ISO/IEC 29100
(Main)Information technology — Security techniques — Privacy framework
Information technology — Security techniques — Privacy framework
ISO/IEC 29100:2011 provides a privacy framework which specifies a common privacy terminology; defines the actors and their roles in processing personally identifiable information (PII); describes privacy safeguarding considerations; and provides references to known privacy principles for information technology. ISO/IEC 29100:2011 is applicable to natural persons and organizations involved in specifying, procuring, architecting, designing, developing, testing, maintaining, administering, and operating information and communication technology systems or services where privacy controls are required for the processing of PII.
Technologies de l'information — Techniques de sécurité — Cadre privé
La présente Norme internationale fournit un cadre pour la protection de la vie privée qui: — spécifie une terminologie commune relative à la protection de la vie privée; — définit les acteurs et leurs rôles dans le traitement de données à caractère personnel (DCP); — décrit les éléments à prendre en considération pour la protection de la vie privée; et — fournit des références à des principes connus de protection de la vie privée pour les technologies de l'information. La présente Norme internationale s'applique aux personnes physiques et aux organismes participant à la spécification, à la fourniture, à l'architecture, à la conception, au développement, aux essais, à la maintenance, à l'administration et à l'exploitation des systèmes ou services de technologies de l'information et de la communication dans lesquels des mesures de protection de la vie privée sont requises pour le traitement de DCP.
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FINAL
INTERNATIONAL ISO/IEC
DRAFT
STANDARD FDIS
29100
ISO/IEC JTC 1/SC 27
Information technology — Security
Secretariat: DIN
techniques — Privacy framework
Voting begins on:
2023-06-20
Technologies de l'information — Techniques de sécurité — Cadre
privé
Voting terminates on:
2023-08-15
RECIPIENTS OF THIS DRAFT ARE INVITED TO
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BEING ACCEPTABLE FOR INDUSTRIAL, TECHNO-
ISO/IEC FDIS 29100:2023(E)
LOGICAL, COMMERCIAL AND USER PURPOSES,
DRAFT INTERNATIONAL STANDARDS MAY ON
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LIGHT OF THEIR POTENTIAL TO BECOME STAN-
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NATIONAL REGULATIONS. © ISO/IEC 2023
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ISO/IEC FDIS 29100:2023(E)
FINAL
INTERNATIONAL ISO/IEC
DRAFT
STANDARD FDIS
29100
ISO/IEC JTC 1/SC 27
Information technology — Security
Secretariat: DIN
techniques — Privacy framework
Voting begins on:
Technologies de l'information — Techniques de sécurité — Cadre
privé
Voting terminates on:
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BEING ACCEPTABLE FOR INDUSTRIAL, TECHNO
ISO/IEC FDIS 29100:2023(E)
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LOGICAL, COMMERCIAL AND USER PURPOSES,
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© ISO/IEC 2023 – All rights reserved
NATIONAL REGULATIONS. © ISO/IEC 2023
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ISO/IEC FDIS 29100:2023(E)
Contents Page
Foreword .iv
Introduction .v
1 Scope . 1
2 Normative references . 1
3 Terms and definitions . 1
4 Abbreviated terms . 4
5 Basic elements of the privacy framework. 4
5.1 Overview of the privacy framework . 4
5.2 Actors and roles . 5
5.2.1 General . 5
5.2.2 PII principals . 5
5.2.3 PII controllers. 5
5.2.4 PII processors . 5
5.2.5 Third parties . 5
5.3 Interactions . 6
5.4 Recognizing PII . 7
5.4.1 General . 7
5.4.2 Identifiers . 7
5.4.3 Other distinguishing characteristics . 7
5.4.4 Information which is or can be linked to a PII principal . 8
5.4.5 Pseudonymous data . 8
5.4.6 Metadata . 9
5.4.7 Unsolicited PII . 9
5.4.8 Sensitive PII . 9
5.5 Privacy safeguarding requirements . 10
5.5.1 General . 10
5.5.2 L egal and regulatory factors . 11
5.5.3 Contractual factors . 11
5.5.4 Business factors .12
5.5.5 Other factors .12
5.6 Privacy policies .13
5.7 Privacy controls . .13
6 The privacy principles of this document.14
6.1 Overview of privacy principles . 14
6.2 Consent and choice . 14
6.3 Purpose legitimacy and specification . 15
6.4 Collection limitation .15
6.5 Data minimization . 16
6.6 Use, retention and disclosure limitation . 16
6.7 Accuracy and quality . 16
6.8 Openness, transparency and notice . 17
6.9 Individual participation and access . 17
6.10 Accountability . 18
6.11 Information security . 19
6.12 Privacy compliance . . . 19
Annex A (informative) Correspondence between ISO/IEC 29100 concepts and ISO/
IEC 27000 concepts .20
Bibliography .21
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ISO/IEC FDIS 29100:2023(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.
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 or
www.iec.ch/members_experts/refdocs).
ISO and IEC draw attention to the possibility that the implementation of this document may involve the
use of (a) patent(s). ISO and IEC take no position concerning the evidence, validity or applicability of
any claimed patent rights in respect thereof. As of the date of publication of this document, ISO and IEC
had not received notice of (a) patent(s) which may be required to implement this document. However,
implementers are cautioned that this may not represent the latest information, which may be obtained
from the patent database available at www.iso.org/patents and https://patents.iec.ch. ISO and IEC shall
not be held responsible for identifying any or all such patent rights.
Any trade name used in this document is information given for the convenience of users and does not
constitute an endorsement.
For an explanation of the voluntary nature of standards, the meaning of ISO specific terms and
expressions related to conformity assessment, as well as information about ISO's adherence to
the World Trade Organization (WTO) principles in the Technical Barriers to Trade (TBT) see
www.iso.org/iso/foreword.html. In the IEC, see www.iec.ch/understandingstandards.
This document was prepared by Joint Technical Committee ISO/IEC JTC 1, Information technology,
Subcommittee SC 27, Information security, cybersecurity and privacy protection.
This second edition cancels and replaces the first edition (ISO/IEC 29100:2011), of which it constitutes
a minor revision. It also incorporates the Amendment ISO/IEC 29100:2011/Amd 1:2018.
The main changes are as follows:
— Clause 2 (normative references) has been added and crossreferences have been updated throughout
the document;
— replaced the term "secondary use” with “secondary purpose” in Clause 3;
— bibliography has been updated.
Any feedback or questions on this document should be directed to the user’s national standards
body. A complete listing of these bodies can be found at www.iso.org/members.html and
www.iec.ch/nationalcommittees.
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ISO/IEC FDIS 29100:2023(E)
Introduction
This document provides a high-level framework for the protection of personally identifiable information
(PII) within information and communication technology (ICT) systems. It is general in nature and
places organizational, technical, and procedural aspects in an overall privacy framework.
The privacy framework is intended to help organizations define their privacy safeguarding
requirements related to PII within an ICT environment by:
— specifying a common privacy terminology;
— defining the actors and their roles in processing PII;
— describing privacy safeguarding requirements; and
— referencing known privacy principles.
Due to the increasing number of information and communication technologies that process PII, it is
important to have international information security standards that provide a common understanding
for the protection of PII. This document is intended to enhance existing security standards by adding a
focus relevant to the processing of PII.
The increasing commercial use and value of PII, the sharing of PII across jurisdictions, and the growing
complexity of ICT systems, can make it difficult for an organization to ensure privacy and to achieve
compliance with the various applicable laws. Privacy stakeholders can prevent uncertainty and distrust
from arising by handling privacy matters properly and avoiding cases of PII misuse.
Use of this document will:
— aid in the design, implementation, operation, and maintenance of ICT systems that handle and
protect PII;
— spur innovative solutions to enable the protection of PII within ICT systems; and
— improve organizations’ privacy programs through the use of best practices.
The privacy framework provided within this document can serve as a basis for additional privacy
standardization initiatives, such as for:
— a technical reference architecture;
— the implementation and use of specific privacy technologies and overall privacy management;
— privacy controls for outsourced data processes;
— privacy risk assessments; or
— specific engineering specifications.
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FINAL DRAFT INTERNATIONAL STANDARD ISO/IEC FDIS 29100:2023(E)
Information technology — Security techniques — Privacy
framework
1 Scope
This document provides a privacy framework which:
— specifies a common privacy terminology;
— defines the actors and their roles in processing personally identifiable information (PII);
— describes privacy safeguarding considerations;
— provides references to known privacy principles for information technology.
This document is applicable to natural persons and organizations involved in specifying, procuring,
architecting, designing, developing, testing, maintaining, administering, and operating information and
communication technology systems or services where privacy controls are required for the processing
of PII.
2 Normative references
There are no normative references in this document
3 Terms and definitions
For the purposes of this document, the following terms and definitions apply.
ISO and IEC maintain terminology databases for use in standardization at the following addresses:
— ISO Online browsing platform: available at https:// www .iso .org/ obp
— IEC Electropedia: available at https:// www .electropedia .org/
3.1
anonymity
characteristic of information that does not permit a personally identifiable information principal (3.9) to
be identified directly or indirectly
3.2
anonymization
process by which personally identifiable information (PII) (3.7) is irreversibly altered in such a way that
a PII principal (3.9) can no longer be identified directly or indirectly, either by the PII controller alone or
in collaboration with any other party
3.3
anonymized data
data that has been produced as the output of a personally identifiable information (3.7) anonymization
(3.2) process
3.4
consent
personally identifiable information (PII) principal’s (3.9) freely given, specific and informed agreement to
the processing of their PII
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ISO/IEC FDIS 29100:2023(E)
3.5
identifiability
condition which results in a personally identifiable information (PII) principal (3.9) being identified,
directly or indirectly, on the basis of a given set of PII
3.6
opt-in
process or type of policy whereby the personally identifiable information (PII) principal (3.9) is required
to take an action to express explicit, prior consent (3.4) for their PII to be processed for a particular
purpose
Note 1 to entry: A different term that is often used with the privacy principle "consent and choice" is “opt-out”.
It describes a process or type of policy whereby the PII principal is required to take a separate action in order
to withhold or withdraw consent, or oppose a specific type of processing. The use of an opt-out policy presumes
that the PII controller has the right to process the PII in the intended way. This right can be implied by some
action of the PII principal different from consent (e.g. placing an order in an online shop).
3.7
personally identifiable information
PII
information that (a) can be used to establish a link between the information and the natural person to
whom such information relates, or (b) is or might be directly or indirectly linked to a natural person
Note 1 to entry: The “natural person” in the definition is the PII principal (3.9). To determine whether a PII
principal is identifiable, account should be taken of all the means which can reasonably be used by the privacy
stakeholder holding the data, or by any other party, to establish the link between the set of PII and the natural
person.
3.8
PII controller
privacy stakeholder (or privacy stakeholders) that determines the purposes and means for processing
personally identifiable information (PII) (3.7) other than natural persons who use data for personal
purposes
Note 1 to entry: A PII controller sometimes instructs others [e.g. PII processors (3.10)] to process PII on its behalf
while the responsibility for the processing remains with the PII controller.
3.9
PII principal
data subject
natural person to whom the personally identifiable information (PII) (3.7) relates
3.10
PII processor
privacy stakeholder that processes personally identifiable information (PII) (3.7) on behalf of and in
accordance with the instructions of a PII controller (3.8)
3.11
privacy breach
situation where personally identifiable information (3.7) is processed in violation of one or more relevant
privacy safeguarding requirements
3.12
privacy control
measure that treats privacy risks by reducing their likelihood or their consequences
Note 1 to entry: Privacy controls include organizational, physical and technical measures, e.g. policies,
procedures, guidelines, legal contracts, management practices or organizational structures.
Note 2 to entry: Control is also used as a synonym for safeguard or countermeasure.
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ISO/IEC FDIS 29100:2023(E)
3.13
privacy enhancing technology
PET
privacy control (3.12), consisting of information and communication technology (ICT) measures,
products, or services that protect privacy by eliminating or reducing personally identifiable information
(PII) (3.7) or by preventing unnecessary and/or undesired processing of PII, all without losing the
functionality of the ICT system
Note 1 to entry: Examples of PETs include, but are not limited to, anonymization (3.2) and pseudonymization
(3.22) tools that eliminate, reduce, mask, or de-identify PII or that prevent unnecessary, unauthorized and/or
undesirable processing of PII.
Note 2 to entry: Masking is the process of obscuring elements of PII.
3.14
privacy policy
overall intention and direction, rules and commitment, as formally expressed by the personally
identifiable information (PII) controller (3.8) related to the processing of PII (3.7) in a particular setting
3.15
privacy preference
specific choices made by a personally identifiable information (PII) principal (3.9) about how their PII
(3.7) should be processed for a particular purpose
3.16
privacy principle
shared value governing the privacy protection of personally identifiable information (PII) (3.7) when
processed in information and communication technology systems
3.17
privacy risk
effect of uncertainty on privacy
Note 1 to entry: Risk is defined as the “effect of uncertainty on objectives” in ISO Guide 73 and ISO 31000.
Note 2 to entry: Uncertainty is the state, even partial, of deficiency of information related to, understanding or
knowledge of, an event, its consequence, or likelihood.
3.18
privacy impact assessment
privacy risk assessment
overall process of identifying, analysing, evaluating, consulting, communicating and planning
the treatment of potential privacy impacts with regard to the processing of personally identifiable
information (3.7), framed within an organization’s broader risk management framework
3.19
privacy safeguarding requirement
requirement that an organization takes into account when processing personally identifiable information
(PII) (3.7) with respect to the privacy protection of PII
3.20
privacy stakeholder
natural or legal person, public authority, agency or any other body that can affect, be affected by, or
perceive themselves to be affected by a decision or activity related to personally identifiable information
(PII) (3.7) processing
3
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ISO/IEC FDIS 29100:2023(E)
3.21
processing of PII
operation or set of operations performed upon personally identifiable information (PII) (3.7)
Note 1 to entry: Examples of processing operations of PII include, but are not limited to, the collection, storage,
alteration, retrieval, consultation, disclosure, anonymization (3.2), pseudonymization (3.22), dissemination or
otherwise making available, deletion or destruction of PII.
3.22
pseudonymization
process applied to personally identifiable information (PII) (3.7) which replaces identifying information
with an alias
Note 1 to entry: Pseudonymization can be performed either by PII principals (3.9) themselves or by PII controllers
(3.8). Pseudonymization can be used by PII principals to consistently use a resource or service without disclosing
their identity to this resource or service (or between services), while still being held accountable for that use.
Note 2 to entry: Pseudonymization does not rule out the possibility that there can be (a restricted set of) privacy
stakeholders (3.20) other than the PII controller of the pseudonymized data which are able to determine the PII
principal’s identity based on the alias and data linked to it.
3.23
sensitive PII
category of personally identifiable information (PII) (3.7), either whose nature is sensitive, such as those
that relate to the PII principal’s (3.9) most intimate sphere, or that can have a significant impact on the
PII principal
Note 1 to entry: In some jurisdictions or in specific contexts, sensitive PII is defined in reference to the nature of
the PII and can consist of PII revealing the racial origin, political opinions or religious or other beliefs, personal
data on health, sex life or criminal convictions, as well as other PII that can be defined as sensitive.
3.24
third party
privacy stakeholder (3.20) other than the personally identifiable information (PII) principal (3.9), the PII
controller (3.8) and the PII processor (3.10), and the natural persons who are authorized to process the
data under the direct authority of the PII controller or the PII processor
4 Abbreviated terms
ICT information and communication technology
PET privacy enhancing technology
PII personally identifiable information
5 Basic elements of the privacy framework
5.1 Overview of the privacy framework
The following components relate to privacy and the processing of PII in ICT systems and make up the
privacy framework described in this document:
— actors and roles;
— interactions;
— recognizing PII;
— privacy safeguarding requirements;
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ISO/IEC FDIS 29100:2023(E)
— privacy policies;
— privacy controls.
For the development of this privacy framework, concepts, definitions and recommendations from other
official sources have been taken into consideration. These sources can be found in Reference [3].
NOTE In order to make it easier to use ISO/IEC 27000 and related international standards concerning ISMS
[4]-[25]
in the specific context of privacy and to integrate privacy concepts in the ISO/IEC 27000 context, Table A.1
shows how the concepts from References [4] to [25] correspond with the concepts used in this document.
5.2 Actors and roles
5.2.1 General
For the purposes of this document, it is important to identify the actors involved in the processing
of PII. There are four types of actors who can be involved in the processing of PII: PII principals, PII
controllers, PII processors and third parties.
5.2.2 PII principals
PII principals provide their PII for processing to PII controllers and PII processors and, when it is not
otherwise provided by applicable law, they give consent and determine their privacy preferences for
how their PII should be processed. PII principals can include, for example, an employee listed in the
human resources system of a company, the consumer mentioned in a credit report, and a patient listed
in an electronic health record. It is not always necessary that the respective natural person is identified
directly by name in order to be considered a PII principal. If the natural person to whom the PII relates
can be identified indirectly (e.g. through an account identifier, social security number, or even through
the combination of available attributes), he or she is considered to be the PII principal for that PII set.
5.2.3 PII controllers
A PII controller determines why (purpose) and how (means) the processing of PII takes place. The PII
controller should ensure adherence to the privacy principles in this framework during the processing
of PII under its control (e.g. by implementing the necessary privacy controls). There can be more than
one PII controller for the same PII set or set of operations performed upon PII (for the same or different
legitimate purposes). In this case, the different PII controllers shall work together and make the
necessary arrangements to ensure the privacy principles are adhered to during the processing of PII. A
PII controller can also decide to have all or part of the processing operations carried out by a different
privacy stakeholder on its behalf. It is expected that PII controllers carefully
...
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