ISO/IEC 29101:2013
(Main)Information technology — Security techniques — Privacy architecture framework
Information technology — Security techniques — Privacy architecture framework
ISO/IEC 29101:2013 defines a privacy architecture framework that specifies concerns for information and communication technology (ICT) systems that process personally identifiable information (PII); lists components for the implementation of such systems; and provides architectural views contextualizing these components. ISO/IEC 29101:2013 is applicable to entities involved in specifying, procuring, architecting, designing, testing, maintaining, administering and operating ICT systems that process PII. It focuses primarily on ICT systems that are designed to interact with PII principals.
Technologies de l'information — Techniques de sécurité — Architecture de référence de la protection de la vie privée
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INTERNATIONAL ISO/IEC
STANDARD 29101
First edition
2013-10-15
Information technology — Security
techniques — Privacy architecture
framework
Technologies de l'information — Techniques de sécurité — Architecture
de référence de la protection de la vie privée
Reference number
ISO/IEC 29101:2013(E)
©
ISO/IEC 2013
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ISO/IEC 29101:2013(E)
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ISO/IEC 29101:2013(E)
Contents Page
Foreword .v
Introduction.vi
1 Scope.1
2 Normative references.1
3 Terms and definitions .1
4 Symbols and abbreviated terms .1
5 Overview of the privacy architecture framework .2
5.1 Elements of the framework.2
5.2 Relationship with management systems.3
6 Actors and PII .3
6.1 Overview.3
6.2 Phases of the PII processing life cycle .4
6.2.1 Collection .4
6.2.2 Transfer .5
6.2.3 Use .5
6.2.4 Storage .6
6.2.5 Disposal.6
7 Concerns .6
7.1 Overview.6
7.2 The privacy principles of ISO/IEC 29100.7
7.3 Privacy safeguarding requirements .7
8 Architectural views.8
8.1 Introduction.8
8.2 Component view.8
8.2.1 Privacy settings layer.9
8.2.2 Identity management and access management layer .12
8.2.3 PII layer.14
8.3 Actor view.21
8.3.1 ICT system of the PII principal .21
8.3.2 ICT system of the PII controller .21
8.3.3 ICT system of the PII processor.22
8.4 Interaction view .23
8.4.1 Privacy settings layer.23
8.4.2 Identity and access management layer.24
8.4.3 PII layer.24
Annex A (informative) Examples of the PII-related concerns of an ICT system.26
Annex B (informative) A PII aggregation system with secure computation .32
Annex C (informative) A privacy-friendly, pseudonymous system for identity and access control
management .39
Annex D (informative) Relating privacy principles to information security controls .45
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ISO/IEC 29101:2013(E)
Figures
Figure 1 — Elements of the privacy architecture framework in context . 2
Figure 2 — The actors and their ICT systems according to ISO/IEC 29101. 4
Figure 3 — The architecture of the ICT system of the PII principal. 21
Figure 4 — The architecture of the ICT system of the PII controller . 22
Figure 5 — The architecture of the ICT system of the PII processor . 23
Figure 6 — The deployment of components in the privacy settings layer. 24
Figure 7 — The deployment of components in the identity and access management layer. 24
Figure 8 — The deployment of components in the PII layer . 25
Figure B.1 — Deployment of the secure computation system . 33
Figure B.2 — The architecture for the PII entry ICT system. 33
Figure B.3 — The architecture for the study coordinator ICT system . 35
Figure B.4 — The architecture for the secure data analysis application . 36
Figure C.1 — An overview of the architecture – actors and their interactions . 40
Figure C.2 — Architecture of the ICT system of the University Credential Issuer. 41
Figure C.3 — Architecture of the ICT system of the student. 42
Figure C.4 — Architecture of the Course Evaluation Application. 43
Tables
Table 1 — Example of the relationship between privacy principles and the components in the privacy settings
layer . 12
Table 2 — Example of the relationship between privacy principles and the components in the identity and
access management layer. 15
Table 3 — Example of the relationship between privacy principles and the components in the PII layer . 20
Table A.1 — Examples of the relationship between concerns and the components in the privacy settings layer
.................................................................................................................................................................... 29
Table A.2 — Examples of the relationship between concerns and the components in the identity and access
management layer. 29
Table A.3 — Examples of the relationship between concerns and the components in the PII layer . 30
Table A.4 — Examples of the relationship between privacy principles and the high-level concerns. 31
Table D.1 — Privacy principles and their corresponding information security controls . 45
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ISO/IEC 29101:2013(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.
International Standards are drafted in accordance with the rules given in the ISO/IEC Directives, Part 2.
The main task of the joint technical committee is to prepare International Standards. Draft International
Standards adopted by the joint technical committee are circulated to national bodies for voting. Publication as
an International Standard requires approval by at least 75 % of the national bodies casting a vote.
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.
ISO/IEC 29101 was prepared by Joint Technical Committee ISO/IEC JTC 1, Information technology,
Subcommittee SC 27, Security techniques.
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ISO/IEC 29101:2013(E)
Introduction
This International Standard describes a high-level architecture framework and associated controls for the
safeguarding of privacy in information and communication technology (ICT) systems that store and process
personally identifiable information (PII).
The privacy architecture framework described in this International Standard
— provides a consistent, high-level approach to the implementation of privacy controls for the processing
of PII in ICT systems;
— provides guidance for planning, designing and building ICT system architectures that safeguard the
privacy of PII principals by controlling the processing, access and transfer of personally identifiable
information; and
— shows how privacy enhancing technologies (PETs) can be used as privacy controls.
This International Standard builds on the privacy framework provided by ISO/IEC 29100 to help an
organization define its privacy safeguarding requirements as they relate to PII processed by any ICT system.
In some countries, privacy safeguarding requirements are understood to be synonymous with data
protection/privacy requirements and are the subject of data protection/privacy legislation.
This International Standard focuses on ICT systems that are designed to interact with PII principals.
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INTERNATIONAL STANDARD ISO/IEC 29101:2013(E)
Information technology — Security techniques — Privacy
architecture framework
1 Scope
This International Standard defines a privacy architecture framework that:
— specifies concerns for ICT systems that process PII;
— lists components for the implementation of such systems; and
— provides architectural views contextualizing these components.
This International Standard is applicable to entities involved in specifying, procuring, architecting, designing,
testing, maintaining, administering and operating ICT systems that process PII.
It focuses primarily on ICT systems that are designed to interact with PII principals.
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 29100:2011, Information technology — Security techniques — Privacy framework
ISO/IEC/IEEE 42010:2011, Systems and software engineering — Architecture description
3 Terms and definitions
For the purposes of this document, the terms and definitions given in ISO/IEC 29100 and
ISO/IEC/IEEE 42010 apply.
4 Symbols and abbreviated terms
The following abbreviations apply to ISO/IEC 29101:
ICT Information and Communication Technology
PET Privacy Enhancing Technology
PII Personally Identifiable Information
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5 Overview of the privacy architecture framework
5.1 Elements of the framework
The privacy architecture framework presented in ISO/IEC 29101 is intended as a technical reference for
developers of ICT systems that process PII. This standard does not set requirements for privacy policies; it
assumes that a privacy policy is in place and that privacy safeguarding requirements have been defined and
that appropriate safeguards will be implemented within the ICT system.
This architecture framework focuses on the protection of PII. Since this is partly a security goal, ICT systems
processing PII should also follow information security engineering guidelines. This architecture framework lists
some information security components that are critical for safeguarding PII processed within ICT systems. The
architecture framework presented is based on the model used in ISO/IEC/IEEE 42010.
The stakeholders related to these concerns are the privacy stakeholders defined in ISO/IEC 29100. They are
discussed in more detail in Clause 6.
The concerns for the architecture framework are described in Clause 7 and include the privacy principles of
ISO/IEC 29100 and privacy safeguarding requirements specific to an ICT system.
The architecture framework is presented as follows:
a. the layers of the technical architecture framework in 8.2 show the architecture from a component
viewpoint. Each layer groups components with a common goal or a similar function;
b. the deployment model in 8.3 shows the architecture framework from a standalone ICT system
viewpoint. Each view shows a grouping of the components based on their deployment in the
stakeholders’ ICT systems; and
c. the views in 8.4 show the architecture framework from an interaction viewpoint. The views illustrate
how the components interact between ICT systems of different stakeholders.
The architecture framework also presents correspondence rules between the concerns and viewpoints
through the use of mapping tables.
ISO/IEC 29101 Other
concerns concerns
affect affect
ISO/IEC 29101 Other
components components
uses
ISO/IEC 29101
actor
ICT system processing PII
Figure 1 — Elements of the privacy architecture framework in context
Figure 1 illustrates the relationship between the elements of the privacy architecture framework. The central
element of the architecture framework is the ICT system being built. An ISO/IEC 29101 actor uses the ICT
system. The design of the ICT systems is affected by both ISO/IEC 29101 concerns and also other concerns.
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ISO/IEC 29101:2013(E)
Examples of other concerns include non-functional requirements that affect the performance, accessibility and
design of the ICT system and do not affect the functional processing of PII. These other concerns are out of
the scope of ISO/IEC 29101.
The ICT system may contain components from the ISO/IEC 29101 privacy architecture framework as well as
other components. These components do not process PII, but instead handle other functionality in the ICT
system like providing accessibility or rendering special user interfaces. Such components are out of the scope
of this standard.
5.2 Relationship with management systems
The use of a management system enables PII controllers and processors to more effectively meet their
privacy safeguarding requirements using a structured approach. This structured approach also provides PII
controllers and processors the ability to measure outcomes and continuously improve the management
system’s effectiveness.
An effective management system is as transparent as possible but still impacts people, processes and
technology. It should be part of the internal control program and risk mitigation strategy of an organization and
its implementation helps to satisfy compliance with data protection and privacy regulations.
6 Actors and PII
6.1 Overview
The actors of the ISO/IEC architecture framework are the privacy stakeholders involved in PII processing
described in ISO/IEC 29100. These actors are
a. the PII principal;
b. the PII controller; and
c. the PII processor.
NOTE The “third party” defined as one of the four categories of the actors in ISO/IEC 29100 is out of the scope of the
architecture framework specified in this standard.
From the deployment viewpoint, the architecture framework is divided into three parts. Each part applies to the
ICT system deployed from the viewpoint of each of these actors.
Figure 2 shows the ICT systems of the actors and the flows of PII between these ICT systems. It illustrates the
logical division of functionality for the architecture framework described in this standard. It is not intended as a
representation of the physical structure, organisation or ownership of ICT system hardware.
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ISO/IEC 29101:2013(E)
Figure 2 — The actors and their ICT systems according to ISO/IEC 29101
An actor may or may not be responsible for building the ICT systems that it uses. For example, the PII
principal may use a system built by and the responsibility of the PII controller or the ICT system of the PII
principal may be a part of the ICT system of the PII controller. Furthermore, the functionality of the ICT system
of the PII principal might be split across different ICT hardware systems owned by the PII principal and the PII
controller. Similarly, the PII controller may provide the ICT system of the PII processor. Business processes in
which ICT systems are employed use a wide range of communication and trust models. The architecture
framework in this international standard builds on an abstraction of these models.
If the PII principal is using a privately owned ICT system, the other privacy stakeholders may impose
requirements on this ICT system. For example, the ICT system of the PII principal may have to meet a
minimum baseline of security requirements to be allowed to connect to the other ICT systems. Other
examples include the use of special security components like hardware authentication tokens, certain
operating system versions or special web browser versions.
For example, in ICT systems employing peer-to-peer communications (communication method,
communication model or communication technology featuring communication in between/among the entities
that are peer to each other without central servers), every application may take the roles of all three listed
actors. Information is both sent and received by each peer, so each peer could be a PII controller or processor
for PII transferred by another party in the role of a PII principal.
In social networking applications, PII may be processed by anyone with access to other people's profiles.
Web-based social networking applications allow all the authorized and possible anonymous users of the
service to process PII provided by the PII principals connected to the social network.
6.2 Phases of the PII processing life cycle
6.2.1 Collection
Many organizations collect information from PII principals. This information can contain PII.
When collecting PII, organizations should always consider the privacy preferences and legal rights of the PII
principal and privacy safeguarding requirements as stated by applicable law. Factors such as the type of PII,
consent given, or any privacy preferences stated need to be considered throughout all stages of processing.
PII should only be collected if it is needed for the declared purposes.
Documentation should be associated with the PII. Examples include, but are not limited to:
a. software tags that state the purpose(s) the PII can be used for;
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b. records describing the purpose(s) that PII can be used for; and
c. records of the consent given and any specific sensitivities that should be observed (e.g., certain PII
categories should be encrypted or deleted after a certain period of time).
Privacy controls should be implemented wherever data is tagged as PII or wherever PII is marked with
additional information concerning the PII principal. It is also important to preserve tags that are relevant to
processing PII during the usage, transfer, storage and disposal phases. If stored PII may have been modified,
it should be validated for accuracy and currency before use.
In addition, PII collection processes should be designed to collect only the PII that is necessary for the
respective transaction. Organizations should take steps to minimize the inadvertent/unintended collection of
PII through data entry systems (e.g., web application forms that allow the entry of any information). The entry
of arbitrary PII should be minimized through the use of context specific display of input fields reducing or
eliminating areas in the web form where this information could be entered (e.g., removing unnecessary check
boxes and free text fields). In addition, the use of fields with predefined entries (e.g., list boxes and drop-down
lists), containing non-PII options, should be considered. When free form text fields are necessary, the User
Interface (UI) should provide:
a. warnings to alert the PII principal not to enter PII other than that which is explicitly asked for and
consented to or required by applicable law;
b. clear indication of those fields where PII is to be entered and what PII should be entered (e.g. name,
address, health information); and
c. clear indication of those fields where PII should not be entered.
6.2.2 Transfer
Transferring, disseminating, or releasing PII to others means that the PII is no longer under the sole control of
the PII principal. Transfer is usually the term given for dissemination of PII from the PII controller or PII
processor to other PII controllers and processors. If PII is transferred from the PII controller to another actor,
transfer is sometimes also referred to as disclosure.
Accountability and responsibility for the transferred PII should be agreed upon and maintained by each party
involved in the PII processing. This agreement should be in writing where required by applicable law.
Furthermore, such agreements will need to be compliant with data protection legislation in the source and
destination domains of the transfers. When relevant and appropriate, or when legally required to do so, the PII
principal should be notified that transfer is taking place and should be informed of the content and purpose of
the transfer. If a dispute occurs between the PII principal and the PII controller or PII processor, records of
relevant PII transfer transactions should be available to assist in resolving any such dispute.
The transfer of sensitive PII should be avoided unless it is necessary to provide a service that the PII
principals has requested, it fulfils a business requirement for offering the requested service, or unless it is
required by law. Some jurisdictions have instituted laws that specifically require formal contractual agreements
that include all privacy safeguarding requirements between the involved parties when PII is transferred outside
a jurisdiction that has a prescribed level of privacy protection. Where cross-border transfers are used,
particular attention should be given to protection measures for the PII being transferred.
Appropriate protection mechanisms should be in place during the transfer of PII. In the case of a digital
transfer, PII should be transmitted over a secure channel or in encrypted form if the transmission is over an
insecure channel. If PII is transferred on physical media, it should be encrypted. If encryption is used, the
encryption key should not be stored or transmitted together with the encrypted PII.
6.2.3 Use
Using PII means any form of PII processing that does not include “collect”, “transfer”, “store”, “archive” or
“dispose”. The privacy principles described in ISO/IEC 29100 (Privacy Framework), as well as some data
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ISO/IEC 29101:2013(E)
protection and privacy laws, may limit the processing of PII if that processing is incompatible with the originally
specified purposes. Therefore, PII should only be processed for the declared purposes for which it was
collected.
If the PII is to be processed for any other purpose that is not covered by applicable law, consent should be
obtained from the PII principal or his agent. The PII principal should be provided a means for contacting the
PII controller or processor in the event there are any questions about any activities about which the PII
principals is unclear.
Where such processing is considered necessary the consent of the PII principal should be obtained unless
otherwise permitted by law. PII principals should be provided clear notice about the specific use of the PII.
Additionally, protection mechanisms appropriate to the usage of PII should be applied as deemed necessary
by a thorough risk analysis. This includes the use of anonymization or pseudonymization techniques prior to
processing and the use of secure computation techniques during processing.
6.2.4 Storage
When it is necessary to store PII, the consent of the PII principal should be obtained, taking into account any
specific measures that may be required by law. In such cases, the PII should be stored only for the amount of
time necessary to achieve the specific business purpose.
PII should be stored with appropriate controls and mechanisms to prevent unauthorized access, modification,
destruction, removal, or other unauthorized use. Such controls include, but are not limited to, encryption,
secret sharing, pseudonymization and anonymization.
Archived PII needs careful attention. The privacy principles state that PII should be retained only as long as
necessary to fulfil the stated purposes and then be securely destroyed or anonymized. However, if the PII
controller or PII processor is required by applicable law to retain P
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