ETSI TR 103 370 V1.1.1 (2019-01)

Practical introductory guide to Technical Standards for Privacy

DTR/CYBER-0010

General Information

• Status: Published
• Publication Date: 24-Jan-2019
• Technical Committee: CYBER - Cyber Security
• Current Stage: 12 - Completion
• Due Date: 18-Feb-2019
• Completion Date: 25-Jan-2019

Standards Content (Sample)

ETSI TR 103 370 V1.1.1 (2019-01)






TECHNICAL REPORT
Practical introductory guide
to Technical Standards for Privacy

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2 ETSI TR 103 370 V1.1.1 (2019-01)



Reference
DTR/CYBER-0010
Keywords
confidentiality, privacy

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3 ETSI TR 103 370 V1.1.1 (2019-01)
Contents
Intellectual Property Rights . 4
Foreword . 4
Modal verbs terminology . 4
Executive summary . 4
1 Scope . 5
2 References . 5
2.1 Normative references . 5
2.2 Informative references . 5
3 Definition of terms, symbols and abbreviations . 7
3.1 Terms . 7
3.2 Symbols . 7
3.3 Abbreviations . 7
4 Glossary of terms . 7
4.1 Collation of terms . 7
4.2 Taxonomy of terms . 14
5 Standards and guidelines to management of privacy . 16
5.1 Privacy Impact Assessment . 16
5.2 Guidelines and best practices . 17
5.3 Impact assessment and analysis . 17
5.4 Codes of practice . 17
5.5 Cryptographic mechanisms . 17
5.6 Management system including privacy protection . 18
6 General principles . 18
6.1 Caveats and warnings . 18
6.2 EU regulatory and legal context . 19
6.3 Privacy management principles . 19
7 Application of principles to example use cases . 22
7.1 Least to kno w/collect . 22
7.2 Data/privacy protection and data brokering . 22
7.3 The Right to be forgotten . 24
8 Gaps in standardization . 24
Annex A: Bibliography . 26
History . 27


ETSI

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4 ETSI TR 103 370 V1.1.1 (2019-01)
Intellectual Property Rights
Essential patents
IPRs essential or potentially essential to normative deliverables may have been declared to ETSI. The information
pertaining to these essential IPRs, if any, is publicly available for ETSI members and non-members, and can be found
in ETSI SR 000 314: "Intellectual Property Rights (IPRs); Essential, or potentially Essential, IPRs notified to ETSI in
respect of ETSI standards", which is available from the ETSI Secretariat. Latest updates are available on the ETSI Web
server (https://ipr.etsi.org/).
Pursuant to the ETSI IPR Policy, no investigation, including IPR searches, has been carried out by ETSI. No guarantee
can be given as to the existence of other IPRs not referenced in ETSI SR 000 314 (or the updates on the ETSI Web
server) which are, or may be, or may become, essential to the present document.
Trademarks
The present document may include trademarks and/or tradenames which are asserted and/or registered by their owners.
ETSI claims no ownership of these except for any which are indicated as being the property of ETSI, and conveys no
right to use or reproduce any trademark and/or tradename. Mention of those trademarks in the present document does
not constitute an endorsement by ETSI of products, services or organizations associated with those trademarks.
Foreword
This Technical Report (TR) has been produced by ETSI Technical Committee Cyber Security (CYBER).
Modal verbs terminology
In the present document "should", "should not", "may", "need not", "will", "will not", "can" and "cannot" are to be
interpreted as described in clause 3.2 of the ETSI Drafting Rules (Verbal forms for the expression of provisions).
"must" and "must not" are NOT allowed in ETSI deliverables except when used in direct citation.
Executive summary
The present document has been prepared in response to Mandate M/530 [i.9] and presents a guide to the application of
standards in the implementation of privacy management. The present document has been structured in four parts to
achieve the goals of the Mandate:
Part 1: Privacy terms and definitions based on existing documents.
Part 2: Status of standardization work considering existing or future work in ISO, CEN/CENELEC, ETSI
and other bodies - identification of the basic building blocks.
Part 3: General principles how to introduce privacy management in equipment, services and solutions.
Part 4: Application of the principles for privacy by design to some examples:
 Least to know/collect.
 Data/privacy protection and data brokering (especially considering aggregated data, here in
many legal systems it is the case that applying advanced algorithms on open data may result
in private data).
 The right to be forgotten.
In addition, the present document identifies gaps in standardization and makes a number of recommendations for
addressing those gaps.
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1 Scope
The present document gives a guide to the use of standards to assist in the management of privacy. The present
document contains the following key elements:
• Table 1 contains a collation of terms related to data protection and privacy from selected SDOs and
comparison to the GDPR [i.1].
• Privacy terms and definitions based on existing documents (ISO, ENISA, and others).
• Status of standardization work including consideration of existing or future work in ISO, CEN/CENELEC,
ETSI and other bodies.
• Identification of the basic building blocks and main principles for privacy protection and their mapping to
available standards.
• Fundamental privacy by design principles that are commonly recognized.
• Examples of application of the privacy by design principles.
In addition, the present document identifies gaps in standardization and makes several recommendations for addressing
those gaps.
2 References
2.1 Normative references
Normative references are not applicable in the present document.
2.2 Informative references
References are either specific (identified by date of publication and/or edition number or version number) or
non-specific. For specific references, only the cited version applies. For non-specific references, the latest version of the
referenced document (including any amendments) applies.
NOTE: While any hyperlinks included in this clause were valid at the time of publication ETSI cannot guarantee
their long-term validity.
The following referenced documents are not necessary for the application of the present document, but they assist the
user with regard to a particular subject area.
[i.1] Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the
protection of natural persons with regard to the processing of personal data and on the free
movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
[i.2] European Convention of Human Rights.
NOTE: Available at www.echr.coe.int.
[i.3] Universal Declaration of Human Rights.
NOTE: Available at http://www.un.org/en/universal-declaration-human-rights/.
[i.4] ETSI TS 103 486: "CYBER; Identity management and naming schema protection mechanisms".
[i.5] ETSI TS 103 485: "CYBER; Mechanisms for privacy assurance and verification".
[i.6] ETSI TR 187 010: "Telecommunications and Internet converged Services and Protocols for
Advanced Networking (TISPAN); NGN Security; Report on issues related to security in identity
imanagement and their resolution in the NGN".
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6 ETSI TR 103 370 V1.1.1 (2019-01)
[i.7] ISO/IEC 29100:2011 amended by ISO/IEC 29100:2011/Amd 1:2018: "Information technology --
Security techniques -- Privacy framework".
[i.8] ISO/IEC 29191:2012: "Information technology -- Security techniques -- Requirements for partially
anonymous, partially unlinkable authentication".
[i.9] M/530 Commission Implementing Decision C(2015) 102 final of 20.1.2015 on a standardisation
request to the European standardisation organisations as regards European standards and European
standardisation deliverables for privacy and personal data protection management pursuant to
Article 10(1) of Regulation (EU) No 1025/2012 of the European Parliament and of the Council in
support of Directive 95/46/EC of the European Parliament and of the Council and in support of
Union's security industrial policy.
[i.10] Article 29 Data Protection Working Party, Guidelines on Data Protection Impact Assessment
(DPIA) and determining whether processing is "likely to result in a high risk" for the purposes of
Regulation 2016/679.
[i.11] ETSI TS 103 532: "CYBER; Attribute Based Encryption for Attribute Based Access Control".
[i.12] Charter of Fundamental Rights of the European Union.
[i.13] ISO/IEC 29134:2017: "Information technology -- Security techniques -- Guidelines for privacy
impact assessment".
[i.14] ISO/IEC 27001:2013: "Information technology -- Security techniques --Information security
management systems - Requirements".
[i.15] ISO/IEC 27552: 2019: "Extension to ISO/IEC 27001 and ISO/IEC 27002 for privacy information
management - Requirements and guidelines (PIMS)".
NOTE: At the time of publication of the present document ISO/IEC 27552 is not yet published.
[i.16] ETSI TR 103 305-5: "CYBER; Critical Security Controls for Effective Cyber Defence; Part 5:
Privacy enhancement".
[i.17] ETSI TS 102 165-1: "CYBER; Methods and protocols; Part 1: Method and pro forma for Threat,
Vulnerability, Risk Analysis (TVRA)".
[i.18] ETSI TR 103 305-1: "CYBER; Critical Security Controls for Effective Cyber Defence; Part 1: The
Critical Security Controls".
[i.19] ETSI GS NFV-SEC 006: "Network Functions Virtualisation (NFV); Security Guide; Report on
Security Aspects and Regulatory Concerns".
[i.20] ISO/IEC 15408 series: "Information technology -- Security techniques -- Evaluation criteria for IT
security".
[i.21] ISO/IEC 20889:2018: "Privacy enhancing data de-identification terminology and classification of
techniques".
[i.22] ISO/IEC 29151:2017: "Information technology -- Security techniques -- Code of practice for
personally identifiable information protection".
[i.23] ISO/IEC 27018:2014: "Information technology -- Security techniques -- Code of practice for
protection of personally identifiable information (PII) in public clouds acting as PII processors".
[i.24] ISO/IEC CD 29184: "Information technology -- Online privacy notices and consent" (under
develpment).
[i.25] ISO/IEC PDTR 27550: "Information technology -- Security techniques -- Privacy engineering"
(under develpment).
[i.26] ISO/IEC 29146:2016: "Information technology -- Security techniques -- A framework for access
management".
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7 ETSI TR 103 370 V1.1.1 (2019-01)
[i.27] ISO/IEC 29190:2015: "Information technology -- Security techniques -- Privacy capability
assessment model".
[i.28] ISO/IEC 27002:2013: "Information technology -- Security techniques -- Code of practice for
information security controls".
[i.29] Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning
the processing of personal data and the protection of privacy in the electronic communications
sector (Directive on privacy and electronic communications).
3 Definition of terms, symbols and abbreviations
3.1 Terms
For the purposes of the present document, the terms given in clause 4 apply.
3.2 Symbols
Void.
3.3 Abbreviations
For the purposes of the present document, the following abbreviations apply:
ABE Attribute Based Encryption
DPIA Data Protection Impact Assesment
EC European Commission
ECHR European Court of Human Rights
ENISA European Union Agency for Network and Information Security
GDPR General Data Protection Regulation
ICT Information and Communication Technology
IOT Internet Of Things
ISMS Information Security Management System
ISO International Standard Organization
IV Initial Value
NGP Next Generation Protocol
PET Privacy Enhancing Technology
PIA Privacy Impact Assessment
PII Personally Identifiable Information
PIMS Privacy Impact Management System
TE Terminal Equipment
TEDDI Terms and Definitions Database Interactive
TS Technical Specification
UDHR Universal Declaration of Human Rights
4 Glossary of terms
4.1 Collation of terms
Table 1 presents a general collation of the terms from a small set of primary sources of the terms used in addressing
privacy in standards. The primary sources that have been used to build this collation are:
• Regulation (EU) 2016/679 (GDPR) [i.1];
• ISO/IEC 29000 series [i.8], [i.7] and [i.13];
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8 ETSI TR 103 370 V1.1.1 (2019-01)
• ISO/IEC 15408 series [i.20];
• ISO/IEC 20889 [i.21]; and
• ETSI TEDDI repository https://webapp.etsi.org/Teddi/.
Table 1: Collation of terms related to data protection and privacy
from selected SDOs and comparison to the GDPR
Term Definition Source of definition Remarks
anonymity characteristic of information that ISO/IEC 29100 To determine whether an
does not permit a personally individual is identifiable,
identifiable information principal account should be taken of
to be identified directly or all the means likely
indirectly reasonably to be used by
the entity holding the data
or by any other party, to
identify that individual
principle whereby ones identity ETSI TEDDI, group NA Identical text
is withheld from other parties
(see note 1)
'Anonymity' is the principle ETSI TEDDI, group SMG
whereby ones identity is
withheld from other parties
(see note 1)
ability of a user to use a
ETSI TEDDI, group ITS Derived from
resource or service without ISO/IEC 15408-2
disclosing the user's identity
(see note 2)
act of ensuring that a user may ETSI TEDDI, group SMG
use a resource or service
without disclosing the user's
identity (see note 2)
anonymization process by which personally ISO/IEC 29100
identifiable information (PII) is
irreversibly altered in such a
way that a PII principal can no
longer be identified directly or
indirectly, either by the PII
controller alone or in
collaboration with any other
party
process that replaces an actual ETSI TEDDI, group
identifier with an attribute CYBER
obtained by randomization or
generalization in such a way
that there is a reasonable level
of confidence that no individual
can be identified
de-anonymization Any process in which ETSI TEDDI, group
anonymous data is cross- CYBER
referenced with other sources of ISO/IEC 20889
data to re-identify the
anonymous data source
anonymized data data that has been produced as
the output of a personally
identifiable information
anonymization process
de-identification process of removing the ISO/IEC 20889
association between a set of
identifying data and the data
principal
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Term Definition Source of definition Remarks
enterprise natural or legal person engaged GDPR See also 'undertakings' in
in an economic activity, GDPR
irrespective of its legal form,
including partnerships or
associations regularly engaged
in an economic activity
unit of economic organization or ETSI TEDDI groups
activity, especially a business 3GPP&TISPAN
organization
identifiability condition which results in a
personally identifiable
information (PII) principal being
identified, directly or indirectly,
on the basis of a given set of PII
identifier set of attribute values that
unambiguously distinguish one
entity from another one in a
given context
total list of attribute values of an Appears to overlap with
entity that allows this entity to definition of identity below
be unambiguously distinguished
from all other entities within a
context and to be recognized as
a single identity in that specific
context
means of indicating a point of ETSI TEDDI, group 3GPP
contact, intended for public use
such as on a business card.
Telephone numbers, email
addresses, and typical home
page URLs are all examples of
identifier in other systems
series of digits, characters and ETSI TEDDI, group
symbols used to identify TISPAN
uniquely subscriber(s), user(s),
network element(s), function(s)
or network entity(ies) providing
services/applications
user's name and optionally a
password
attribute or a set of attributes of ETSI TEDDI, group ITS
an entity which uniquely
identifies the entity within a
certain context
series of digits, characters and ETSI TEDDI, group NGP
symbols or any other form of
data used to identify
subscriber(s), user(s), network
element(s), function(s), network
entity(ies) providing
services/applications, or other
entities (e.g. physical or logical
objects)
user identification (name and, ETSI TEDDI, group TE
where appropriate, password)
which can be supplied during
the call in order to indicate
entitlements with regard to
operations on files
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Term Definition Source of definition Remarks
identity set of attributes which make it
possible to identify the
personally identifiable
information principal
technical label which may ETSI TETRA
represent the origin or
destination of any
telecommunications traffic, as a
rule clearly identified by a
physical telecommunications
identity number (such as a
telephone number) or the
logical or virtual
telecommunications identity
number (such as a personal
number) which the subscriber
can assign to a physical access
on a case-by-case basis
attributes by which an entity or ETSI TEDDI, group OCG
person is described, recognized
or known
data or information (identifier) ETSI TEDDI, group HF
that are used to distinguish one
object or person from others.
These data can take many
forms, and also a single object
or person may have different
identities associated.
Authentication can be used to
verify purported identities. An
identity, which has been so
verified, is called an
authenticated identity
essence of an entity and often ETSI TEDDI, group

described by its characteristics BROADCAST
identifier allocated to a ETSI TEDDI, group

particular entity, e.g. a particular TISPAN
end-user, provides an Identity
for that entity
a system unique tag applied to ETSI TEDDI, group SMG

an entity
information about an entity that ETSI TEDDI, group NGP

is sufficient to identify that entity
in a particular context
opt-in process or type of policy
ISO/IEC 29100
whereby the personally
identifiable information (PII)
principal is required to take an
action to express explicit, prior
consent for their PII to be
processed for a particular
purpose (see note 7)
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11 ETSI TR 103 370 V1.1.1 (2019-01)
Term Definition Source of definition Remarks
personally, identifiable any information that: ISO/IEC 29100 Regulation (EU) 2016/679
information (PII) a) can be used to establish a defines personal data:
link between the "any information relating to
information and the natural an identified or identifiable
person to whom such natural person ('data
information relates, or subject'); an identifiable
b) is or might be directly or natural person is one who
indirectly linked to a natural can be identified, directly
person (see note 10) or indirectly, in particular
by reference to an
identifier such as a name,
an identification number,
location data, an online
identifier or to one or more
factors specific to the
physical, physiological,
genetic, mental, economic,
cultural or social identity of
that natural person"
PII controller privacy stakeholder (or privacy ISO/IEC 29100 Regulation (EU) 2016/679
stakeholders) that determines defines controller as "the
the purposes and means for natural or legal person,
processing personally public authority, agency or
identifiable information (PII) other body which, alone or
other than natural persons who jointly with others,
use data for personal purposes determines the purposes
(see note 8) and means of the
processing of personal
data; where the purposes
and means of such
processing are determined
by Union or Member State
law, the controller or the
specific criteria for its
nomination may be
provided for by Union or
Member State law"
PII principal natural person to whom the ISO/IEC 29100 Data subject indirectly
personally identifiable defined in Regulation
information (PII) relates (see (EU)2016/679 as part of
note 9) the definition of personal
data: "identified or
identifiable natural person
('data subject')"
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Term Definition Source of definition Remarks
processing of PII operation or set of operations ISO/IEC 29100 Regulation (EU) 2016/679
performed upon personally defines processing as
identifiable information (PII) "any operation or set of
operations which is
performed on personal
data or on sets of personal
data, whether or not by
automated means, such as
collection, recording,
organization, structuring,
storage, adaptation or
alteration, retrieval,
consultation, use,
disclosure by transmission,
dissemination or otherwise
making available,
alignment or combination,
restriction, erasure or
destruction"
PII processor privacy stakeholder that ISO/IEC 29100 Regulation (EU) 2016/679
processes personally defines data processor:
identifiable information (PII) on "means a natural or legal
behalf of and in accordance person, public authority,
with the instructions of a PII agency or other body
controller which processes personal
data on behalf of the
controller"
privacy breach situation where personally ISO/IEC 29100 Regulation (EU) 2016/679
identifiable information is defines personal data
processed in violation of one or breach: "breach of security
more relevant privacy leading to the accidental or
safeguarding requirements unlawful destruction, loss,
alteration, unauthorized
disclosure of, or access to,
personal data transmitted,
stored or otherwise
processed"
privacy controls measures that treat privacy
ISO/IEC 29100
risks by reducing their likelihood
or their consequences (see
notes 3 and 4)
privacy-enhancing privacy control, consisting of
ISO/IEC 29100
technology PET information and communication
technology (ICT) measures,
products, or services that
protect privacy by eliminating or
reducing personally identifiable
information (PII) or by
preventing unnecessary and/or
undesired processing of PII, all
without losing the functionality
of the ICT system
privacy impact anything that has an effect on ISO/IEC 29134 The privacy impact might
the privacy of a PII principal result from the processing
and/or group of PII principals of PII in conformance or in
violation of privacy
safeguarding requirements
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Term Definition Source of definition Remarks
Privacy Impact overall process of identifying, ISO/IEC 29134
Assessment (PIA) analysing, evaluating,
consulting, communicating and
planning the
treatment of potential privacy
impacts with regard to the
processing of personally
identifiable
information, framed within an
organization's broader risk
management framework
privacy risk assessment
overall process of risk ISO/IEC 29100 Data Protection Impact
(also known as privacy identification, risk analysis and Assessment in Regulation
impact assessment PIA) risk evaluation with regard to (EU) 2016/679
the processing of personally
identifiable information (PII)

specific choices made by a
personally identifiable
information (PII) principal about
how the
...