1. Frank Dawson/Nokia, Director information privacy compliance
Ecole Polytech Nice – Sophia Antipolis
2015-01-23
Privacy Engineering &
Privacy Assurance
Lecture
© Nokia 2015 PE_PA-Lecture-Ecole_Polytechnic_Nice_SA-20150123 Author :Frank Dawson
1

2. Privacy Engineering &Assurance
2
1. WHAT – Information Privacy
− Terminology
− Roles within the Privacy Framework
− Privacy Principles
− Essence of privacy
− Privacy data lifecycle
− Personally Identifiable Information
and Identifiability
2. HOW – Compliance or Accountability
− Elements of an ACCOUNTABLE
privacy program
− Privacy activities across the product
life cycle
− Privacy program roles &
responsibilies
3. HOW - Privacy Engineering & Assurance
simplified
− Applying Privacy Engineering
− Privacy Engineering steps
− Privacy Assurance steps
− Design activities across the product
life cycle
− Privacy impact assessment
− Privacy risk management
− Assessing privacy maturity
− Privacy related business processes
4. Use case
− Initial description
− Assessment planning
− Kickoff meeting
− Use case & DFD
− Data inventory & classification
− Threat analysis
− Security considerations
− Privacy Policy template
− Assessment findings
− Final assessment review

3. Information privacy
The right of an individual to control the processing of their
personal data such that there is:
No hidden, unwanted, uncontrolled,
excessive or insecure
Collection, processing and disclosure of
consumer’s personal data
3

4. EU GDPR and ISO 29100
• TheEU data protection regulations will soon be based on the
proposed General Data Protection Regulation
• Potential harmonizing DP effect across EU businesses
• ISO 29100 defines a Privacy Framework that reflects many of
the proposed components of the GDPR
• The PDF of the standard is freely available here
• Privacy Framework includes:
• Terminology
• Roles and interactions
• Recognizing PII
• Privacy safeguarding requirements
• Privacy policy
• Privacy controls
• Privacy principles
4

5. Terminology (29100 §2)
• Identifiability - condition which
results in a PII principal being
identified, directly or indirectly,
on the basis of a given set of PII
• Personally Identifiable
Information (PII) - any
information that (a) can be used
to identify the PII principal to
whom such information relates,
or (b) is or might be directly or
indirectly linked to a PII principal
• PII Controller - privacy
stakeholder (or privacy
stakeholders) that determines
the purposes and means for
processing personally identifiable
information (PII) other than
natural persons who use data for
personal purposes
• PII Principal - natural person to
whom the personally identifiable
information (PII) relates
• PII Processor - privacy stakeholder
that processes personally
identifiable information (PII) on
behalf of and in accordance with
the instructions of a PII controller
• Privacy Breach - situation where PII
is processed in violation of one or
more relevant privacy safeguarding
requirements
• Privacy Safeguarding
Requirements - set of
requirements an organization has
to take into account when
processing personally identifiable
information (PII) with respect to the
privacy protection of PII
5

6. Roles within the privacy framework
• DPA, Data Privacy Authority,
Information Privacy
Commissioner, etc is the
independent legal authority for
administering privacy rules within
a country
• The consumer is the PII Principal
• The PII Controller is entity that
determines purposes and means
of processing consumer’s
personal data and is
RESPONSIBLE for data
processing of data subject’s PII
• The PII Processor performs
information processing on behalf
of the Data Controller
Data Protection
Authority (DPA)
PII
Principal
PII
Processor
PII
Controller
Sometimes a reference is also
made to a Third Party, which can
be viewed as outside this privacy
framework, but the
responsibility of the Data
Controller.
6

7. Privacy Principles (ISO 29100 §5)
# Principle Description
1 Consent and choice PII Principal has choice on and has Opt-In to PII processing
2 Purpose legitimacy and specification Processing complies with laws, giving notice before
processing
3 Collection limitation Within laws and necessary for specified purposes
4 Data minimization Minimize the processing of PII
5 Use, retention and disclosure limitation Also applies to limitation on cross-border transfers
6 Accuracy and quality Measure to assure validity and correctness of PII
processing
7 Openness, transparency and notice Clear, complete and accessible information on PII
processing
8 Individual participation and access PII Principal access to review their PII and correct
inaccuracies
9 Accountability Demonstrate care in duty toward PII Principal for PII
stewardship
10 Information security Protecting PII under its authority with appropriate controls
11 Privacy compliance Verifying and demonstrating adherence to laws with
internal or 3rd party audits
7

8. Essence of privacy
Privacy emerges from personally identifiable data
Personal data or information
• Any information relating to an identified or identifiable
natural person, an individual
+
Identifiability
• (Nymity) The measure of the degree that personal data can
be associated with an individual
8

9. Privacy data lifecycle
• Also called the Consumer Data
Lifecycle , it is a fundamental
component of the privacy
knowledge base
• Define the actions related to
personal data within the privacy
framework
• When analyzing the data flow in
your specifications, you should
also consider the complete
lifecycle for the associated PII
• Within the EU, collection, itself is
considered to be an act of
processing !
Deletion
Storage
Processing
Transfer
Collection
x
9

10. Personal data/information
• Relates to information about a
natural person
• When the data can be associated
with an individual, it is referred to as
Personally Identifiable Information
(PII)
• Criteria for linkability of data to an
individual is a hot-topic within the
privacy community
• Sensitive PII must be treated
specially
• Generally, if PII is of a racial,
religious, political, sexual
orientation, medical nature, it is
characterized as Sensitive; but
other categories should also be
consisted
• Also commonly referred to as
Personal Data
Basic data (E.G. first
name, last name, mobile
number)
Address data (E.G. postal
code, email address)
Restricted categories of
data (E.G. racial or ethnic
origin, religion, trade
union membership – if
allowed by applicable law)
Social networking related
data (E.G.. metadata of
pictures uploaded, site
activity information)
Location data (E.G. GPS
coordinates or mobile
network base station ID)
Identifiers (E.G. IMEI,
device identifiers, IP-
address)
System data is
information about how
individual users are using
the system (E.G. log files)
Monetary data
transactions (E.G. credit
card number, account
information)
These are some of the
categories of personal
data to consider when
identifying the PII in your
particular project
10

11. Privacy Engineering &Assurance
11
1. WHAT – Information Privacy
− Terminology
− Roles within the Privacy Framework
− Privacy Principles
− Essence of privacy
− Privacy data lifecycle
− Personally Identifiable Information
and Identifiability
2. HOW – Compliance or Accountability
− Elements of an ACCOUNTABLE
privacy program
− Privacy activities across the product
life cycle
− Privacy program roles &
responsibilies
3. HOW - Privacy Engineering & Assurance
simplified
− Applying Privacy Engineering
− Privacy Engineering steps
− Privacy Assurance steps
− Design activities across the product
life cycle
− Privacy impact assessment
− Privacy risk management
− Assessing privacy maturity
− Privacy related business processes
4. Use case
− Initial description
− Assessment planning
− Kickoff meeting
− Use case & DFD
− Data inventory & classification
− Threat analysis
− Security considerations
− Privacy Policy template
− Assessment findings
− Final assessment review

12. Compliance orAccountability
• Goal of being privacy compliance may not be sufficient for
avoiding regulatory actions against your company
• Data protection authorities (DPA) now expect
organizations to demonstrate their good intentions
• Accountability has roots in 1980 OECD privacy guidelines
• Accountability framework builds trust between DPA and
organizations for the handling of personal data
• Accountability means being able to show how your
company has holistically integrated privacy best practices
• Centre for Information & Policy Leadership (CIPL) has
defined a global DPA endorsed approach to Accountability
Data Protection Accountability: The Essential Elements
12

13. Elements of anAccountable privacy program
1. Executive accountability and oversight
Internal senior executive oversight and responsibility for data privacy and data protection
2. Policies and processes to implement them
Binding and enforceable written policies and procedures that reflect applicable laws, regulations and industry
standards, including procedures to put those policies into effect
3. Staffing and delegation
Allocation of resources to ensure that the organization's privacy program is appropriately staffed by
adequately trained personnel
4. Education and awareness
Existence of up-to-date education and awareness programs to keep employees and on-site contractors
aware of data protection obligations
5. Risk assessment and mitigation
Ongoing risk assessment and mitigation planning for new products, services, technologies and business
models.
 Periodic Program risk assessment to review the totality of the accountability program
6. Event management and complaint handling
Procedures for responding to inquiries, complaints and data protection breaches
7. Internal enforcement
Internal enforcement of the organization's policies and discipline for non-compliance
8. Redress
Provision of remedies for those whose privacy has been put risk
Not just compliant but accountable
13

14. Privacy activities across the product life cycle
14

15. Privacy program roles & responsibilities
Executive privacy owner
• The senior executive with oversight and responsibility for data privacy
and data protection in the organization
Chief privacy officer
• The senior manager with responsibility for the implementation and
operation of the privacy program in the organization
Privacy officer
• The privacy professional responsible for implementation and
operation of the privacy program within an organizational unit
Privacy champ
• The program or product member with sufficient privacy competence
to be responsible for transposing privacy requirements into product
requirements
Data Protection Officer
• A privacy professional required by some organizational entities with
reporting accountability to the local Data Protection Authority
15
These are minimal privacy program roles

16. Privacy Engineering &Assurance
16
1. WHAT – Information Privacy
− Terminology
− Roles within the Privacy Framework
− Privacy Principles
− Essence of privacy
− Privacy data lifecycle
− Personally Identifiable Information
and Identifiability
2. HOW – Compliance or Accountability
− Elements of an ACCOUNTABLE
privacy program
− Privacy activities across the product
life cycle
− Privacy program roles &
responsibilies
3. HOW - Privacy Engineering & Assurance
simplified
− Applying Privacy Engineering
− Privacy Engineering steps
− Privacy Assurance steps
− Design activities across the product
life cycle
− Privacy impact assessment
− Privacy risk management
− Assessing privacy maturity
− Privacy related business processes
4. Use case
− Initial description
− Assessment planning
− Kickoff meeting
− Use case & DFD
− Data inventory & classification
− Threat analysis
− Security considerations
− Privacy Policy template
− Assessment findings
− Final assessment review

17. Privacy Engineering &Assurance simplified
Principles,
Policies,
Requirements,
Procedures,
Guidelines,
Patterns
Design, Implement, Test
Map privacy requirements into product
features
Select guidelines, patterns
Review
Against requirements
Can be standalone
Release Assessment
Sign-off
Evidence
Evidence
Evidence
Privacy Engineering
Privacy Assurance
Privacy
Knowledge
Base
Planning & Concepting
Threat Assessment and Mitigation
Privacy requirements identification
17

18. Applying Privacy Engineering
Principles
Requirements
Threats
Controls
Residual
Risk
Privacy Principles
Privacy Requirements &
Guidelines
Privacy & Security Threats &
Vulnerabilities
Privacy & Security
Safeguards
Business Acceptable
Risk
18

19. Privacy Engineering steps
• Define the product context
− Define product in terms of main
functions, assets, stakeholders,
business model, sales estimates,
deployment target countries,
release schedule(s), strategic
importance, risk summary
• Document the data flows
and classify the data
− Inventory of all the personal data
& data clusters
− Classification of each data
element
− User story/epic based diagram
of the flow of data through
product components,
interactors
• Analyze the threats and
risks
− Identification of applicable
privacy principles and underlying
requirements
− Definie inherent threats to key
privacy & security principles
− Analysis of attack surface and
minimization
− Identification of root cause or
vulnerability
• Mitigation
− Selection of privacy & security
safeguarding controls
− Identification of key test causes
and test tools to verify control
fidelity
− Identification of residual risk
Implementing Privacy by Design
19

20. Privacy Assurance steps
• Purpose of assurance is to verify that Privacy Engineering
activities have been implemented as agreed, operational, as well
as any required staffing is in place
• Kick-off the assessment process with Privacy Officer early to
understand what will be needed for final sign-off
• Privacy & security assessment is based on a thorough
assessment of the Product Team evidence that Privacy
Engineering activities has been implemented and is operational
• Final sign-off recommendation is made by Privacy Officer with
approval by Product Management & Chief Privacy Officer
• Escallation process may be needed to address disagreements
over findings between Privacy Officer and Product Management
• Non-compliance with privacy regulations SHOULD NOT be
approved
A final assessment of all product or service that
have a privacy impact is a necessity
20

21. Threat model
• Threats exploit Vulnerabilities and damage Assets
• Controls mitigate Vulnerabilities and therefore might
mitigate Threats
• Attacks manifest Threats
Asset 1
Threat
Vulnerability 1
Vulnerability 2
Control
Control
Control
Asset 2
damages
damages
exploits
exploits
mitigates
mitigates
mitigates
mitigates
mitigates
mitigates
21

22. What is threat analysis
• Threat analysis is about understanding privacy threats to a system, determining
harm from those threats and establishing appropriate migitations (privacy controls
or safeguards) against those harms
• Analyzes threats to underlying Privacy Principles at each stage of the Privacy Data
Lifecycle
• Analysis results facilitate selection of mitigation Privacy Safeguards/Controls
Why follow this practice?
• A structured approach better ensures PbD than an ad hoc approach
• Threat analysis allows development teams to effectively find potential privacy
design issues. Mitigation of privacy issues is less expensive when performed during
design
• By knowing the threats, privacy testing efforts can be focused more effectively
• This is a prerequisite to conducting a Risk Analysis to mitigate associated harm
22

23. Threats come with data – DFD can identify them
• Therefore we model the data using a data flow diagram
(DFD)
• Scope is the processes (your code), all neighbouring actors,
data stores and the trust boundaries between them
Data store
External
interactor
Process
External
interactor
Process
Data flow
External
interactor
Trust boundary
References: Open Web
Application Security Project,
Microsoft TMA
Trust boundary
23

24. Threat analysis modeling
1. Getting ready
− Product description, data inventory, data flow diagram
2. Identify assets
− Digital, physical, reputational, operational
3. Identify entry points
− Entry or exit through a trust boundary in DFD
4. Identify vulnerabilities
− A weakness or failing
5. Define attacker types
− Threats exploit vulnerabilities, attack manifests a threat
6. Define controls
− A countermeasure or safeguard
7. Build threat scenarios and mitigation plans
− Possibly by making use of an attack tree/threat tree
24

25. Illustrative table to capture privacy threats table
Lifecycle Principle Threat Controls Harm
Collection Transparency
Notice & Consent
Unauthorized
collection
Data analysis
Purpose verification
Hidden data bases
Collection Collection limitation Unlimited collection Purpose verification
Collection method
analysis
Lack of
proportionality
Processing Purpose
specification
Legitimate purpose
Processing
unrelated to
purpose
Function limits
User participation
Processing with
llegitimate purpose
Processing Processing Lack of consumer
control
Opt-out, Platform
privacy control
Automatic
processing
Processing Security Data integrity fault
or data
misrepresentation
Data integrity check
on read, write
Misrepresentation
Transfer Legal obligations Transfer PII outside
EU without consent
Notice & Consent Violation of EU
citizens’ basic rights
Maintenance Access &
participation,
Individual
participation,
Redress
Lack of consumer
redress
Privacy policy
includes process for
user redress
Inability to rectify
errors
25

26. Documenting controls and validation tests
• Selected controls should be documented in a reliable
storage as a part of the evidence of applying Privacy
Engineering
• It is good practice to also define test cases for validating
that the controls are implemented, operating as intended
and effect against the associated threat(s)
• This documentation forms part of the compliance
evidence, and it has to be reviewed by a privacy & product
security officers
26

27. Privacy risk assessment
• Produces evidence of minimization of possible privacy risk
• Residual risk = Fn (Harm, Impact, Probability, Mitigations)
• Re-conducted when material changes made to product
• ISO 31000 – A reference risk management framework
Context
establish external, internal context for risk, risk management
process and risk assessment criteria to be used
Identify
identify sources of risk, areas of impact, events and causes,
potential consequences
Analyze
consider causes and sources of risk, positive & negative
consequences, both tangible and intangible
Evaluate
make decisions based on risk analysis, which risks need treatment
and the priority for treatment implementation
Treat
select remediation based on avoiding, taking on, removing,
changing potential for, changing harm of, sharing of risk
Monitor &
Review
assures controls effective, learn and improve, detect context
changes, identify new risks, measure KPI
Improve commit to constant improvement of the overall risk footprint
Identify the
RESIDUAL RISK in
your product.
Product
management
must accept
residual risk!
27

28. Understanding privacy risks
Threats/Vulnerabilities (examples)
• “Hidden, uncontrolled, excessive or unsecure processing”
• Improper collection, use, disclosure
• Globally accepted privacy principles and laws often articulate these in more detail
• Privacy requirements and guidelines act as controls to these threats/vulnerabilities
Impacts to individuals (examples)
• Tangible (e.g. credit card fraud, discrimination)
• Intangible (e.g. embarrasement)
• Societal (e.g. chilling effect on freedom of speach)
Impacts/consequences to companies (in general)
• Bad publicity, erosion of trust
• Fines up to millions (new EU proposal: up to 2% of annual global turnover)
• Penalties, including personal criminal liability
• Forced privacy program with 20 year external audit obligation
• Data breach notifications (~$200 per lost record in US, similar in e.g. Germany)
• Deletion of unlawfully collected data
• Sales stops, recalls, cost of remediation
• Human rights, ethics challenges
28

29. Privacy risk assessment
• Objective is to reduce the business impact from exploitation of a set
of threats
• Process utilizes the results of the threat analysis and mitigation activity
• Product team is responsible for completion of risk analysis
• Technical team provides complementary support
• Residual Risk = Fn (Harm, Impact, Probability of Occurrence,
Mitigations)
• Risk migitation = actionable steps to reduce harm, impact or
probability
• Migitation approaches include:
• Do nothing, hope for the best
• Mitigate the risk by putting countermeasures in place
• Reduce impact or probability
• Accept the risk after evaluating the business impact
• Transfer the risk with contractual agreements or insurance
• Remove the risk, for example shutdown the product, remove feature
Security risk is about harm to the company, but privacy risk is about harm to the consumer
29

30. Example risk assessment report
ID Event Root causes Consequences Impact Probability
Treatment
actions
Monitoring
measures
Action
Deadline
Action owner
Privacy
breaches,
privacy
related loss
of
business,
compliance
including
corruption
and fraud
- Failures to
design
privacy into
products
and
services.
- NSA
espionage:
Cloud
services
concentrate
d to US
based cloud
providers
- User privacy
vs. benefits
of analytics
- Privacy
program and
resourcing
and
maturity
- Data
breaches
- Regulatory
enforcement
- Business
interruptions
, requests to
delete data,
sales stops.
- -End user
and business
customers
lost with US
based cloud
services
100-150 MEUR
Anything up to
$200 USD per
record in US
Up to 100 euro
per record in
Germany
Reputational
damage and lost
business
opporutnity
~15% -
Medium
Insurance
policy?
Training,
security
scanning and
audits
including
corrective
actions
MS
integrations
project
actions
Progress
measures,
milestones
followed
2Q2015 Alice
30

31. Privacy impact assessment
• EU GDPR Article 33 promulgates PIA for public/privacy orgs
• Produces evidence of implementation of Privacy by Design
• Conducted by staff when personal data is collected, used or
disclosed in a product or service
• Re-conducted if material changes made to product or service
• ISO 29134 (WD) will standardize methodology
31
Identify
describe the project, including the aims, whether any personal
information will be handled, inherent privacy principles
Analyze
identify the personal information flows, classify data, identify
relevant regulations, privacy requirements, privacy impact
Verify
validate that only essential data is collected and processed
for legitimate purposes required by the product or service
Simplify
change system and processes to only collect/store/process
essential data for minimum period with a data deletion plan
Secure
use industry best practices for safeguarding personal data
through life cycle, providing consumer control over their data
Remediate
identify remaining risk, level of harm and mitigation plan to
eliminate or reduce risk to acceptable level
Attest
record findings, gain sponsor commitment to implement any
needed changes, report results to management

32. Privacy capability assessment
• Provides a method for advancement of your privacy program
• Conducted to measure baseline and incremental changes
• Part of a commitment to accountability, constant improvement
• ISO 29190 (new IS) will standardize a methodology
32
Plan
agree on privacy capability assessment model (e.g., context
or business process based) and assessment scale to be used
Assess rate the current capability against target capability
Review
identify sub-optimal capabilities to be improved and overall
improvement plan
Report
communicate to management the assessment activity,
results, improvement actions and next scheduled assessment
Improve implement improvement plan

33. Privacy related business processes
• Quality management process
• Risk management process
• Assessment process
• Security engineering process
• Business continuity process
• Customer care process
• Incident response management process
• External communications process
• Authority request/lawful intercept process
33

34. Privacy Engineering &Assurance
34
1. WHAT – Information Privacy
− Terminology
− Roles within the Privacy Framework
− Privacy Principles
− Essence of privacy
− Privacy data lifecycle
− Personally Identifiable Information
and Identifiability
2. HOW – Compliance or Accountability
− Elements of an ACCOUNTABLE
privacy program
− Privacy activities across the product
life cycle
− Privacy program roles &
responsibilies
3. HOW - Privacy Engineering & Assurance
simplified
− Applying Privacy Engineering
− Privacy Engineering steps
− Privacy Assurance steps
− Design activities across the product
life cycle
− Privacy impact assessment
− Privacy risk management
− Assessing privacy maturity
− Privacy related business processes
4. Use case
− Initial description
− Assessment planning
− Kickoff meeting
− Use case & DFD
− Data inventory & classification
− Threat analysis
− Security considerations
− Privacy Policy template
− Assessment findings
− Final assessment review

35. Use case – Globetrotter Tech WeatherApp
You work as the privacy officer for Globetrotter Technologies, a
technology start-up. The business intends to rule the world of
mobile software apps to aid business travellers. You report to the
CPO Elliot.
You just finished giving a privacy training to the software staff and
Alice, a program manager, approached you to get some guidance,
as her Android Weather App is planning on going Live at the end of
the month. You have just reminded her that corporate policy is
that no product goes live without satisfactory recommendation
from the privacy officer after a final privacy assessment. Alice
designated Bob on her team as the privacy champ. Her dev
manager is Chuck. She reports to VP of programs, David.
She wants to get started ASAP.
What is your course of action?
35

36. 5. Gather
feedback
Review &
communicate
lessons learned
1. Plan & Prepare 2. Conduct 3. Report
Assessment planning
What is your course of action?
Generic role Purpose of the role
Assessment sponsor Has the authority in Nokia to decide Go/No go for assessments. Authorizes plan
and resourcing, specifies requirements. Ensures actions on findings
Lead assessor Ensures the successful execution of the assessment
Assessment team Team of people assessing the interviewees. Assessment team is headed by lead
assessor
Interviewees The sample of people from the audited/assessed organization that are
interviewed for the audit/ assessment
Assessment roles
Define scope, objectives,
Review and agree plan
with sponsors
Brief Assessment Team
Communicate
purpose to persons
to be assessed
Schedule & run
interviews per plan
Write report, agree
with all assessed then
report to sponsors &
stakeholders
Follow up
improvement
actions
4. Follow Up
• Get sponsor agreement for assessment and scope
• Identify and secure support of key assessor roles
• Follow the “Plan, Do, Check, Act” (PDCA) steps
36

37. Next steps
• Confirm assessment sponsorship with David, VP Programs
• Confirm assessment request with Elliot, CPO
• Email confirmation of availability to provide assessment
assistance to Alice, PM and request meeting to identify
assessment team and participants
• At subsequent meeting with Alice, verify role of Bob,
Privacy Champ and agree on Kickoff meeting purpose and
agenda
• Introductions, Purpose of assessment, Activities/Evidence
• Email invite to assessment Kickoff meeting to participants
• Req: Alice, PM; Bob, Privacy Champ; Chuck, Dev Mgr; You
• Opt: David, VP Programs; Elliot, CPO
37

38. Kickoff meeting
• At the kickoff meeting you learn
the following about the Weather
App project
• Alice is the program manager
• Bob is her privacy champ
• Chuck is the development
manager
• David is the program VP and
business owner
• Elliot is your CPO
• Android 4.4 app for Google Play
Store distribution
• Wave 1: EU countries
• Wave 2: US and CA
• 3rd party partners:
− OpenWeatherMap – Forecast
data
− CrashDaddy – Crash analytics
• Features
− Lookup city from GPS lat-lon
− Lookup forecast from city name
− History of last 12 forecasts
− Admin console for crash
analytics
What is your next course of action?
38

39. Next steps
• Schedule periodic meetings to progress assessment with
Alice, PM; Bob, Dev Mgr; and Chuck, Privacy Champ
• Verify product description through Team provided
evidence
• Perform/create System diagram, Data flow diagram, Data
inventory & classification, Threat analysis & mitigation
with Alice, PM; Bob, Dev Mgr; and Chuck, Privacy Champ
39

40. User experience concept
40

41. Weather app use case DFD
Open Weather
Map
Get
City
API Token,
Lat-Lon
Trust boundary
City
GPS
Sensor
Lat-Lon
City
Data
Store
Lat-Lon,
City
Get
Fore
cast
Forecast
API Token,
City
Forecast
Data
StoreLat-Lon, City
City
Look
up
Fore
cast
Forecast
Lat-Lon,
City
What findings can you infer?
• Forecast for current
position displayed
• User can enter city
name and get forecast
for that city
• Previous forecasts
kept to avoid data
charges from
unnecessary lookup
Mobile App
41

42. Web BrowserMobile App
Crash analytics use case DFD
Crash Daddy
Transfer
Crash
Data
API Token, Device ID,
Crash Payload
Trust boundary
Crash
Data
Store
Analytic
Request
What findings can you infer?
• Crash Payload pushed
on app restart after
crash recovery
• Web browser access to
crash analytics console
with admin credentials
• Crash analytics console
functions include
display of reports
based on crash-type
specific requestsCrash
Analytics
Console
Function
Analytic
Response
Crash
Payload
42

43. Data inventory
43

44. Example threat list (1 of 4)
44

45. Example threat list (2 of 4)
45

46. Example threat list (3 of 4)
46

47. Example threat list (4 of 4)
47

48. Threat analysis notes – Weather app
• No plan for product information to be provided to consumer in Google Play Store
entry
• No plan for supporting consumer inquiry
• No notice & consent given consumer on Terms or Privacy Policy
• Verify use of Globbetrotter Technologies Terms & Privacy Policy
• Google Play Store
• First-Use-Experience
• Within App
• No prior notice & consent of consumer on Location Data collection and use
• No data minimization effort
• Unclear vetting of Open Weather Map for 3rd party services
• Unclear how location/forecast history secured in device
• Unclear if uninstall will delete app data
• Unclear how API token secured in device
• Unclear product security plans
• Need product security training & awareness
• Unclear if app hardening will include tamper-prevention
• Unclear legal review plans
• Unclear service continuity plans
• Unclear reactive vulnerability & incident response plans
• No data retention/deletion plan
• Unclear coordination between Weather App & other business traveller app Teams
48

49. Threat analysis notes – Crash analytics
• No data minimization effort
• Unclear purpose for device id in crash payload
• Unclear purpose for memory dump in crash payload
• Unclear vetting of Crash Daddy for 3rd party services
• Unclear how API token secured in device
• Unclear product security plans
• Need product security training & awareness
• Unclear if app hardening will include tamper-prevention
• Unclear legal review plans
• Unclear service continuity plans
• No data retention/deletion plan
• Unclear if crash analytics planned only for Beta phase
49

50. Next steps
• Connect Alice, PM with Product Security Team to plan for
product security assessment
• Draft and share privacy assessment findings with Alice,
PM; Bob, Dev Mgr; and Chuck, Privacy Champ
• Coordinate assessment findings with Product Security
Team
• Assist and encourage Alice, PM; Bob, Dev Mgr; and Chuck,
Privacy Champ with documenting evidence of privacy
engineering activities
• Plan & schedule final assessment review with Alice, PM
50

51. Security considerations
Define
• OWASP Top-10 Security Threats
• Google Android Developer Security Guidelines
• Japan Smartphone Security Association Guidelines
Develop
• Static & dynamic code scanner
• Peer code review
• 3rd party security review
Deploy
• Hardening guidelines
• Vulnerability testing (eg, NMAP)
• Tamper-proofing, security distribution code
• Penetration testing
• Google Hacking
• Reactive vulnerability response
Roles & responsibility for drafting & approval of Privacy Policy should be clearly defined
51

52. Privacy policy template
• Title
• Change control/effective date
• Business privacy vision
• Define categories of applicable personal data
• Organization to which policy applies
• Why the defined categories of personal data is collected
• Limits on collection, use & disclosure of the personal data
• Define circumstance for disclosure of the personal data
• How consent for personal data collection & processing is
obtained
• How long the personal data is retained
• How the personal data is secured
• How the accuracy of the personal data is ensured
• How individuals can access their personal data
• How individuals can complain or make an inquiry
• Your identity and contact information
Roles & responsibility for drafting & approval of
Privacy Policy should be clearly defined52

53. Assessment report – Major findings
ID Category Title of finding Description of requirement Action Status
01 Major Notice & Consent Provide notice prior to initial collection,
Provide Opt-Out of data processing
Privacy notice and Terms need to be
provided in Google Play Store, First User
Experience and Settings
Major Notice & Consent Provide notice & consent prior to use of
location data
Add notice & consent control for location
data
03 Major Data minimization Minimum data collection & processing
for stated primary purposes
Conduct data minimization review of
data inventory against primary purpose
Major Data minimization No cross-border transfer of personal
data without user's Active Consent
Include cross-border transfer purpose in
Privacy Policy, as needed
Major Use, retention and
disclosure limitation
Provide method for consumer requests
for information & redress
Data Retention & Deletion Plan, Privacy
policy includes instructions for consumer
redress
Major Security Provide product security to protection
personal data
Verify no open major product security
assessment findings
Major 3rd Party Privacy &
Security
Management
Vetting of 3rd party service providers Email from PM verifying vetting of 3rd
party vendors by sourcing/legal
Not Ok Ok53

54. Assessment report – Minor findings
ID Category Title of finding Description of requirement Action Statu
s
Minor Service Continuity No service continuity plan Agree on service continuity strategy
and define and resource a plan
aligned with strategy
Minor Reactive
Vulnerability &
Incident Response
Management
No RV&IR plan Agree on reactive vulnerability &
incident response strategy and define
and resource a plan aligned with
strategy
Minor Requirements
alignment
Privacy & security
requirements alignment
across GT app teams
Coordinate privacy & security
requirements across app Teams
Not Ok Ok54

55. Assessment report – Recommendations
ID Category Title of finding Description of requirement Action Status
Recommend Requirements alignment Privacy & security requirements
alignment across GT app teams
Coordinate privacy & security
requirements across app Teams
Recommend App Hardening Harden install file with tamper-
detection, encryption of token handling
Integrate hardening tool such as
DEXGuard
Recommend Security Training &
Awareness
Train key team members on product
security
Product security training completed for
PM, Dev, QA, Req Mgmt
Recommend Legal Review Comply with local laws & regulations Complete legal review with legal counsel
Not Ok Ok55

56. Next steps
• Distribute final assessment report with Alice, PM; Bob, Dev
Mgr; and Chuck, Privacy Champ
• Work to close open action items with Alice, PM; Bob, Dev
Mgr; and Chuck, Privacy Champ
• Schedule and meet to conclude perform final assessment
review with Alice, PM
• Share final assessment recommendation with Alice, PM;
Elliot, CPO; and David, VP Programs
• Support Elliot, CPO on any resulting escallation
56

57. Final assessment review
Category Activity Requirement Criteria Status
Development Business Impact Overall product business
criticality & risks assessed
Risk assessment report
Product information Defined product
description, responsible
roles identified
Product description document
Data flows, System
architecture
Use cases identified, data
flows documented
Data inventory & classification
spreadsheet
Threat Analysis Privacy & security threats
and mitigating controls
documented
Threat assessment report
Code review Security code scan of
software. Manual security
code reviews also
recommended.
No open major code scan report
items or action items from manual
code review
Third party privacy &
security management
Contracts with 3rd parties
reference privacy &
security requirements.
Sign-off email from sourcing/legal
counsel
Not Ok Ok57

58. Final assessment review
Category Activity Requirement Criteria Status
Deployment Business continuity
plan
Defined, resourced &
tested plan, supporting
agreed RTO (Recovery
Time Objective)
Business continuity plan approved
by business accountable
Backup/recovery plan Defined, resourced &
tested plan, supporting
agreed RPO (Recovery
Point Objective)
Backup/recovery plan approved by
business accountable
Reactive Vulnerability
& Incident Response
Plan
Defined, resourced &
tested plan, supporting
agreed vulnerability &
incident mgmt. objectives
Reactive Vulnerability & Incident
Response plan approved by
business accountable
Audit logs Key activities logged and
according to retention &
deletion plan. No PII in logs
without legitimate purpose
Sign-off email from responsible
development manager
Access control Access to system admin
functions and to
sensitive/personal data
follows AAA best practices
Sign-off email from responsible
development manager
Software hardening Hardening to remove
insecure, unnecessary
software, features, test
data, accounts and similar
from the product
Sign-off email from responsible
development manager
Not Ok Ok58

59. Final assessment review
Category Activity Requirement Criteria Status
Compliance Privacy assessment Privacy controls selected in
threat analysis must be
implemented and verified
No open major findings, FUE
screenshots, Privacy Policy UX Test
Report
Security assessment Security controls selected
in threat analysis must be
implemented and verified
No open major findings
Not Ok Ok59

60. 60
5. References
60

61. References
EU Proposed General Data Protection Regulation
ISO 29100 from ISO (PDF version is freely available)
CIPL Implementing Accountability
CIPL Accountability Self-Assessment Tool
Android Developer Security Tips
Android Secure Design/Secure Coding Guidelines
Privacy policy generator
UK Privacy Commissioner guidelines
frank.dawson at nokia.com
61

62. What did you learn?
62

63. Q1: Which is not correct about Privacy Risk?
a. Related to harm to the individual’s personal data rights
b. Involves categories of tangible, intangible & ethical harm
c. Can be mitigated by accepting, transferring risk,
eliminating the harm or diminishing the probability or
impact of the harm
d. None of these
63

64. Q2: Which is not correct about the Data Flow
Diagram used in Privacy Engineering?
a. Visualizes internal and external interactors
b. Evidence of application of Privacy Engineering
c. Identifies the flow and category of personal data
d. Identifies threats to personal data
e. Can be useful in Product Security Assessment
64

65. Q3: What does best practice say should be
included in a Privacy Policy?
a. Business privacy vision
b. Categories of personal data that are collected and
processed
c. Purposes for which personal data is collected and
processed
d. Name & address for contacting the Data Controller
e. All of the above
65

66. Q4: What is the essence of privacy?
a. Personal data
b. Privacy data lifecycle
c. Identifiability of personal data
d. a and c
e. Nymity
f. a and c and e
66

67. Q5: Which statement about Privacy Engineering and
PrivacyAssurance is not correct?
a. Privacy Engineering involves implementation of Privacy by
Design
b. Privacy Assurance involves the acceptance of any residual
product privacy risk
c. Privacy Engineering includes activities at all stages of the
product life cycle and should begin as early as feasible
d. Privacy Assurance should include a final verification that
the findings from the Privacy Engineering have been
implemented and are operational in the product
e. Privacy Engineering is an emerging discipline
67

68. Q6: What is not a purpose of PrivacyAssurance?
a. Verify that identified privacy safeguards are implemented
b. Determine if the product is ready to ”Go Live”
c. Document residual privacy risks
d. Ensure there is evidence of Privacy Engineering in the
event a privacy audit is required
e. Identify possible areas of privacy non-compliance
68

69. QuizAnswers
1. d
2. d, Threats are identified as a result of the Threat
Assessment process
3. e
4. f
5. b, It is the responsibility of the business owners to accept
residual risk in the product
6. b, The decision to ”Go-Live” with a product involves more
than just successful conclusion to a Privacy Assurance
review.
69