SecTor 2009 October 6, Tracy Ann Kosa
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1 SecTor 2009 October 6, 2009 Tracy Ann Kosa
2 Privacy versus Security Un enforced Privacy Privacy Requirements that Work People Process Technology
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4 Territorial Privacy Setting boundaries on intrusion into an explicit space or location Physical Privacy Defining intimate acts, behaviour or body parts Informational Privacy Legislatively defined
5 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) Any information concerning the personal or material circumstances of an identified or identifiable person "personal information" (PI) means information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization
6 In computers, security refers to ensuring the: Confidentiality Integrity Availability of the data and systems that process data. This definition transforms security from a value into a technical objective
7 Without technology, privacy is a part of physical reality I walked down the street, if no one else was there, I could assume I was unobserved Video-surveillance cameras = a hidden camera can observe me even when I think I'm alone Technology evolves, digital cameras = cheap and compact to store the video forever, machines can read it without human intervention
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9 Technology amplifies the possibility of surveillance Technology enables the misuse of personal information
10 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)
11 Privacy and security are on a collision course. Your desire to be kept safe will soon collide with your wish to be left alone.
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18 Security techniques can help protect personal information Security techniques can affect the privacy of a data subject
19 Goal: increase the apprehension rate for known criminals Super Bowl XXXV Face recognition software was used to scan all people entering the stadium, looking for known criminals, and possible matches were sent to a police control room Privacy objections: it was done without the knowledge or consent of the people being scanned Security impact: the existence of such knowledge or consent would have changed the security function of the system from detection to deterrence
20 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
21 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
22 BLM LM BM Clark Chinese RBAC WAM DOOM MOON Protection of confidentiality of personal data Protection of integrity of personal data Necessity of personal data processing Purpose binding of access to data Ability to provide pseudonymity or anonymity (yes) (yes) No Yes (yes) Yes Yes Yes (yes) No No (yes) Yes (yes) Yes Yes Yes No No No No (yes) No (yes) Yes (yes) No No No No No No No No No No (yes) Yes (yes) (yes) Yes Yes Yes No Yes
23 Security Protect confidentiality, integrity and availability of PI Protect data subjects as system users Privacy Protect PI from unauthorized collection, use and disclosure (including theft) Protect PI from accidental disclosure Protect PI from unlawful destruction Protect PI from alteration Ensure availability of PI Enable anonymization Enable pseudonymization Support informational self-determination
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25 Security Assessments Security Specialist Business Program Management Application Developer Database Administrator Service Providers Auditors Privacy Assessments Privacy Specialist Business Program Management Application Developer Database Administrator Service Providers Auditors Records Manager Legal Counsel
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27 Private sector companies are legislated by the Personal Information Protection and Electronic Documents Act (PIPEDA) PIPEDA is regulated by the Office of the Privacy Commissioner of Canada (OPC) Complaint-based Right of audit
28 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. Complaint-based enforcement rate: 2%
29 The purposes for which personal information is collected shall be identified by the organization at or before the time the information is collected. Complaint-based enforcement rate: 3%
30 The knowledge and consent of the individual are required for the use, or disclosure of personal information, except where inappropriate. Complaint-based enforcement rate: 41%
31 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. Complaint-based enforcement rate: 9%
32 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. Complaint-based enforcement rate: 10%
33 Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. Complaint-based enforcement rate: 2%
34 Personal information shall be protected by security safeguards appropriate to the sensitivity of the information. Complaint-based enforcement rate: 11%
35 An organization shall make readily available to individuals specific information about its policies and practices relating to the management of personal information. Complaint-based enforcement rate: 3%
36 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. Complaint-based enforcement rate: 19%
37 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. Complaint-based enforcement rate: 0%
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39 Privacy legislation plays an important role in designing, implementing, and using privacyenhancing systems (Fisher-Hubner 2001)
40 Privacy design requirements are: A group of documented needs that enable a system (people, process and technology) to protect the informational privacy of the data subject Used as a basis for: Building privacy compliance from the concept phase Limiting resource costs associated with retrofitting for compliance purposes Enhancing the privacy risk posture of an organization
41 Consent Individual Access Safeguards
42 Consent
43 Train all staff on how to collect consent properly
44 Develop consent management program: Voluntary nature of consent Ability to withdraw / alter Allow restriction and / or limitation on disclosure Document any authority / rationale for secondary use
45 Track and implement consent preferences at the data element level Display consent statements prior to collection Record terms of consent and timestamp Issue new consent when notice of collection changes Allow revocation of consent preferences (any/all) Record terms of revocation and timestamps Serve explanatory notices of the ramifications of consent revocation Complete purging of PI as requested
46 Individual Access
47 Train any staff with direct data subject contact procedures for managing requests for access
48 Glossary of terms for all data fields Policies and procedures should be in place to support requests for access Different formats for release of data Requests for review / correction Validation of the data subject Written communication with the data subject on outcome / recourse
49 Provide PI at the least possible cost to the data subject Enable data subject direct access to their PI Amend or annotate any PI subject to disagreement regarding accuracy (including logs) Notifications to any parties who received incorrect PI within the last year Enable access to PI in multiple formats 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) Segregate PI in records by data subjects
50 Safeguards
51 All staff should be provided with privacy and security training
52 Document policies and procedures to safeguard the confidentiality, integrity and availability of PI Avoid archiving of hard copy PI Conducting Threat Risk Assessments Document policies and procedures on incident management reporting and investigation, including notification of data subjects (where necessary and /or appropriate) Implement procedures to revoke access privileges (including tokens) from staff where necessary (e.g. termination, transfer, promotion) Contracts with third parties should specify privacy and security requirements and expectations, and include audit processes Physical security measures should be in place to protect electronic and hard-copy PI (e.g. locked doors and server rooms) Disaster recovery and business continuity plans should be in place for all mission critical business processes
53 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 information classification requirements
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3. Consent for the Collection, Use or Disclosure of Personal Information
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