ISO/IEC 29190:2015

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

• Status: Published
• Publication Date: 09-Aug-2015
• ICS: 35.030 - IT Security
• ICS: 35.040 - Information coding
• Technical Committee: ISO/IEC JTC 1/SC 27 - Information security, cybersecurity and privacy protection
• Drafting Committee: ISO/IEC JTC 1/SC 27/WG 5 - Identity management and privacy technologies
• Current Stage: 9093 - International Standard confirmed
• Start Date: 19-Apr-2021
• Completion Date: 30-Oct-2025

Overview

ISO/IEC 29190:2015 - Privacy capability assessment model provides high-level guidance for organizations to assess their capability to manage privacy-related processes. The standard frames a process-based approach to evaluate how effectively an organization handles personally identifiable information (PII) and integrates privacy capability into operations. It supports continuous improvement by producing measurable outputs such as an overall capability score, KPI metrics, and detailed audit inputs for privacy process improvement.

Key topics

• Methodology & lifecycle: Defines a repeatable assessment cycle and steps for capability assessment, including planning, information collection, analysis, presenting results, and iterative improvement.
• Assessment model design: Guidance on defining a privacy capability assessment model tied to process reference models and evidence collection.
• Capability scale: Uses a structured capability scale (example: a multi-level model) to rate current vs. target capability and support benchmarking and goal setting.
• Key process areas & goals: Identifies clusters of privacy-related activities (key process areas) and the goals that indicate effective implementation.
• Common features & key practices: Describes implementation and institutionalization practices such as commitment, ability, performance, measurement and verification.
• Practical assessment steps: Includes defining target capabilities, identifying privacy activities and processes, preparing criteria for data collection, collecting and analysing evidence, and identifying sub-optimal processes and improvement proposals.
• Outputs: Overall capability score, KPIs for privacy performance, and detailed audit-level findings to inform remediation and strategy.

Applications

ISO/IEC 29190 is practical for:

• Privacy and compliance teams building a privacy capability program or baseline assessment.
• Chief Privacy Officers (CPOs) and senior management seeking decision support for privacy strategy and investment.
• Data protection officers, auditors, and risk managers performing process assessments, compliance gap analysis, or benchmarking.
• Consultants and integrators implementing privacy maturity improvement projects and mapping improvements to business functions. Common uses include benchmarking privacy maturity, prioritizing privacy process improvements, supporting regulatory compliance programs, and informing privacy risk and governance activities.

Who should use it

• Organizations of any size that process PII and need a structured, process-based way to assess privacy capability.
• Stakeholders responsible for privacy strategy, operations, legal compliance, and continuous improvement.

Related standards

• ISO/IEC 29100 - Privacy framework (normative reference)
• ISO/IEC 33001:2015 - Process assessment concepts and terminology
• ISO/IEC 33020:2015 - Process measurement framework for assessment of process capability

Keywords: ISO/IEC 29190:2015, privacy capability assessment model, privacy management, process assessment, privacy maturity, PII, data protection.

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 2015
© ISO/IEC 2015, Published in Switzerland
All rights reserved. Unless otherwise specified, no part of this publication may be reproduced or utilized otherwise in any form
or by any means, electronic or mechanical, including photocopying, or posting on the internet or an intranet, without prior
written permission. Permission can be requested from either ISO at the address below or ISO’s member body in the country of
the requester.
ISO copyright office
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www.iso.org
ii © ISO/IEC 2015 – All rights reserved

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
© ISO/IEC 2015 – All rights reserved iii

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.
iv © ISO/IEC 2015 – All rights reserved

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.
© ISO/IEC 2015 – All rights reserved v

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.
© ISO/IEC 2015 – All rights reserved 1

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.
2 © ISO/IEC 2015 – All rights reserved

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
© ISO/IEC 2015 – All rights reserved 3

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.
4 © ISO/IEC 2015 – All rights reserved

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.
Fu
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