Control design for data protection and privacy version 1 release 2

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Control design for data protection and privacy version 1 release 2

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Control design for data protection and privacy version 1 release 2

  1. 1. Mark E.S. Bernard, CISSP, CISM, CRISC, CISA, CGEIT, CNASkype; Mark_E_S_BernardTwitter; @MESB_TechSecureLinkedIn; http://ca.linkedin.com/in/markesbernard*** THIS DOCUMENT IS CLASSIFIED FOR PUBLIC ACCESS ***
  2. 2. *** THIS DOCUMENT IS CLASSIFIED FOR PUBLIC ACCESS ***1. Accountability - An organization is responsible for personal information under its control and shalldesignate an individual or individuals who are accountable for the organizations compliance with thefollowing principles.2. Identifying Purposes - The purposes for which personal information is collected shall be identified by theorganization at or before the time the information is collected.3. Consent - The knowledge and consent of the individual are required for the collection, use, or disclosure ofpersonal information, except where inappropriate.4. Limiting Collection - The collection of personal information shall be limited to that which is necessary forthe purposes identified by the organization. Information shall be collected by fair and lawful means.5. Limiting Use, Disclosure, and Retention - Personal information shall not be used or disclosed for purposesother 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.
  3. 3. *** THIS DOCUMENT IS CLASSIFIED FOR PUBLIC ACCESS ***6. Accuracy - Personal information shall be as accurate, complete, and up-to-date as is necessary for thepurposes for which it is to be used.7. Safeguards - Personal information shall be protected by security safeguards appropriate to the sensitivityof the information.8. Openness - An organization shall make readily available to individuals specific information about itspolicies and practices relating to the management of personal information.9. Individual Access - Upon request, an individual shall be informed of the existence, use, and disclosure ofhis or her personal information and shall be given access to that information. An individual shall be able tochallenge the accuracy and completeness of the information and have it amended as appropriate.10. Challenging - Compliance An individual shall be able to address a challenge concerning compliance withthe above principles to the designated individual or individuals accountable for the organizationscompliance.
  4. 4. *** THIS DOCUMENT IS CLASSIFIED FOR PUBLIC ACCESS ***The Assets at riskpotentially leading toa breach of DataProtection & loss ofConfidentialityinclude ‘People’,‘Information’,‘Property /Facilities’,’Software /Systems’,‘Hardware’,‘Telecommunications’.
  5. 5. *** THIS DOCUMENT IS CLASSIFIED FOR PUBLIC ACCESS ***The Assets at riskpotentially leading toa breach of DataProtection & loss ofData Integrity include‘People’,‘Information’,‘Property /Facilities’,’Software /Systems’,‘Hardware’,‘Telecommunications’.
  6. 6. *** THIS DOCUMENT IS CLASSIFIED FOR PUBLIC ACCESS ***The Assets at riskpotentially leading toa breach of DataProtection & loss ofAvailability include‘People’,‘Information’,‘Property /Facilities’,’Software /Systems’,‘Hardware’,‘Telecommunications’.
  7. 7. *** THIS DOCUMENT IS CLASSIFIED FOR PUBLIC ACCESS ***During the executionof a standard processor operationprocedure risks areexposed and with theproper control designmitigated toacceptable levelswithin the riskappetite. Identity &Access Managementis one example of acrucial process.
  8. 8. *** THIS DOCUMENT IS CLASSIFIED FOR PUBLIC ACCESS ***To achieve theeffective and efficientintegration betweenQuality Management& Risk Managementwhile addressingCompliance withLegal Obligationsduring the DesignControl process it willbe necessary toassess risk identifythreats and matchingvulnerabilities.
  9. 9. *** THIS DOCUMENT IS CLASSIFIED FOR PUBLIC ACCESS ***It is necessary to define thetesting scenarios to helpframe the evaluated threatsand vulnerabilities ensuringthe Control Design isachieving its intendedpurpose. Reiterating themitigation control andmapping it to the testingscenario is an important stepin validation controls andestablishing a tractabilitymatrix for the ControlDesign.
  10. 10. *** THIS DOCUMENT IS CLASSIFIED FOR PUBLIC ACCESS ***Leveraging proven bestpractices for Governance likethe RACI Chart is extremelyuseful to establishing who isaccountable, responsible orwho needs to be consultedad informed about theControl Design.
  11. 11. *** THIS DOCUMENT IS CLASSIFIED FOR PUBLIC ACCESS ***Taking the Control Design forData Protection and Privacyone step further byestablishing andcommunicating the securitycontrols to those on theRACI Chart that must beinformed is essential toelevating the Control designeffectiveness. Additionaltesting can be added to thetesting scenarios thatencompassed these securitytools and techniques.
  12. 12. *** THIS DOCUMENT IS CLASSIFIED FOR PUBLIC ACCESS ***A feedback loop canensure continuousimprovement as part ofthe Quality Managementintegration. The fishbonechart is extremely usefulto communicate, trackand update the essentialControl Design. This chartmay also facilitate Root-Cause Analysis, IncidentManagement andProblem Management.
  13. 13. *** THIS DOCUMENT IS CLASSIFIED FOR PUBLIC ACCESS ***Mark E.S. Bernard, CISSP, CISM, CRISC, CISA, CGEIT, CNASkype; Mark_E_S_BernardTwitter; @MESB_TechSecureLinkedIn; http://ca.linkedin.com/in/markesbernard

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