizations like CEA Properly equip DPAs for effective enforcement Improve survey instrument clearer questions, more focused Pursue in-depth follow-up investigations to improve compliance, not just take its temperature ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

8 Collaborative Enforcement: Cooperation with Third Countries Unprecedented enforcement action outside the EU: in situ inspections of data transferred to Colombia Legal basis: model contract clause for international data transfers Where data is transferred internationally, DPA may conduct audits of the importer, using the same techniques and tools that are available for audits of the exporter in the DPA s jurisdiction Telecom company included clause in contract for Colombian tech support outsourcing AEPD awareness that data might be at risk of misuse or vulnerable to security breaches; decision to audit in situ ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

9 Collaborative Enforcement: Cooperation with Third Countries Cooperation and facilitation by exporter (data controller) Coordinated inspections Served as contact point for audits Audited all involved data importers in Colombia 5 days of auditing in Colombia 3 inspectors + Inspection Subdirector Document access and examination in situ checks of technical systems Access to and evaluation of information stored in the system in situ verification of security measures Findings: general compliance with technical and organizational security requirements Importers saw audit as a helpful experience to improve practices ÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

10 Dr. Artemi Rallo Lombarte Director, Spanish Data Protection Agency ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

11 Workshop 3 Panelists Mr. Chris Turner Head of Audit and Remedies, Office of the Information Commissioner, UK Mr. Joel Winston Associate Director of Privacy and Identity Protection Branch, FTC Consumer Protection Bureau, USA Mr. Nicholas Cheung Principal, Assurance Services Development of the Canadian Institute of Chartered Accountants Ms. Yim Chan Global Privacy Executive, IBM and Chief Privacy Officer, IBM Canada ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

12 Data Protection Auditing A UK Perspective Chris Turner Head of Audit & Remedies Information Commissioner s Office ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

13 Background 1998 Data Protection Act Provides a power to audit with consent of the data controller. Mid 2001 Completion of Audit Manual and promotion via our website A major milestone for the Office. Late 2003 new initiative launched to undertake programme of trial audits and consider audit accreditation schemes. Audits conducted by compliance team members. May 2005 permanent Audit Team created as part of a new Regulatory Action Division looking to expand team and increase powers. ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

14 Audit Programme Programme based on: Volunteers Theme Identified Non Compliance / Issues Engagement Invitation / Request Assessment / Remedies Undertaking Make Up Predominantly public authorities, private companies more likely to be as a result of undertakings. ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

15 Audit Methodology Based broadly on the Audit Manual 2/3 man team, compliance background experience Development of key relationships to facilitate cooperation and establish mutual benefits Scoping and planning (background information) Adequacy Audit Policies, Procedures, Guidelines, Training Material Checklist Evaluation Compliance Audit Data Protection System Business (Functional) Processes Computer applications / operations ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

16 Audit Output ICO Methodology Adequacy Audit Summary Report Observations Report (Working document) Compliance Audit On-site Feedback (key findings) Compliance Report (Observations / Evaluation / Recommendations) Follow up ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

17 Challenges No audit without consent Team Experience (Audit / Technical) Questionnaire approach getting the questions right. Availability of adequate background information e.g. process / job descriptions Getting the timetable right! Deep and Narrow v Wide and Shallow Reports & Recommendations Balancing the workload Small team considerations ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

18 Benefits ICO Opportunity to identify / address systemic issues. Provides an alternative to enforcement. Increased ICO understanding of processing. Identifies the need for guidance. Raise the profile of data protection. Organisations Raise data protection awareness at an individual and corporate level. Provides a perspective of the regulator s view Is a catalyst for change. Provides an alternative to enforcement. ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

19 Privacy The USA Model Joel Winston Division of Privacy and Identity Protection September 26, 2007 ÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

20 Meet the FTC U.S. s only general jurisdiction consumer protection agency Mission: promote efficient functioning of the marketplace by protecting consumers from unfair and deceptive practices ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

21 U.S. Legal Framework for Privacy No general privacy law or obligation to have any particular privacy practices Various federal laws and regulations governing specific industries - financial industry - health care industry - credit reporting industry State laws FTC Act unfair or deceptive practices ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

22 U.S. Legal Framework for Data Security No general security law or obligation to have any particular security practices Various federal laws and regulations governing specific industries - financial industry - health care industry - credit reporting industry State laws on data security and breach notification FTC Act unfair or deceptive practices ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

23 FTC Act prohibits unfair or deceptive acts or practices in or affecting commerce deceptive practice one that is likely to mislead reasonable consumers in a material way unfair practice one that causes or is likely to cause substantial consumer injury that is not reasonably avoidable by consumers and is not outweighed by benefits to consumers or competition ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

24 Safeguards Safeguards Rule data security requirements for financial institutions Must have reasonable procedures to safeguard sensitive personal information Flexible and adaptable standards security as a process No specific technical requirements See ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

25 FTC Enforcement Investigations Law enforcement actions - deception cases - Safeguards cases - Fair Credit Reporting Act cases - Gramm-Leach-Bliley Act cases - unfairness cases ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

26 FTC Enforcement Conduct remedies auditing requirements Monetary remedies consumer redress, civil penalties ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

27 Other FTC Efforts Business education Consumer education Rulemaking Legislative assistance See ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

28 Other Government Enforcement Banking agencies (OCC, FDIC, FRB, OTS, NCUA) examination and law enforcement powers State enforcement ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

29 Generally Accepted Privacy Principles A Global Privacy Framework Nicholas F. Cheung, CA, CIPP/C The Canadian Institute of Chartered Accountants ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

30 Why Is the Accounting Profession Involved with Privacy? Privacy is a risk management issue Accountants are trusted business advisors Goes hand in glove with internal control assessments Need for external assurance regarding an organization s privacy practices CAs are recognized for their audit expertise Any audit requires an examination against suitable criteria Standard setting experience CICA sets accounting and assurance standards for businesses, not-for-profit organizations and government ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

31 What are Generally Accepted Privacy Principles (GAPP)? A privacy framework to help both public and private entities develop and assess their privacy program and privacy risk Developed by the CICA and AICPA To create a common North American standard Endorsed and supported by: ISACA Information System and Audit Control Assoc IIA The Institute of Internal Auditors ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

32 Generally Accepted Privacy Principles Management Notice Choice & Consent Collection Use & Retention Access Disclosure to Third Parties Security for Privacy Quality Monitoring & Enforcement ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

33 GAPP Australia Canada PIPEDA EU Data Protection Directive Global Privacy Standard Management Accountability Notification Accountability Notice Openness Identifying Purposes, Openness Choice & Consent Collection Use and Retention Access Disclosure Use and Disclosure Collection, Sensitive Information, Anonymity Identifiers, Use and Disclosure Access and Correction Use and Disclosure, Trans-border Data Flows Consent Limiting Collection Limiting Use, Disclosure, and Retention Individual Access Limiting Use, Disclosure, and Retention Information to be Given to the Data Subject Criteria for Making Data Processing Legitimate, Data Subject s Right to Object Principles Relating to Data Quality, Exemptions and Restrictions Making Data Processing Legitimate, Special Categories of Processing, Principles Relating to Data Quality, Exemptions and Restrictions, The Data Subject s Right to Object The Data Subject s Right of Access to Data Transfer of Personal Data to Third Countries Purposes, Openness Consent Collection Limitation Use, Retention & Disclosure Limitation Access Security Data Security Safeguards Confidentiality and Security of Processing Security Use, Retention & Disclosure Limitation Quality Data Quality Accuracy Principles Relating to Data Quality Accuracy Monitoring & Enforcement (Enforcement by the Office of the Privacy Commissioner) Challenging Compliance ES ET DE LA VIE PRIVÉE E 29 Processing of Personal th Data Judicial Remedies, Liability and Sanctions, Codes of Conduct, Supervisory Authority and Working Party on the Protection of Individuals with Regard to the Compliance th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

34 The Benefits of GAPP Comprehensive Framework of over 60 measurable and relevant criteria Not just a list of principles Objective Developed by the auditing profession to Address international expectations Create a basis for comparability Universally available at no charge Relevant Widespread use and recognition Applicable for evaluating privacy risk enterprise-wide Recognized as suitable criteria for a privacy audit Can also be the basis for an internal assessment ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

35 Ref Example of GAPP Criteria Security for Privacy Criteria Physical Access Controls Physical access is restricted to personal information in any form. Illustrations and Explanations of Criteria Systems and procedures are in place to: Manage logical and physical access to personal information, including hard copy, archival, and backup copies. Log and monitor access to personal information. Prevent the unauthorized or accidental destruction or loss of personal information. Investigate breaches and attempts to gain unauthorized access. Communicate investigation results to appropriate privacy executive. Maintain physical control over the distribution of reports containing personal information. Securely dispose of waste containing ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS confidential information. Additional Considerations Physical safeguards may include the use of: locked file cabinets Card access systems physical keys sign-in logs other techniques to control access to offices, data centers, and other locations in which personal information is processed or stored.

36 External Reports for Privacy Benefits of third-party assurance Independent Objective Trained in audit techniques Why Is This Important Strengthen customer confidence Provide useful reports to internal and external stakeholders Required as part of a contract ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

37 Specified Procedures Engagement What Is It? A special type of engagement where the procedures are agreed upon by the client and the public accountant Accountant provides a report listing any exceptions found Not an audit opinion Limited distribution of report When Would This Be Useful? Organization may not be ready for an audit, but want to provide a third-party report on privacy Could use selected criteria from GAPP More cost effective than an audit ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

38 External Audit What Is It? Similar to auditor s report used for financial statements (GAPP vs. GAAP) Provides reasonable assurance Unlimited distribution of report When Would This Be Useful? Provide assurance to Customers and prospective customers Employees / Board of Directors Regulatory and government bodies To obtain assurance over privacy practices of a 3rdparty vendor (outsourcing contract requirement) ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

39 Other Uses of GAPP Privacy Risk Assessment Diagnose new or current privacy program Cannot be relied upon for legal compliance Benchmarking Against GAPP criteria or compare results against prior GAPP assessments Can be used in a local, national or international context Privacy Notice Development ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

40 Contact Info Nicholas F. Cheung, CA, CIPP/C Principal, Assurance Services Development CICA (416) ES ET DE LA VIE PRIVÉE E 29 th INTERNATIONAL CONFERENCE OF DATA PROTECTION AND PRIVACY COMMISS

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