ETSI TR 103 534-2 V1.1.1 (2019-10)

SmartM2M; Teaching material; Part 2: Privacy

DTR/SmartM2M-103534-2

General Information

• Status: Published
• Publication Date: 10-Oct-2019
• Technical Committee: SmartM2M - Smart M2M
• Current Stage: 12 - Completion
• Due Date: 08-Nov-2019
• Completion Date: 11-Oct-2019

Standards Content (Sample)

ETSI TR 103 534-2 V1.1.1 (2019-10)






TECHNICAL REPORT
SmartM2M;
Teaching material;
Part 2: Privacy



---------------------- Page: 1 ----------------------
2 ETSI TR 103 534-2 V1.1.1 (2019-10)



Reference
DTR/SMARTM2M-103534-2
Keywords
cybersecurity, IoT, oneM2M, privacy, security

ETSI
650 Route des Lucioles
F-06921 Sophia Antipolis Cedex - FRANCE

Tel.: [phone]  Fax: [phone]

Siret N° 348 623 562 00017 - NAF 742 C
Association à but non lucratif enregistrée à la
Sous-Préfecture de Grasse (06) N° 7803/88

Important notice
The present document can be downloaded from:
http://www.etsi.org/standards-search
The present document may be made available in electronic versions and/or in print. The content of any electronic and/or
print versions of the present document shall not be modified without the prior written authorization of ETSI. In case of any
existing or perceived difference in contents between such versions and/or in print, the prevailing version of an ETSI
deliverable is the one made publicly available in PDF format at www.etsi.org/deliver.
Users of the present document should be aware that the document may be subject to revision or change of status.
Information on the current status of this and other ETSI documents is available at
https://portal.etsi.org/TB/ETSIDeliverableStatus.aspx
If you find errors in the present document, please send your comment to one of the following services:
https://portal.etsi.org/People/CommiteeSupportStaff.aspx
Copyright Notification
No part may be reproduced or utilized in any form or by any means, electronic or mechanical, including photocopying
and microfilm except as authorized by written permission of ETSI.
The content of the PDF version shall not be modified without the written authorization of ETSI.
The copyright and the foregoing restriction extend to reproduction in all media.

© ETSI 2019.
All rights reserved.

DECT™, PLUGTESTS™, UMTS™ and the ETSI logo are trademarks of ETSI registered for the benefit of its Members.

3GPP™ and LTE™ are trademarks of ETSI registered for the benefit of its Members and
of the 3GPP Organizational Partners.
oneM2M™ logo is a trademark of ETSI registered for the benefit of its Members and
of the oneM2M Partners.
®
GSM and the GSM logo are trademarks registered and owned by the GSM Association.
ETSI

---------------------- Page: 2 ----------------------
3 ETSI TR 103 534-2 V1.1.1 (2019-10)
Contents
Intellectual Property Rights . 5
Foreword . 5
Modal verbs terminology . 5
Introduction . 5
1 Scope . 6
1.1 Context for the present document . 6
1.2 Scope of the present document . 6
2 References . 7
2.1 Normative references . 7
2.2 Informative references . 7
3 Definitions of terms, symbols and abbreviations . 8
3.1 Terms . 8
3.2 Symbols . 9
3.3 Abbreviations . 10
4 What is privacy? . 10
4.1 Outline . 10
4.2 Privacy and data protection . 10
4.3 The General Data Protection Regulation (GDPR) . 11
4.3.1 Introduction. 11
4.3.2 Data Protection Principles . 12
4.3.3 Reasons to Process Data . 13
4.3.4 Rights of Individual . 13
4.4 The novelties of the GDPR. 14
4.4.1 Overview . 14
4.4.2 Data Breach Notification . 14
4.4.2.0 Introduction . 14
4.4.2.1 Who to Notify . 15
4.4.2.2 What to Notify . 15
5 Privacy in the Context of IoT . 15
5.1 A holistic Approach of IoT Systems . 15
5.1.1 Major characteristics of IoT systems . 15
5.1.2 The need for an "IoT-centric" view . 16
5.1.2.1 Introduction . 16
5.1.2.2 Roles . 16
5.1.2.3 Reference Architecture(s) . 16
5.1.2.4 Guidelines . 17
5.2 Summary of Challenges of Privacy in IoT . 17
5.3 Illustrating data processing within the IoT ecosystem. 17
6 Use case example of IoT Privacy . 18
6.1 Introduction . 18
6.2 Use Case 1: Ambient assisted living in smart homes, older people . 18
6.2.1 Overview . 18
6.2.2 Background . 19
6.2.3 Description . 19
6.2.4 Data Protection Issues . 19
6.3 Use Case 2: Smart home solutions . 19
6.3.1 Background . 19
6.3.2 Description . 19
6.3.3 Data Protection Issues . 20
6.4 Use Case 3: Logistics and workplace . 20
6.4.1 Background . 20
6.4.2 Description . 20
ETSI

---------------------- Page: 3 ----------------------
4 ETSI TR 103 534-2 V1.1.1 (2019-10)
6.4.3 Data Protection Issues . 20
7 How to assess risks in the IoT ecosystem? . 21
7.1 Overview of risks linked to data protection . 21
7.2 Data Protection Impact Assessment . 22
8 How to mitigate risks in an IoT ecosystem? . 23
8.1 Introduction . 23
8.2 How to mitigate risks upstream? . 23
8.3 How to mitigate risks mid-strea m? . 24
8.4 How to mitigate risks downstream? . 26
9 Concluding Remarks . 26
Annex A: Guide to Certification in Privacy . 28
A.0 Introduction . 28
A.1 Certified Information Privacy Professional (CIPP) . 28
A.2 Certified Information Privacy Manager (CIPM) . 28
A.3 Certified Information Privacy Technologist (CIPT) . 29
Annex B: IoT Privacy Teaching Slides . 30
Annex C: Change History . 31
History . 32


ETSI

---------------------- Page: 4 ----------------------
5 ETSI TR 103 534-2 V1.1.1 (2019-10)
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 Smart Machine-to-Machine
communications (SmartM2M).
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.
Introduction
The present document is to focus on producing teaching material on privacy and to direct the reader to other materials
that are available in order to gain a basic understanding on what the privacy concept relates to that is particularly
relevant, also, for the IoT environment. The present document is based on the Privacy Report ETSI TR 103 591 [i.1].
Taking into account the main gaps result of the STF 505 (https://portal.etsi.org/STF/STFs/STFHomePages/STF505) in
relation to privacy and security as captured under ETSI TR 103 376 [i.13], the document starts by introducing the target
audience to whom the present document is addressed to base on the assumption that the future reader has no knowledge
on the issue of privacy. To this end and in view of achieving the maximum of the learning outcome, the document will
address key aspects of privacy by raising a set of relevant questions. In line with the educational purpose envisioned, the
document will be largely based on the use of examples.
In addition, the present document provides for other sources available for learners. In particular and in line with the
approach taken under STF 515 (https://portal.etsi.org/STF/STFs/STFHomePages/STF515), a set of quizzes will allow
the learner to verify the knowledge gained. Similarly, a set of slides will allow the learner to easily gain access to the
contents of the present document. Both the quizzes and the slides are integrated in annex B of the present document.

ETSI

---------------------- Page: 5 ----------------------
6 ETSI TR 103 534-2 V1.1.1 (2019-10)
1 Scope
1.1 Context for the present document
The design, development and deployment of - potentially large - IoT systems require to address a number of topics -
such as privacy, interoperability or privacy - that are related and should be treated in a concerted manner. In this
context, several Technical Reports have been developed that each address a specific facet of IoT systems.
In order to provide a global a coherent view of all the topics addressed, a common approach has been outlined across
the Technical Reports concerned with the objective to ensure that the requirements and specificities of the IoT systems
are properly addressed and that the overall results are coherent and complementary.
The present document has been built with this common approach also applied in all of the other documents listed
below:
ETSI TR 103 533 [i.14]
ETSI TR 103 534-1 [i.7]
ETSI TR 103 534-2 (the present document)
ETSI TR 103 535 [i.15]
ETSI TR 103 536 [i.16]
ETSI TR 103 537 [i.17]
ETSI TR 103 591 [i.1]
1.2 Scope of the present document
The focus of the present document is to present a summary of the teaching material to help in acquiring knowledge on
IoT Privacy. The teaching slides are in annex B of the present document. The present document is to support the IoT
Technical Report (TR) and it will re-enforce the knowledge in the TR such that reader can acquire basic knowledge to
apply IoT privacy in their area of engagement or at least know where to obtain that information. The present document
does not address IoT security, although closely linked but this is being addressed in a separate report which is ETSI
TR 103 534-1 [i.7].
Learning Objective: Considering that the overarching objective of this teaching material is to provide learners with the
necessary information, so as to gain basic knowledge on how the concept of privacy applies in the IoT environment.
Allowing them to make decisions and act accordingly.
This teaching material is addressed to learners holding different functions in the supply chain. To this end, it provides
for actors such as device manufacturers, software developers, and users benefiting from the delivery of service through
the IoT supply chain.
ETSI

---------------------- Page: 6 ----------------------
7 ETSI TR 103 534-2 V1.1.1 (2019-10)
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] ETSI TR 103 591 (V1.1.1): "SmartM2M; Privacy study report; Standards Landscape and best
practices".
[i.2] European Data Protection Supervisor: "Glossary".
NOTE: Available at https://edps.europa.eu/data-protection/data-protection/glossary_en.
[i.3] Cloud Service Level Agreement Standardisation Guidelines.
NOTE: Available at https://ec.europa.eu/digital-single-market/en/news/cloud-service-level-agreement-
standardisation-guidelines.
[i.4] 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),
OJ 2016 L 119/1.
[i.5] Directive 95/46/EC on the protection of individuals with regard to the processing of personal data
and on the free movement of such data.
[i.6] ETSI TS 103 485: "CYBER; Mechanisms for privacy assurance and verification".
[i.7] ETSI TR 103 534-1 (V1.1.1): "SmartM2M; Teaching Material; Part 1: Security".
[i.8] Protecting Privacy and Data in the Internet of Things: "Considerations and techniques for big data,
machine learning and analytics February 2019 GSMA".
NOTE: Available at www.gsma.com.
[i.9] European Data Protection Supervisor: "Preliminary Opinion on privacy by design", 31 May 2018.
[i.10] Noto La Diega Guido and Walden Ian: "Contracting for the 'Internet of Things': Looking into the
Nest" (February 1, 2016). Queen Mary School of Law Legal Studies Research Paper
No. 219/2016.
[i.11] Article 29 Data Protection Working Party, Opinion 8/2014 on the Recent Developments on the
Internet of Things, adopted on 16 September 2014.
[i.12] ICO: "Privacy in Mobile Apps Guidance for app developers".
NOTE: Available at https://ico.org.uk/media/for-organisations/documents/1596/privacy-in-mobile-apps-dp-
guidance.pdf.
[i.13] ETSI TR 103 376 (V1.1.1) (2016-10): "SmartM2M; IoT LSP use cases and standards gaps".
ETSI

---------------------- Page: 7 ----------------------
8 ETSI TR 103 534-2 V1.1.1 (2019-10)
[i.14] ETSI TR 103 533: "SmartM2M; Security; Standards Landscape and best practices".
[i.15] ETSI TR 103 535: "SmartM2M; Guidelines for using semantic interoperability in the industry".
[i.16] ETSI TR 103 536: "SmartM2M; Strategic / technical approach on how to achieve
interoperability/interworking of existing standardized IoT Platforms".
[i.17] ETSI TR 103 537: "SmartM2M; Plugtests™ preparation on Semantic Interoperability".
[i.18] Proposal for a Regulation of the European Parliament and of the Council on ENISA, theof the
European Parliament and of the Council on ENISA, the "EU Cybersecurity Agency", and
repealing Regulation.
3 Definitions of terms, symbols and abbreviations
3.1 Terms
For the purposes of the present document, the following terms apply:
cyber security (or cybersecurity): comprises all activities necessary to protect network and information systems, their
users, and affected persons from cyber threats [i.18]
NOTE: There are multiple definitions on cybersecurity each of which pertains to a specific domain. The
definition above has been considered appropriate for the purpose of the present document.
data concerning health: personal data related to the physical or mental health of a natural person, including the
provision of health care services, which reveal information about his or her health status [i.18]
genetic data: personal data relating to the inherited or acquired genetic characteristics of a natural person which give
unique information about the physiology or the health of that natural person and which result, in particular, from an
analysis of a biological sample from the natural person in question
The following terms are taken from [i.3]:
authentication: verification of the claimed identity of an entity
availability: property of being accessible and usable upon demand by an authorized entity
data: Data of any form, nature or structure, that can be created, uploaded, inserted in, collected or derived from or with
cloud services and/or cloud computing, including without limitation proprietary and non-proprietary data, confidential
and non-confidential data, non-personal and personal data, as well as other human readable or machine-readable data.
data controller: natural or legal person, public authority, agency or any other body which alone or jointly with others
determines the purposes and means of the processing of personal data
data integrity: property of protecting the accuracy and completeness of assets
data portability: bility to easily transfer data from one system to another without being required to re-enter data
data processor: natural or legal person, public authority, agency or any other body which processes personal data on
behalf of the Data controller
data protection: The employment of technical, organisational and legal measures in order to achieve the goals of data
security (confidentiality, integrity and availability), transparency, intervenability and portability, as well as compliance
with the relevant legal framework.
NOTE: In the context of the present report, data protection refers to the protection of personal data. It is largely
technically feasible that non-personal data become personal data.
data retention period: length of time which the cloud service provider will retain backup copies of the cloud service
customer data during the termination process (in case of problems with the retrieval process or for legal purposes); this
period may be subject to legal or regulatory requirements, which can place lower or upper bounds on the length of time
that the provider can retain copies of cloud service customer data
ETSI

---------------------- Page: 8 ----------------------
9 ETSI TR 103 534-2 V1.1.1 (2019-10)
data subject: identified or identifiable natural person, being an identifiable person is one who can be identified, directly
or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical,
physiological, mental, economic, cultural or social identity
information security: preservation of confidentiality, integrity and availability of information
personal data: any information relating to an identified or identifiable natural person ('data subject'); an identifiable
natural person is one who can be identified, directly 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
processing purposes: list of processing purposes (if any) which are beyond those requested by the customer acting as a
controller
vulnerability: weakness of an asset or group of assets, e.g. software or hardware related, that can be exploited by one
or more threats
The following terms are taken from [i.4]:
biometric data: personal data resulting from specific technical processing relating to the physical, physiological or
behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person,
such as facial images or dactyloscopic data
The following terms are taken from [i.2]:
privacy: ability of an individual to be left alone, out of public view, and in control of information about oneself
NOTE: One can distinguish the ability to prevent intrusion in one's physical space ("physical privacy", for
example with regard to the protection of the private home) and the ability to control the collection and
sharing of information about oneself ("informational privacy"). The concept of privacy therefore
overlaps, but does not coincide, with the concept of data protection. The right to privacy is enshrined in
the Universal Declaration of Human Rights (Article 12) as well as in the European Convention of Human
Rights (Article 8), (also, see the definition in [i.4]). The concept of privacy within the context of data
protection entails that personal data is entrusted to the data controller and/or data processor. The data
controller and/or data processor are responsible to keep the data as "private" as possible, in the sense that
data needs to be protected, as if it was not disclosed.
privacy by design: approach that aims to build privacy and data protection up front, into the design specifications and
architecture of information and communication systems and technologies, in order to facilitate compliance with privacy
and data protection principles
NOTE: It is considered that a wider spectrum of approaches may be taken into account for the objective of
privacy by design which includes a visionary and ethical dimension, consistent with the principles and
values enshrined in the EU Charter of Fundamental Rights of the EU. In practice, organizations often
confuse privacy by design with data protection; privacy by design forms the broader concept, part of
which is data protection.
Privacy Enhancing Technologies (PETs): coherent system of information and communication technology (ICT)
measures that protect privacy by eliminating or reducing personal data or by preventing unnecessary and/or undesired
processing of personal data, all without losing the functionality of the information system
NOTE: The use of PETs can help to design information and communication systems and services in a way that
minimizes the collection and use of personal data and facilitates compliance with data protection rules. It
s
...