ISO/IEC 29190:2015
(Main)Information technology — Security techniques — Privacy capability assessment model
Information technology — Security techniques — Privacy capability assessment model
ISO 29190:2015 provides organizations with high-level guidance about how to assess their capability to manage privacy-related processes. In particular, it - specifies steps in assessing processes to determine privacy capability, - specifies a set of levels for privacy capability assessment, - provides guidance on the key process areas against which privacy capability can be assessed, - provides guidance for those implementing process assessment, and - provides guidance on how to integrate the privacy capability assessment into organizations operations.
Technologies de l'information — Techniques de sécurité — Modèle d'évaluation de l'aptitude à la confidentialité
General Information
Standards Content (Sample)
INTERNATIONAL ISO/IEC
STANDARD 29190
First edition
2015-08-15
Information technology — Security
techniques — Privacy capability
assessment model
Technologies de l’information — Techniques de sécurité — Modèle
d’évaluation de l’aptitude à la confidentialité
Reference number
ISO/IEC 29190:2015(E)
©
ISO/IEC 2015
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ISO/IEC 29190:2015(E)
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ISO/IEC 29190:2015(E)
Contents Page
Foreword .iv
Introduction .v
1 Scope . 1
2 Normative references . 1
3 Terms and definitions . 1
4 Methodology . 1
4.1 Introduction . 1
4.2 Define a privacy capability assessment model . 2
4.3 Capability scale . 4
4.4 Rate the process’s current capability vs. target capability . 5
4.5 Determine sub-optimal processes . 6
4.6 Identify proposals for changing processes . 6
4.7 Modify processes . 7
5 Capability assessment process . 7
5.1 Introduction . 7
5.2 Plan the assessment . 7
5.3 Identify privacy activities and target capabilities . 8
5.4 Identify privacy-related processes. 9
5.5 Prepare criteria for information collection . 9
5.6 Collect and analyse information .10
5.7 Present results .11
6 Example of a business function approach .11
Bibliography .15
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ISO/IEC 29190:2015(E)
Foreword
ISO (the International Organization for Standardization) and IEC (the International Electrotechnical
Commission) form the specialized system for worldwide standardization. National bodies that are
members of ISO or IEC participate in the development of International Standards through technical
committees established by the respective organization to deal with particular fields of technical
activity. ISO and IEC technical committees collaborate in fields of mutual interest. Other international
organizations, governmental and non-governmental, in liaison with ISO and IEC, also take part in the
work. In the field of information technology, ISO and IEC have established a joint technical committee,
ISO/IEC JTC 1.
The procedures used to develop this document and those intended for its further maintenance are
described in the ISO/IEC Directives, Part 1. In particular the different approval criteria needed for
the different types of document should be noted. This document was drafted in accordance with the
editorial rules of the ISO/IEC Directives, Part 2 (see www.iso.org/directives).
Attention is drawn to the possibility that some of the elements of this document may be the subject
of patent rights. ISO and IEC shall not be held responsible for identifying any or all such patent
rights. Details of any patent rights identified during the development of the document will be in the
Introduction and/or on the ISO list of patent declarations received (see www.iso.org/patents).
Any trade name used in this document is information given for the convenience of users and does not
constitute an endorsement.
For an explanation on the meaning of ISO specific terms and expressions related to conformity
assessment, as well as information about ISO’s adherence to the WTO principles in the Technical
Barriers to Trade (TBT), see the following URL: Foreword — Supplementary information.
The committee responsible for this document is ISO/IEC JTC 1, Information technology, SC 27, Security
techniques.
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ISO/IEC 29190:2015(E)
Introduction
The aim of this International Standard is to provide organizations with high-level guidance about how
to assess the level of their ability (capability) to manage privacy-related processes. This International
Standard focuses on an approach for assessing the efficiency and effectiveness of privacy-related
processes used by organizations.
Guidance on the issue of privacy management needs is multi-faceted as follows:
— The decision support information useful to a senior executive in formulating and executing a privacy
strategy is different from the decision support useful to operational and line-of-business staff even
though their various activities might all ultimately be directed towards the same goal;
— There are likely to be multiple “privacy stakeholders” (that is, parties who have an interest in the way
the organization manages privacy). Those stakeholders might impose very different requirements,
for example, driven by legal and regulatory compliance requirements, but also by inter-related
“good practice” provisions stipulated, for example, by policies, codes-of-conduct, business risk
assessments, audit findings, reputational, and/or financial imperatives and/or personal privacy
preferences.
A broader, good practice context is important because it is possible for an organization to meet its
legal and regulatory compliance obligations and still suffer significant damage if it fails to address the
requirements of the other stakeholders. An assessment of the organization’s capabilities in this area
will need to meet the following principal sets of criteria:
— It needs to provide the organization with information which is useful to the appropriate level or
levels of management;
— It needs to cater for the fact that “capability” needs to be assessed in many different domains (legal
compliance, risk management, reputation, and so on).
This International Standard is aimed at those individuals responsible for directing, managing, and
operating an organization’s privacy management capabilities, or those responsible for advising
the relevant stakeholder group. Thus, the capability model will consider multiple kinds of privacy
stakeholder requirements and will result in guidance to multiple levels of stakeholders, from enterprise
strategists to operational and line-of-business managers.
This International Standard provides guidance for how to set up a capability assessment program
within an organization. It is expected that the management of the organization will need to apply an
iterative and incremental process of improvement using the criteria defined for assessing their privacy
capability. Once a baseline assessment has been identified and a set of targets for improvement of the
organization’s capability has been agreed, then the assessment will need to be periodically repeated in
order to move the organization, over increments, towards the targeted level of capability desired by the
organization.
This International Standard guides organizations towards the production of several different kinds of
output:
— an overall “score” against a simple capability assessment model;
— a set of metrics indicating assessment against key performance indicators;
— the detailed outputs from privacy process management audits and management practices (for
example, assessment against data protection criteria and data custody best practice) for input into
improving capability in these specific areas.
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INTERNATIONAL STANDARD ISO/IEC 29190:2015(E)
Information technology — Security techniques — Privacy
capability assessment model
1 Scope
This International Standard provides organizations with high-level guidance about how to assess their
capability to manage privacy-related processes.
In particular, it
— specifies steps in assessing processes to determine privacy capability,
— specifies a set of levels for privacy capability assessment,
— provides guidance on the key process areas against which privacy capability can be assessed,
— provides guidance for those implementing process assessment, and
— provides guidance on how to integrate the privacy capability assessment into organizations
operations.
2 Normative references
The following documents, in whole or in part, are normatively referenced in this document and are
indispensable for its application. For dated references, only the edition cited applies. For undated
references, the latest edition of the referenced document (including any amendments) applies.
ISO/IEC 29100, Information technology — Security techniques — Privacy framework
ISO/IEC 33001:2015, Information technology — Process assessment — Concepts and terminology
ISO/IEC 33020:2015, Information technology — Process assessment — Process measurement framework
for assessment of process capability
3 Terms and definitions
For the purposes of this document, the terms and definitions given in ISO/IEC 29100 and ISO/IEC 33001
and apply.
4 Methodology
4.1 Introduction
In the current global environment, there is a tendency towards collection, use, disclosure and retention
of more and more personally identifiable information (PII), for purposes ranging from support
for business operations to national security and law enforcement. As is evident from the regular
notification of privacy breaches, much more work is required on the part of organizations to adequately
protect the PII that they are collecting, using, disclosing and retaining, as required by relevant national
regulatory laws.
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One way to develop and refine an organization’s processes is to begin with an assessment of their
existing capabilities in this area. To perform a process assessment in the privacy domain, typically
involves the following activities:
— Define a privacy capability assessment model (see 4.2);
— Define a capability scale (see 4.3);
— Rate the process’s current capability vs. target capability (see 4.4);
— Determine sub optimal processes (see 4.5);
— Identify proposals for changing processes (see 4.6);
— Modify processes (see 4.7);
— Identify the privacy activities and target capability (see 5.1);
— Identify the privacy-related processes (see 5.4);
— Prepare criteria for information collection (see 5.5);
— Collect and analyse information from privacy-related processes (5.6).
An optional additional subsequent action is to map the capability determination (i.e. the target
capability level) to a scale taken from a process assessment model to assist in goal setting, comparative
analysis (i.e. to measure current capability and use as a baseline for assessing an incremental process
improvement target), and continual improvement strategies (i.e. develop a context or business function
improvement strategy to use in planning for a process improvement project).
This International Standard as a whole guides organizations towards the production of several different
kinds of output:
— an over-all “score” against a simple capability assessment such as the example of the six-level model
described in 4.3;
— a set of metrics indicating assessment against key performance indicators in areas such as those
described in the second example in 5.1;
— the detailed outputs from audit and management disciplines in specific areas of privacy management
(for example, assessment against data protection criteria and data custody best practice).
4.2 Define a privacy capability assessment model
ISO/IEC 3300x is a suite of International Standards that has been developed by the ISO/IEC JTC
1/SC 7 Software and system engineering committee. It provides information on the concepts of process
assessment and its use in process improvement and process capability determination. ISO/IEC 29190
uses the concepts of ISO/IEC 3300x for the assessment of privacy capability.
For the purposes of this International Standard, a process assessment model is related to one or more
process reference models. It forms the basis for the collection of evidence and rating of a process quality
characteristic. The relationships within the process assessment model is shown in Figure 1.
The information collected during assessments should be referenced against this model in order to
determine a relative capability.
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Figure 1 — Process assessment model relationships
Privacy capability assessment assumes a cycle of continuous improvement, as shown in Figure 2.
Figure 2 — Lifecycle of privacy capability assessment
With some refinement, a capability assessment model can be used to assess how competent an
organization is with respect to, for instance, protecting PII as required by relevant national regulatory
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laws. A capability assessment model can also be used as a benchmark for comparing different
organizations where there is something that can be used as a basis for comparison. For the purposes
of this International Standard, the basis for comparison should be the organizations’ processes for
handling PII in a manner compliant with national regulatory laws and relevant good practice.
A capability assessment model typically involves the following aspects:
a) Capability Levels: a layered framework providing a progression to the discipline needed to engage
in continuous improvement. It is important to note that an organization needs to develop the ability
to assess the impact of a new practice, technology or tool on their business activities. Hence it is not
a matter of adopting these rather it is a matter of determining how innovative efforts influence
existing practices.
This empowers projects, teams, and organizations by giving them the foundation to support
reasoned choice.
b) Key Process Areas: this identifies a cluster of related activities which, when performed collectively,
achieve a set of goals considered important.
c) Goals: the goals of a key process area summarize the states that need to exist for each key process
area to have been implemented in an effective and lasting way. The extent to which the goals have
been accomplished is an indicator how well the organization has established that capability level.
The goals signify the scope, boundaries and intent of each key process area.
d) Common Features: common features include practices that implement and institutionalize a key
process area.
Common features are frequently defined as: Commitment to Perform; Ability to Perform; Activities
Performed, Measurement and Analysis, and Verifying Implementation.
e) Key Practices: the key practices describe the elements of infrastructure and practice that contribute
most effectively to the implementation and institutionalization of the key process areas.
The objective of this International Standard is to provide guidance to organizations on assessing
how mature they are with respect to compliance with privacy and data protection legislation and
relevant good practice. This International Standard focusses on assessing those activities that
organizations should carry out in order to demonstrate such compliance.
4.3 Capability scale
A process assessment is a disciplined evaluation of an organizational unit’s processes against a process
assessment model. A processes assessment aims to determine how well the processes in the current
practice are performing relative to their goals and to locate areas of weakness.
A capability assessment model needs to be a structured collection of elements that describe the
characteristics of effective processes. In the form documented by ISO 33020, the model allows an
organization to rate its processes on the following capability scale:
Level 0: Incomplete process
— The process is not implemented, or fails to achieve its process purpose. At this level there is little or
no evidence of any systematic achievement of the process purpose.
Level 1: Performed process
— The implemented process achieves its process purpose.
Level 2: Managed process
— The performed process is implemented in a managed fashion (planned, monitored and adjusted)
and its work products are appropriately established, controlled and maintained.
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Level 3: Established process
— The managed process is implemented using a defined process capable of achieving its process
outcomes.
Level 4: Predictable process
— The established process operates within defined limits to achieve its process outcomes.
Level 5: Innovating process
— The predictable process is continuously improved to respond to change aligned to organizational
goals.
This capability scale provides a layered framework to advance the disciplines needed to engage in
continuous improvement. This empowers projects, teams, and organizations by giving them the
foundation to support reasoned choice.
With profiling, the model can be used to assess an organization’s capability with respect to, for instance,
protecting PII as required by relevant national regulatory laws.
A capability model can also be used as a benchmark for comparing different organizations once there
is a common model that can be used as a basis for comparison. For the purposes of this International
Standard, the basis for comparison is the organizations’ processes for handling PII in a manner
compliant with national regulatory laws and relevant good practice.
There is benefit in including this capability scale, as it is of more use (to the corporate executive
responsible) than some of the more detailed analysis and audit results which one could expect from
assessment at the “key performance indicator” level (see Annex A).
4.4 Rate the process’s current capability vs. target capability
The extent of achievement of a capability determined in accordance with 4.3 is assessed based on a
four-point rating scale. In each case, the target capability against which assessments are made should
be as defined in corporate privacy policies and practices:
Not achieved (0 - 15%);
— There is little or no evidence of achievement of the defined capability in the assessed process.
Partially achieved (>15% - 50%);
— There is some evidence of an approach to, and some achievement of, the defined capability in the
assessed process. Some aspects of achievement of the capability may be unpredictable.
Largely achieved (>50%- 85%);
— There is evidence of a systematic approach to and significant achievement of, the defined capability
in the assessed process. Some weakness related to this capability may exist in the assessed process.
Fully achieved (>85% - 100%).
— There is evidence of a complete and systematic approach to and full achievement of the defined
capability in the assessed process. No significant weaknesses related to this capability exist in the
assessed process.
The rating should be based upon information collected against the practice indicators, which
demonstrate fulfilment of the process capabilities.
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A rating should be identified for each of the capabilities applicable to the target privacy capability level.
This should involve rating each of the capabilities that are assigned to the target privacy capability level
(e.g. for ‘Managed’ there are:
— Process Performance;
— Performance Management;
— Work Product Management.)
This will result in not a singular rating result but rather a multi-dimensional rating result. Where
a complex set of results are provided to the organization’s management, it may be necessary to
include explanations and descriptions of the information provided in order to ensure an appropriate
level of understanding. In some circumstances, a summary report should be provided. This adds to
the importance of conducting a thorough assessment planning step (see 5.1) prior to conducting the
assessment.
As well as defining a suitable scope, participants and assessment team as a part of the definition of the
assessment constraints for a privacy capability assessment, the sponsor and competent assessor need
to agree on the types of objective evidence and the terms for each indicators to be used so that reporting
of results is consistent and objective.
4.5 Determine sub-optimal processes
Sub-optimal processes (e.g. gaps) should then be identified from the existence of gaps between a target
capability and an assessed capability. A gap is said to exist:
— if the target capability requires that a particular capability be Fully achieved, while the assessed
capability is less than Fully achieved;
— if the target capability requires that a particular capability be Largely achieved, while the assessed
capability is less than Largely achieved.
The potential consequence of a gap depends upon the capability level and process capability where the
gap occurs.
The assessment should also identify specific areas of process major and minor non-conformance and
other recommendations for improvement, as sources for determining sub-optimal processes. It is
also important that findings in an assessment should be based on documented evidence or the lack of
required evidence to support achieving target level for a business process.
4.6 Identify proposals for changing processes
The business goals of an organization in relation to privacy are often centred around:
— providing the PII principal with the capacity to perform their rights regarding their PII;
— achieving compliance with legislation and regulation.
These key management concerns become drivers that initiate process improvement throughout the
organization with objectives of:
— improving the processing of PII;
— ensuring the transparency of processing of PII;
— decreasing development and maintenance costs of systems that manage PII;
— reducing the risk of breaches of privacy;
— improving the processes for dealing with privacy breaches.
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From an analysis of the organization’s business goals and existing stimuli for improvement, the
objectives of process improvement are set. These objectives should be used to identify which sub-
optimal processes identified in 4.5 needs to be selected for modification.
4.7 Modify processes
The modification of the sub-optimal processes should be implemented as a project in its own right, with
defined sponsorship, project management, budget, milestones and accountability. In short, the project
should be managed according to a project management process, aligned to the Process Assessment
Model being used.
The objectives of the modifications should be to improve the capability based on the existing capabilities.
5 Capability assessment process
5.1 Introduction
This section describes the process of assessing the capability of an organization or process to manage
their privacy-related processes. The process consists of the following steps:
— plan the assessment;
— identify privacy activities and target capabilities;
— identify privacy-related processes;
— prepare criteria for information collection;
— collect and analyse information;
— present results.
5.2 Plan the assessment
The first stage in carrying out a process capability assessment is the planning of the assessment. This
typically involves a number of steps:
— identify the target of the assessment;
— identify the purpose and objectives for the assessment, including the level of capability required;
— identify a project sponsor and a lead assessor and define their roles;
— determine the approach (for example that given in this International Standard);
— determine whether other International Standards (such as ISO/IEC 9000) are relevant to the
assessment;
— determine the assessment deliverables (such as a status report, a list of sub-optimal processes
and/or proposals for process modification);
— identify and train the assessment team (to include the relevant process owners);
— communicate purpose and plan to those to be assessed;
— schedule and run the assessment interviews;
— agree an assessment timetable.
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5.3 Identify privacy activities and target capabilities
This process is a cluster of related activities which, when performed collectively, identify a set of
privacy-related procedures. This process offers a focus for applying target capabilities that need to be
implemented in an effective and lasting manner. The extent to which this process has been accomplished
is an indicator of how much capability the organization has established at each capability level. This
also signifies the scope, boundaries and intent of each privacy-related process.
There are numerous approaches to assembling these processes and it is outside of the scope of this
International Standard to prescribe a single approach. However, to help readers to better understand
this requirement, two examples of possible approaches are shown below:
First example, a context approach:
— conceptual framework;
— legal context;
— implementation readiness;
— process readiness;
— regulatory and compliance criteria;
— adoption culture/behaviour.
Second example, a business function approach:
— Inventory – identification of business lines, supports functions dealing with PII processing, drawing
up of an inventory of the corresponding processing of PII (how the PII is processed, accessed and
transmitted);
— Legal Analysis — definition of the organization’s liability (P
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