Information technology — Business operational view — Part 12: Privacy protection requirements (PPR) on information life cycle management (ILCM) and EDI of personal information (PI)

This document: — provides method(s) for identifying, in Open-edi modelling technologies and development of scenarios, the additional requirements in business operational view (BOV) specifications for identifying the additional external constraints to be applied to recorded information in business transactions relating to personal information of an individual, as required by legal and regulatory requirements of applicable jurisdictional domains; — integrates existing normative elements in support of privacy and data protection requirements as are already identified in ISO/IEC 14662 and ISO/IEC 15944-1, ISO/IEC 15944-2, ISO/IEC 15944-4, ISO/IEC 15944-5, ISO/IEC 15944-8, ISO/IEC 15944-9, and ISO/IEC 15944-10; — provides overarching, operational ?best practice' statements for associated (and not necessarily automated) processes, procedures, practices and governance requirements that act in support of implementing and enforcing technical mechanisms which support the privacy/data protection requirements necessary for implementation in Open-edi transaction environments; — focuses on the life cycle management of personal information i.e., the contents of SPIs (and their SRIs) related to the business transaction interchanged via EDI as information bundles and their associated semantic components among the parties to a business transaction. NOTE Privacy protection requirements (PPR) on information life cycle management (ILCM) and EDI of personal information as stated in this document serve as a minimum set of ILCM policy and operational requirements for all recorded information pertaining to a business transaction in particular, as well as ILCM implementation in any organization in general. This document does not specify the technical mechanisms, i.e., functional support services (FSV) which are required to support BOV-identified requirements. Detailed exclusions to the scope of this document are provided in Annex H.

Technologies de l'information — Vue opérationnelle d'affaires — Partie 12: Exigences en matière de protection de la vie privée (PPR) relatives à la gestion du cycle de vie de l’information (ILCM) et de l'EDI des renseignements personnels (PI)

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Status
Published
Publication Date
24-May-2020
Current Stage
9092 - International Standard to be revised
Completion Date
22-Jun-2021
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ISO/IEC 15944-12:2020 - Information technology -- Business operational view
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INTERNATIONAL ISO/IEC
STANDARD 15944-12
First edition
2020-05
Information technology — Business
operational view —
Part 12:
Privacy protection requirements
(PPR) on information life cycle
management (ILCM) and EDI of
personal information (PI)
Technologies de l'information — Vue opérationnelle d'affaires —
Partie 12: Exigences en matière de protection de la vie privée (PPR)
relatives à la gestion du cycle de vie de l’information (ILCM) et de
l'EDI des renseignements personnels (PI)
Reference number
ISO/IEC 15944-12:2020(E)
©
ISO/IEC 2020

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ISO/IEC 15944-12:2020(E)

COPYRIGHT PROTECTED DOCUMENT
© ISO/IEC 2020
All rights reserved. Unless otherwise specified, or required in the context of its implementation, 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.
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Published in Switzerland
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ISO/IEC 15944-12:2020(E)

Contents Page
Foreword .v
Introduction .vi
1 Scope . 1
2 Normative references . 1
3 Terms and definitions . 2
4 Abbreviated terms .30
5 Fundamental privacy protection principles .31
5.1 Overview .31
5.2 Primary sources of privacy protection principles .31
5.3 Key eleven (11) privacy protection principles .32
5.4 Link to “consumer protection” and “individual accessibility” requirements (see
ISO/IEC 15944-8:2012, 6.3) .33
5.5 Privacy protection principles in the context of ILCM requirements .34
5.6 Requirement for tagging (or labelling) sets of personal information (SPIs) in
support of privacy protection requirements (PPR) in accordance with ISO/
IEC 15944-8:2012, 5.4 .34
5.7 Requirements for making all personal information (PI) available to the buyer
where the buyer is an individual .34
5.8 Rules governing ILCM aspects of personal information profiles (PIPs) .35
6 Integrated set of information life cycle management (ILCM) principles in support of
information law and privacy protection requirements (PPR) .36
6.1 Primary purpose of Clause 6 .36
6.2 Information life cycle management (ILCM) principles that support privacy
protection requirements (PPR) .38
6.2.1 Compliance with privacy protection requirements (PPR) and associated
information law requirements .38
6.2.2 Direct relevance, informed consent and openness .38
6.2.3 Ensuring that personal information is “under the control of” the
organization throughout its ILCM .40
6.2.4 Limiting use, disclosure and retention .41
6.2.5 Timely, accurate, relevant .43
6.2.6 Data integrity and quality .45
6.2.7 Safeguards for non-authorized disclosure requirements .45
6.2.8 Back-up, retention and archiving .46
6.2.9 Disposition and expungement .47
6.2.10 Organizational archiving .47
6.2.11 Historical, statistical and/or research value .47
6.3 Requirement for tagging (or labelling) data elements in support of privacy
protection requirements (PPR) .49
7 Rules governing ensuring accountability for and control of personal information (PI) .49
7.1 Purpose .49
7.2 Key aspects of Open-edi requirements .49
7.3 Key aspects of “under the control of” .50
7.4 “under the control of” in support of PPR and in an ILCM context .50
7.5 Implementing “under the control of” and accountability .51
8 Rules governing the specification of ILCM aspects of personal information .56
8.1 Overview .56
8.2 Rules governing establishing ILCM responsibilities for personal information (PI) .57
8.3 Rules governing establishing specifications for retention of personal information
(PI) — applicable “SRI retention triggers” .59
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ISO/IEC 15944-12:2020(E)

8.4 Rules governing identification and specification of state changes of personal
information (PI) .62
8.4.1 General requirements .62
8.4.2 Specification of state changes allowed to personal information (PI).63
8.4.3 Specification of store change type .65
8.4.4 Rules governing specification of source of state changes .67
8.5 Rules governing disposition of personal information (PI) .68
8.6 Rules governing the establishment and maintenance of record retention and
disposal schedules (RRDS) for sets of personal information (SPIs) .71
9 Data conversion, data migration and data synchronization .73
9.1 Purpose .73
9.2 Rules governing data conversion of set(s) of personal information (SPI) .74
9.3 Rules governing requirements for data synchronization of sets of personal
information (SPI) .74
10 Rules governing EDI of personal information (PI) between primary ILCM Person,
i.e., the seller, and its “agent”, “third party” and/or “regulator” . .76
10.1 General requirements .76
10.2 ILCM rules pertaining to use of an “agent” .77
10.3 ILCM rules pertaining to use of a “third party” .78
10.4 ILCM rules pertaining to involvement of a “regulator” .78
11 Conformance statement .79
11.1 Overview .79
11.2 Conformance to the ISO/IEC 14662 Open-edi reference model and the ISO/
IEC 15944 series .79
11.3 Conformance to ISO/IEC 15944-12 .80
11.4 Conformance by agents and third parties to ISO/IEC 15944-12 .80
Annex A (normative) Consolidated list of terms and definitions with cultural adaptability:
ISO English and ISO French language equivalency .81
Annex B (normative) Consolidated set of rules in the ISO/IEC 15944 series of particular
relevance to privacy protection requirements (PPR) as external constraints
on business transactions which apply to personal information (PI) in an ILCM
requirements context .96
Annex C (informative) Business transaction model (BTM): Classes of constraints .112
Annex D (informative) Linking ILCM to process phases of a business transaction .116
Annex E (informative) Generic approach to ILCM decisions in a PPR context — ILCM
compliance decision tree .118
Annex F (informative) Generic approach to identification of properties and behaviours of
personal information (PI) as transitory records and their disposition/expungement .121
Annex G (informative) Notes on referential integrity and privacy protection transactional
integrity (PPTI) in Open-edi among IT systems .123
Annex H (informative) Exclusions to the scope of ISO/IEC 15944-12 .125
Annex I (informative) Aspects not currently addressed in this document .127
Annex J (informative) List of parts of the ISO/IEC 15944 series .130
Annex K (informative) Abstract of ISO/IEC 15944-12: ISO English, ISO French and ISO Chinese .131
Bibliography .134
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ISO/IEC 15944-12:2020(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).
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) or the IEC
list of patent declarations received (see http:// patents .iec .ch).
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.
This document was prepared by Joint Technical Committee ISO/IEC JTC 1, Information technology,
Subcommittee SC 32, Data management and interchange.
A list of all parts in the ISO/IEC 15944 series can be found on the ISO website.
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.
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ISO/IEC 15944-12:2020(E)

Introduction
NOTE This document is intended to be used in conjunction with ISO/IEC 14662, ISO/IEC 15944-1,
ISO/IEC 15944-5 and ISO/IEC 15944-8.
0.1  Purpose and overview
Modelling business transactions using scenarios and scenario components includes specifying the
applicable constraints on the data content using explicitly stated rules. ISO/IEC 14662 identifies two
basic classes of constraints, "internal constraints" and "external constraints". External constraints
apply to most business transactions. External constraints have governance over any processing of
personal information including that exchanged among parties to a business transaction and doing so
from an information life cycle management (ILCM) requirements perspective.
Jurisdictional domains are the primary source of external constraints on business transactions (see
Annex C). Privacy protection requirements in turn are a common requirement of most jurisdictional
domains, although they may also result from explicit scenario demands from or on the parties involved
in a business transaction. (Requirements for secrecy or confidentiality are not addressed in this
document, unless they are implicitly needed to apply privacy protection requirements to data).
The focus of this document is on any kind of recorded information concerning identifiable living
individuals as buyers in a business transaction or whose personal information is used in a business
transaction or any type of commitment exchange.
This document describes the added business semantic descriptive techniques needed to support
information life cycle management (ILCM) aspects as part of privacy protection requirements when
modelling business transactions using the external constraints of jurisdictional domains. ILCM aspects
are central to the ability to ensure that privacy protection requirements (PPR) are passed on and
supported among all the parties to a business transaction using EDI.
This document applies to any organization which receives, creates, process, maintains, communicates,
etc. personal information (PI) and, in particular, to those who receive, create, capture, maintain, use,
store or dispose of sets of recorded information (SRIs) electronically. This document applies to private
and public sector activities of Persons irrespective of whether such activities are undertaken on a for-
profit or not-for-profit basis.
This document is intended for use by those organizations to which privacy protection requirements
apply and who therefore need to ensure that the recorded information (electronic records and
transactions) in their IT Systems is trustworthy, reliable and recognized as authentic. Typical users of
this document include
a) managers of private and public sector organizations;
b) IT systems and records/information management system professionals;
c) privacy protection officers (PPOs) and other personnel in organizations, including those responsible
for risk management; and
d) legal professionals and others within an organization responsible for information law compliance
by the organization.
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ISO/IEC 15944-12:2020(E)

0.2  Use of ISO/IEC 14662 and ISO/IEC 15944
1)
0.2.1  ISO/IEC 14662: Open-edi reference model
2)
ISO/IEC 14662 states the conceptual architecture necessary for carrying out electronic business
transactions among autonomous parties. That architecture identifies and describes the need to have
two separate and related views of the business transaction.
The first is the business operational view (BOV). The second is the functional service view (FSV).
Figure 1, taken from ISO/IEC 14662:2010, Figure 1, illustrates the Open-edi environment. (For
definitions of the terms used, see Clause 3.)
Figure 1 — Open-edi reference model environment
ISO/IEC 15944 is a multipart eBusiness standard which is based on and focuses on the BOV perspective
of the ISO/IEC 14662 Open-edi reference model. This document focuses on addressing commonly
definable aspects of external constraints that relate to information life cycle management (ILCM)
3)
in a privacy and data protection context when the source is a jurisdictional domain. A useful
characteristic of external constraints is that, at the sectoral level, national and international levels, etc.,
focal points and recognized authorities often already exist. The rules and common business practices
in many sectoral areas are already known. Use of this document (and related standards) addresses the
transformation of these external constraints (business rules) into specified, registered, and re-useable
scenarios and scenario components.
1)  The Memorandum of Understanding between ISO, IEC, ITU and UN/ECE (2000) concerning standardization
in the field of electronic business is based on this Model. See https:// www .unece .org/ fileadmin/ DAM/ oes/ MOU/
2000/ 24March2000 _IEC _ISO _ITU .pdf.
2)  ISO/IEC 14662 is freely-available at https:// standards .iso .org/ ittf/ PubliclyAvailableStandards/ index .html.
3)  “Privacy protection” is the common set of worldwide requirements. In the European Union, “data protection”
is the equivalent concept (used mainly due to historical reasons). In many other non-European countries,(Australia,
Canada, New Zealand, USA, etc., "privacy" is the legal term used in applicable legislation and pursuant regulations.
This is because "privacy" applies to not just "data" but any form of recorded information containing "personal
information". Thus from an international standards perspective "privacy protection" integrates "privacy" and "data
protection" requirements. In many other countries, "privacy" is the legal term used in applicable legislation and
pursuant regulations.
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ISO/IEC 15944-12:2020(E)

This document is based on ISO/IEC 14662 as well as existing parts of the ISO/IEC 15944 series,
which serve as its key normative references and overall boundaries for the scope of this document.
ISO/IEC 15944-5 and ISO/IEC 15944-8, in particular, serve as the basis for this document as they both
focus on external constraints.
0.2.2  ISO/IEC 15944-1: Business operational view (BOV) – operational aspects of Open-edi for
implementation
ISO/IEC 15944-1 states the requirements of the BOV aspects of Open-edi in support of electronic
business transactions. They are required to be taken into account in the development of business
semantic descriptive techniques for modelling e-business transactions and components thereof as re-
useable business objects. They include:
— Commercial frameworks and associated requirements.
— Legal frameworks and associated requirements.
— Public policy requirements particularly which apply to individuals, i.e., are rights of individuals,
which are of a generic nature such as consumer protection, privacy protection, and accessibility
(see ISO/IEC 15944-5:2008, 6.3).
— Requirements arising from the need to support cultural adaptability. This includes meeting
localization and multilingual requirements, (e.g., as can be required by a particular jurisdictional
domain or desired to provide a good, service and/or right in a particular market). Here one needs
the ability to distinguish, the specification of scenarios, scenario components, and their semantics,
in the context of making commitments, between:
a) the use of unique, unambiguous and linguistically neutral identifiers (often as composite
identifiers) at the information technology interface level among the IT systems of participation
parties on the one hand; and, on the other,
b) their multiple human interface equivalent (HIE) expressions in a presentation form appropriate
to the Persons involved in the making of the resulting commitments.
Figure 2, based on ISO/IEC 15944-1:2011, Figure 3, shows an integrated view of these business
operational requirements. Since the focus of this document is that of external constraints for which
jurisdictional domains are the primary source, these primary sources have been shaded in Figure 2.
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ISO/IEC 15944-12:2020(E)

Figure 2 — Integrated view of business operational requirements with
an external constraints focus
In electronic business transactions, whether undertaken on a for profit or not-for-profit basis, the key
element is commitment exchange among Persons made through their decision-making applications
(DMAs) of their information technology systems (IT Systems, see ISO/IEC 14662:2010, 5.2) acting on
behalf of "Persons". "Persons" are the only entities able to make commitments.
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ISO/IEC 15944-12:2020(E)

The business operational view (BOV) was defined as:
   “perspective of business transactions limited to those aspects regarding the making of business
decisions and commitments among Persons which are needed for the description of a business
transaction”.
   [SOURCE: ISO/IEC 14662:2010, 3.3]
There are three categories of Person as a role player in Open-edi, namely: (1) the Person as "individual",
4)
(2) the Person as "organization", and (3) the Person as "public administration" . There are also three
basic (or primitive) roles of Persons in business transactions, namely: "buyer", "seller", and "regulator".
When modelling business transactions, jurisdictional domains prescribe their external constraints in
the role of "regulator" and execute them as "public administration".
0.2.3  Link to ISO/IEC 15944-5 and ISO/IEC 15944-8
ISO/IEC 15944-5 focuses on external constraints the primary source of which is jurisdictional domains,
at various levels. It also identified a common class of external constraints known as “public policy”,
which apply where and when the “buyer” in a business transaction is an “individual”. It identified three
key sub-types, along with applicable rules; of public policy constraints, namely: “consumer protection”,
“privacy protection” and “individual accessibility” (see ISO/IEC 15944-5:2008, 6.3). In addition,
ISO/IEC 15944-5 specifies how and where (common) external constraints of jurisdictional domains
impact the “Person”, “process”, and “data “components of the business transaction model (BTM), as
introduced in ISO/IEC 15944-1.
ISO/IEC 15944-8, which is based on ISO/IEC 15944-5, focuses on providing a more detailed
identification and specification of the common privacy protection requirements as they apply to any
business transaction where the buyer is an individual.
This document:
— is based on both ISO/IEC 15944-5 and ISO/IEC 15944-8;
— integrates applicable concepts and definitions, principles, rules, etc., found in both ISO/IEC 15944-5
and ISO/IEC 15944-8 (as well as applicable elements of the Open-edi reference model and other
parts of the ISO/IEC 15944 series); and
— focuses on information life cycle management (ILCM) aspects at a more granular level, i.e., that
required to be able to support implementation of the same.
[48]
0.3  Link to Privacy-by-Design (PbD) approach
The overall purpose of the Privacy by Design (PbD) approach is to ensure that privacy protection
requirements (as stated in applicable legal and/or regulatory requirements) are identified and specified
in a systematic and rule-based manner for those developing any IT systems within their organization.
It is noted that although this is the first part in the ISO/IEC 15944 series in which Privacy by Design is
formally mentioned, the PbD approach has always been supported and “imbedded” in the development
of the ISO/IEC 15944 series. The need to comply with and support privacy protection requirements was
already incorporated in ISO/IEC 15944-1:2002, D.1.1.
The development of the ISO/IEC 15944 series fully supports the seven “foundation principles” of the
5)
PbD approach . In particular it provi
...

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