Privacy Assurance

(1)

Frank Dawson/Nokia, Director information privacy compliance

Ecole Polytech Nice – Sophia Antipolis 2015-01-23

Privacy Engineering &

Privacy Assurance Lecture

(2)

Privacy Engineering & Assurance

1. WHAT – Information Privacy

− Terminology

− Roles within the Privacy Framework

− Privacy Principles

− Essence of privacy

− Privacy data lifecycle

− Personally Identifiable Information and Identifiability

2. HOW – Compliance or Accountability

− Elements of an ACCOUNTABLE privacy program

− Privacy activities across the product life cycle

− Privacy program roles &

responsibilies

3. HOW - Privacy Engineering & Assurance simplified

− Applying Privacy Engineering

− Privacy Engineering steps

− Privacy Assurance steps

− Design activities across the product life cycle

− Privacy impact assessment

− Privacy risk management

− Assessing privacy maturity

− Privacy related business processes

4. Use case

− Initial description

− Assessment planning

− Kickoff meeting

− Use case & DFD

− Data inventory & classification

− Threat analysis

− Security considerations

− Privacy Policy template

− Assessment findings

− Final assessment review

(3)

Information privacy

The right of an individual to control the processing of their personal data such that there is:

No hidden, unwanted, uncontrolled, excessive or insecure

Collection, processing and disclosure of consumer’s personal data

(4)

EU GDPR and ISO 29100

• TheEU data protection regulations will soon be based on the proposed General Data Protection Regulation

• Potential harmonizing DP effect across EU businesses

• ISO 29100 defines a Privacy Framework that reflects many of the proposed components of the GDPR

• The PDF of the standard is freely available here

• Privacy Framework includes:

• Terminology

• Roles and interactions

• Recognizing PII

• Privacy safeguarding requirements

• Privacy policy

• Privacy controls

• Privacy principles

(5)

Terminology (29100 §2)

• Identifiability - condition which results in a PII principal being identified, directly or indirectly, on the basis of a given set of PII

• Personally Identifiable Information (PII) - any

information that (a) can be used to identify the PII principal to whom such information relates, or (b) is or might be directly or indirectly linked to a PII principal

• PII Controller - privacy stakeholder (or privacy

stakeholders) that determines the purposes and means for

processing personally identifiable information (PII) other than

natural persons who use data for personal purposes

• PII Principal - natural person to whom the personally identifiable information (PII) relates

• PII Processor - privacy stakeholder that processes personally

identifiable information (PII) on behalf of and in accordance with the instructions of a PII controller

• Privacy Breach - situation where PII is processed in violation of one or more relevant privacy safeguarding requirements

• Privacy Safeguarding Requirements - set of

requirements an organization has to take into account when

processing personally identifiable information (PII) with respect to the privacy protection of PII

(6)

Roles within the privacy framework

• DPA, Data Privacy Authority, Information Privacy

Commissioner, etc is the

independent legal authority for administering privacy rules within a country

• The consumer is the PII Principal

• The PII Controller is entity that determines purposes and means of processing consumer’s

personal data and is RESPONSIBLE for data

processing of data subject’s PII

• The PII Processor performs

information processing on behalf of the Data Controller

Data Protection Authority (DPA)

PII

Principal PII

Processor ControllerPII

Sometimes a reference is also made to a Third Party, which can be viewed as outside this privacy

framework, but the responsibility of the Data

Controller.

(7)

Privacy Principles (ISO 29100 §5)

# Principle Description

1 Consent and choice PII Principal has choice on and has Opt-In to PII processing 2 Purpose legitimacy and specification Processing complies with laws, giving notice before

processing

3 Collection limitation Within laws and necessary for specified purposes 4 Data minimization Minimize the processing of PII

5 Use, retention and disclosure limitation Also applies to limitation on cross-border transfers 6 Accuracy and quality Measure to assure validity and correctness of PII

processing

7 Openness, transparency and notice Clear, complete and accessible information on PII processing

8 Individual participation and access PII Principal access to review their PII and correct inaccuracies

9 Accountability Demonstrate care in duty toward PII Principal for PII stewardship

10 Information security Protecting PII under its authority with appropriate controls 11 Privacy compliance Verifying and demonstrating adherence to laws with

internal or 3rd party audits

(8)

Essence of privacy

Privacy emerges from personally identifiable data

Personal data or information

• Any information relating to an identified or identifiable natural person, an individual

+

Identifiability

• (Nymity) The measure of the degree that personal data can be associated with an individual

(9)

Privacy data lifecycle

• Also called the Consumer Data Lifecycle , it is a fundamental component of the privacy knowledge base

• Define the actions related to personal data within the privacy framework

• When analyzing the data flow in your specifications, you should also consider the complete

lifecycle for the associated PII

• Within the EU, collection, itself is considered to be an act of

processing !

Deletion

Storage Processing

Transfer

Collection

x

(10)

Personal data/information

• Relates to information about a natural person

• When the data can be associated with an individual, it is referred to as Personally Identifiable Information (PII)

• Criteria for linkability of data to an individual is a hot-topic within the privacy community

• Sensitive PII must be treated specially

• Generally, if PII is of a racial, religious, political, sexual

orientation, medical nature, it is characterized as Sensitive; but other categories should also be consisted

• Also commonly referred to as Personal Data

Basic data (E.G. first name, last name, mobile number)

Address data (E.G. postal code, email address) Restrictedcategories of data (E.G. racial or ethnic origin, religion, trade union membership – if allowed by applicable law) Social networking related data (E.G.. metadata of pictures uploaded, site activity information) Location data (E.G. GPS coordinates or mobile network base station ID) Identifiers(E.G. IMEI, device identifiers, IP- address)

System data is

information about how individual users are using the system (E.G. log files) Monetary data

transactions (E.G. credit card number, account information)

These are some of the categories of personal data to consider when identifying the PII in your

particular project

(11)

1. WHAT – Information Privacy

− Terminology

− Roles within the Privacy Framework

− Privacy Principles

− Essence of privacy

− Privacy data lifecycle

− Personally Identifiable Information and Identifiability

2. HOW – Compliance or Accountability

− Elements of an ACCOUNTABLE privacy program

− Privacy activities across the product life cycle

− Privacy program roles &

responsibilies

4. Use case

− Kickoff meeting

− Use case & DFD

− Threat analysis

(12)

Compliance or Accountability

• Goal of being privacy compliance may not be sufficient for avoiding regulatory actions against your company

• Data protection authorities (DPA) now expect

organizations to demonstrate their good intentions

• Accountability has roots in 1980 OECD privacy guidelines

• Accountability framework builds trust between DPA and organizations for the handling of personal data

• Accountability means being able to show how your

company has holistically integrated privacy best practices

• Centre for Information & Policy Leadership (CIPL) has

defined a global DPA endorsed approach to Accountability Data Protection Accountability: The Essential Elements

(13)

Elements of an Accountable privacy program

1. Executive accountability and oversight

Internal senior executive oversight and responsibility for data privacy and data protection

2. Policies and processes to implement them

Binding and enforceable written policies and procedures that reflect applicable laws, regulations and industry standards, including procedures to put those policies into effect

3. Staffing and delegation

Allocation of resources to ensure that the organization's privacy program is appropriately staffed by adequately trained personnel

4. Education and awareness

Existence of up-to-date education and awareness programs to keep employees and on-site contractors aware of data protection obligations

5. Risk assessment and mitigation

Ongoing risk assessment and mitigation planning for new products, services, technologies and business models.

Periodic Program risk assessment to review the totality of the accountability program

6. Event management and complaint handling

Procedures for responding to inquiries, complaints and data protection breaches

7. Internal enforcement

Internal enforcement of the organization's policies and discipline for non-compliance

8. Redress

Provision of remedies for those whose privacy has been put risk

Not just compliant but accountable

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Privacy activities across the product life cycle

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Privacy program roles & responsibilities

Executive privacy owner

• The senior executive with oversight and responsibility for data privacy and data protection in the organization

Chief privacy officer

• The senior manager with responsibility for the implementation and operation of the privacy program in the organization

Privacy officer

• The privacy professional responsible for implementation and operation of the privacy program within an organizational unit Privacy champ

• The program or product member with sufficient privacy competence to be responsible for transposing privacy requirements into product requirements

Data Protection Officer

• A privacy professional required by some organizational entities with reporting accountability to the local Data Protection Authority

These are minimal privacy program roles

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− Terminology

responsibilies

3. HOW - Privacy Engineering & Assurance simplified

− Applying Privacy Engineering

− Privacy Engineering steps

− Privacy Assurance steps

− Design activities across the product life cycle

− Privacy impact assessment

− Privacy risk management

− Assessing privacy maturity

− Privacy related business processes

4. Use case

− Kickoff meeting

− Use case & DFD

− Threat analysis

(17)

Privacy Engineering & Assurance simplified

Principles, Policies, Requirements,

Procedures, Guidelines,

Patterns

Design, Implement, Test

Map privacy requirements into product features

Select guidelines, patterns

Review

Against requirements Can be standalone

Release Assessment

Sign-off

Evidence

Privacy Engineering

Privacy Assurance Privacy

Knowledge Base

Planning & Concepting

Threat Assessment and Mitigation Privacy requirements identification

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Applying Privacy Engineering

Principles

Requirements

Threats

Controls

Residual Risk Privacy Principles

Privacy Requirements &

Guidelines

Privacy & Security Threats &

Vulnerabilities

Privacy & Security Safeguards

Business Acceptable Risk

(19)

Privacy Engineering steps

• Define the product context

− Define product in terms of main functions, assets, stakeholders, business model, sales estimates, deployment target countries, release schedule(s), strategic importance, risk summary

• Document the data flows and classify the data

− Inventory of all the personal data

& data clusters

− Classification of each data element

− User story/epic based diagram of the flow of data through product components,

interactors

• Analyze the threats and risks

− Identification of applicable

privacy principles and underlying requirements

− Definie inherent threats to key privacy & security principles

− Analysis of attack surface and minimization

− Identification of root cause or vulnerability

• Mitigation

− Selection of privacy & security safeguarding controls

− Identification of key test causes and test tools to verify control fidelity

− Identification of residual risk Implementing Privacy by Design

(20)

Privacy Assurance steps

• Purpose of assurance is to verify that Privacy Engineering

activities have been implemented as agreed, operational, as well as any required staffing is in place

• Kick-off the assessment process with Privacy Officer early to understand what will be needed for final sign-off

• Privacy & security assessment is based on a thorough assessment of the Product Team evidence that Privacy

Engineering activities has been implemented and is operational

• Final sign-off recommendation is made by Privacy Officer with approval by Product Management & Chief Privacy Officer

• Escallation process may be needed to address disagreements over findings between Privacy Officer and Product Management

• Non-compliance with privacy regulations SHOULD NOT be approved

A final assessment of all product or service that have a privacy impact is a necessity

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Threat model

• Threats exploit Vulnerabilities and damage Assets

• Controls mitigate Vulnerabilities and therefore might mitigate Threats

• Attacks manifest Threats

Asset 1

Threat

Vulnerability 1

Vulnerability 2

Control

Control Control Asset 2

damages

exploits exploits

mitigates mitigates

(22)

What is threat analysis

• Threat analysis is about understanding privacy threats to a system, determining harm from those threats and establishing appropriate migitations (privacy controls or safeguards) against those harms

• Analyzes threats to underlying Privacy Principles at each stage of the Privacy Data Lifecycle

• Analysis results facilitate selection of mitigation Privacy Safeguards/Controls Why follow this practice?

• A structured approach better ensures PbD than an ad hoc approach

• Threat analysis allows development teams to effectively find potential privacy

design issues. Mitigation of privacy issues is less expensive when performed during design

• By knowing the threats, privacy testing efforts can be focused more effectively

• This is a prerequisite to conducting a Risk Analysis to mitigate associated harm

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Threats come with data – DFD can identify them

• Therefore we model the data using a data flow diagram (DFD)

• Scope is the processes (your code), all neighbouring actors, data stores and the trust boundaries between them

Data store External

interactor

Process

External interactor Process

Data flow

External interactor

Trust boundary

References: Open Web

Application Security Project, Microsoft TMA

Trust boundary

(24)

Threat analysis modeling

1. Getting ready

− Product description, data inventory, data flow diagram

2. Identify assets

− Digital, physical, reputational, operational

3. Identify entry points

− Entry or exit through a trust boundary in DFD

4. Identify vulnerabilities

− A weakness or failing

5. Define attacker types

− Threats exploit vulnerabilities, attack manifests a threat

6. Define controls

− A countermeasure or safeguard

7. Build threat scenarios and mitigation plans

− Possibly by making use of an attack tree/threat tree

(25)

Illustrative table to capture privacy threats table

Lifecycle Principle Threat Controls Harm

Collection Transparency

Notice & Consent Unauthorized

collection Data analysis

Purpose verification Hidden data bases Collection Collection limitation Unlimited collection Purpose verification

Collection method analysis

Lack of

proportionality

Processing Purpose

specification

Legitimate purpose

Processing unrelated to purpose

Function limits

User participation Processing with llegitimate purpose

Processing Processing Lack of consumer

control Opt-out, Platform

privacy control Automatic processing

Processing Security Data integrity fault

or data

misrepresentation

Data integrity check

on read, write Misrepresentation Transfer Legal obligations Transfer PII outside

EU without consent Notice & Consent Violation of EU citizens’ basic rights Maintenance Access &

participation, Individual participation, Redress

Lack of consumer

redress Privacy policy

includes process for user redress

Inability to rectify errors

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Documenting controls and validation tests

• Selected controls should be documented in a reliable storage as a part of the evidence of applying Privacy Engineering

• It is good practice to also define test cases for validating that the controls are implemented, operating as intended and effect against the associated threat(s)

• This documentation forms part of the compliance

evidence, and it has to be reviewed by a privacy & product security officers

(27)

Privacy risk assessment

• Produces evidence of minimization of possible privacy risk

• Risk = Fn (Harm, Impact, Probability, Residual Risk)

• Re-conducted when material changes made to product

• ISO 31000 – A reference risk management framework

Context establish external, internal context for risk, risk management process and risk assessment criteria to be used

Identify identify sources of risk, areas of impact, events and causes, potential consequences

Analyze consider causes and sources of risk, positive & negative consequences, both tangible and intangible

Evaluate make decisions based on risk analysis, which risks need treatment and the priority for treatment implementation

Treat select remediation based on avoiding, taking on, removing, changing potential for, changing harm of, sharing of risk

Monitor &

Review assures controls effective, learn and improve, detect context changes, identify new risks, measure KPI

Improve commit to constant improvement of the overall risk footprint

Identify the RESIDUAL RISK in

your product.

Product management

must accept residual risk!

(28)

Understanding privacy risks

Threats/Vulnerabilities (examples)

• “Hidden, uncontrolled, excessive or unsecure processing”

• Improper collection, use, disclosure

• Globally accepted privacy principles and laws often articulate these in more detail

• Privacy requirements and guidelines act as controls to these threats/vulnerabilities

Impacts to individuals (examples)

• Tangible (e.g. credit card fraud, discrimination)

• Intangible (e.g. embarrasement)

• Societal (e.g. chilling effect on freedom of speach)

Impacts/consequences to companies (in general)

• Bad publicity, erosion of trust

• Fines up to millions (new EU proposal: up to 2% of annual global turnover)

• Penalties, including personal criminal liability

• Forced privacy program with 20 year external audit obligation

• Data breach notifications (~$200 per lost record in US, similar in e.g. Germany)

• Deletion of unlawfully collected data

• Sales stops, recalls, cost of remediation

• Human rights, ethics challenges

(29)

Privacy risk assessment

• Objective is to reduce the business impact from exploitation of a set of threats

• Process utilizes the results of the threat analysis and mitigation activity

• Product team is responsible for completion of risk analysis

• Technical team provides complementary support

• Residual Risk = Fn (Harm, Impact, Probability of Occurrence, Mitigations)

• Risk migitation = actionable steps to reduce harm, impact or probability

• Migitation approaches include:

• Do nothing, hope for the best

• Mitigate the risk by putting countermeasures in place

• Reduce impact or probability

• Accept the risk after evaluating the business impact

• Transfer the risk with contractual agreements or insurance

• Remove the risk, for example shutdown the product, remove feature

Security risk is about harm to the company, but privacy risk is about harm to the consumer

(30)

Example risk assessment report

ID Event Root causes Consequences Impact Probability Treatment

actions

Monitoring measures

Action

Deadline Action owner

Privacy breaches, privacy related loss of

business, compliance including corruption and fraud

- Failures to design privacy into products and services.

- NSA espionage:

Cloud services concentrate d to US based cloud providers - User privacy

vs. benefits of analytics - Privacy

program and resourcing and maturity

- Data breaches - Regulatory

enforcement - Business

interruptions , requests to delete data, sales stops.

- -End user and business customers lost with US based cloud services

100-150 MEUR

Anything up to

$200 USD per record in US Up to 100 euro per record in Germany Reputational damage and lost business

opporutnity

~15% - Medium

Insurance policy?

Training, security scanning and audits

including corrective actions MS

integrations project actions

Progress measures, milestones followed

2Q2015 Alice

(31)

Privacy impact assessment

• EU GDPR Article 33 promulgates PIA for public/privacy orgs

• Produces evidence of implementation of Privacy by Design

• Conducted by staff when personal data is collected, used or disclosed in a product or service

• Re-conducted if material changes made to product or service

• ISO 29134 (WD) will standardize methodology

Identify describe the project, including the aims, whether any personal information will be handled, inherent privacy principles

Analyze identify the personal information flows, classify data, identify relevant regulations, privacy requirements, privacy impact

Verify validate that only essential data is collected and processed for legitimate purposes required by the product or service

Simplify change system and processes to only collect/store/process essential data for minimum period with a data deletion plan

Secure use industry best practices for safeguarding personal data through life cycle, providing consumer control over their data

Remediate identify remaining risk, level of harm and mitigation plan to eliminate or reduce risk to acceptable level

Attest record findings, gain sponsor commitment to implement any needed changes, report results to management

(32)

Privacy capability assessment

• Provides a method for advancement of your privacy program

• Conducted to measure baseline and incremental changes

• Part of a commitment to accountability, constant improvement

• ISO 29190 (new IS) will standardize a methodology

Plan agree on privacy capability assessment model (e.g., context or business process based) and assessment scale to be used

Assess rate the current capability against target capability

Review identify sub-optimal capabilities to be improved and overall improvement plan

Report communicate to management the assessment activity,

results, improvement actions and next scheduled assessment

Improve implement improvement plan

(33)

Privacy related business processes

• Quality management process

• Risk management process

• Assessment process

• Security engineering process

• Business continuity process

• Customer care process

• Incident response management process

• External communications process

• Authority request/lawful intercept process

(34)

− Terminology

responsibilies

4. Use case

− Initial description

− Assessment planning

− Kickoff meeting

− Use case & DFD

− Data inventory & classification

− Threat analysis

− Security considerations

− Privacy Policy template

− Assessment findings

− Final assessment review

(35)

Use case – Globetrotter Tech Weather App

You work as the privacy officer for Globetrotter Technologies, a technology start-up. The business intends to rule the world of

mobile software apps to aid business travellers. You report to the CPO Elliot.

You just finished giving a privacy training to the software staff and Alice, a program manager, approached you to get some guidance, as her Android Weather App is planning on going Live at the end of the month. You have just reminded her that corporate policy is

that no product goes live without satisfactory recommendation from the privacy officer after a final privacy assessment. Alice designated Bob on her team as the privacy champ. Her dev

manager is Chuck. She reports to VP of programs, David.

She wants to get started ASAP.

What is your course of action?

(36)

5. Gather feedback

Review &

communicate lessons learned

1. Plan & Prepare 2. Conduct 3. Report

Assessment planning

What is your course of action?

Generic role Purpose of the role

Assessment sponsor Has the authority in Nokia to decide Go/No go for assessments. Authorizes plan and resourcing, specifies requirements. Ensures actions on findings

Lead assessor Ensures the successful execution of the assessment

Assessment team Team of people assessing the interviewees. Assessment team is headed by lead assessor

Interviewees The sample of people from the audited/assessed organization that are interviewed for the audit/ assessment

Assessment roles

Define scope, objectives, Review and agree plan with sponsors

Brief Assessment Team

Communicate purpose to persons to be assessed

Schedule & run interviews per plan

Write report, agree with all assessed then report to sponsors &

stakeholders

Follow up improvement actions

4. Follow Up

• Get sponsor agreement for assessment and scope

• Identify and secure support of key assessor roles

• Follow the “Plan, Do, Check, Act” (PDCA) steps

(37)

Next steps

• Confirm assessment sponsorship with David, VP Programs

• Confirm assessment request with Elliot, CPO

• Email confirmation of availability to provide assessment assistance to Alice, PM and request meeting to identify assessment team and participants

• At subsequent meeting with Alice, verify role of Bob,

Privacy Champ and agree on Kickoff meeting purpose and agenda

• Introductions, Purpose of assessment, Activities/Evidence

• Email invite to assessment Kickoff meeting to participants

• Req: Alice, PM; Bob, Privacy Champ; Chuck, Dev Mgr; You

• Opt: David, VP Programs; Elliot, CPO

(38)

Kickoff meeting

• At the kickoff meeting you learn the following about the Weather App project

• Alice is the program manager

• Bob is her privacy champ

• Chuck is the development manager

• David is the program VP and business owner

• Elliot is your CPO

• Android 4.4 app for Google Play Store distribution

• Wave 1: EU countries

• Wave 2: US and CA

• 3^rd party partners:

− OpenWeatherMap – Forecast data

− CrashDaddy – Crash analytics

• Features

− Lookup city from GPS lat-lon

− Lookup forecast from city name

− History of last 12 forecasts

− Admin console for crash analytics

What is your next course of action?

(39)

Next steps

• Schedule periodic meetings to progress assessment with Alice, PM; Bob, Dev Mgr; and Chuck, Privacy Champ

• Verify product description through Team provided evidence

• Perform/create System diagram, Data flow diagram, Data inventory & classification, Threat analysis & mitigation

with Alice, PM; Bob, Dev Mgr; and Chuck, Privacy Champ

(40)

User experience concept

(41)

Weather app use case DFD

Open Weather Map

CityGet

API Token, Lat-Lon Trust boundary

City

SensorGPS

Lat-Lon

DataCity Store

Lat-Lon,

Get City

Forecast

Forecast API Token,

City Forecast

StoreData

Lat-Lon, City

City Look

Foreup

Forecast cast

Lat-Lon, City

What findings can you infer?

• Forecast for current position displayed

• User can enter city name and get forecast for that city

• Previous forecasts kept to avoid data charges from

unnecessary lookup

Mobile App

(42)

Web Browser Mobile App

Crash analytics use case DFD

Crash Daddy

Transfer Crash

Data API Token, Device ID, Crash Payload

Trust boundary Crash

Data Store

Analytic Request

What findings can you infer?

• Crash Payload pushed on app restart after crash recovery

• Web browser access to crash analytics console with admin credentials

• Crash analytics console functions include

display of reports based on crash-type specific requests

Crash Analytics

Console Function

Analytic Response Crash

Payload

(43)

Data inventory

(44)

Example threat list (1 of 4)

(45)

(46)

(47)

(48)

Threat analysis notes – Weather app

• No plan for product information to be provided to consumer in Google Play Store entry

• No plan for supporting consumer inquiry

• No notice & consent given consumer on Terms or Privacy Policy

• Verify use of Globbetrotter Technologies Terms & Privacy Policy

• Google Play Store

• First-Use-Experience

• Within App

• No prior notice & consent of consumer on Location Data collection and use

• No data minimization effort

• Unclear vetting of Open Weather Map for 3^rd party services

• Unclear how location/forecast history secured in device

• Unclear if uninstall will delete app data

• Unclear how API token secured in device

• Unclear product security plans

• Need product security training & awareness

• Unclear if app hardening will include tamper-prevention

• Unclear legal review plans

• Unclear service continuity plans

• Unclear reactive vulnerability & incident response plans

• No data retention/deletion plan

• Unclear coordination between Weather App & other business traveller app Teams

(49)

Threat analysis notes – Crash analytics

• No data minimization effort

• Unclear purpose for device id in crash payload

• Unclear purpose for memory dump in crash payload

• Unclear vetting of Crash Daddy for 3^rd party services

• Unclear how API token secured in device

• Unclear product security plans

• Need product security training & awareness

• Unclear if app hardening will include tamper-prevention

• Unclear legal review plans

• Unclear service continuity plans

• No data retention/deletion plan

• Unclear if crash analytics planned only for Beta phase

(50)

Next steps

• Connect Alice, PM with Product Security Team to plan for product security assessment

• Draft and share privacy assessment findings with Alice, PM; Bob, Dev Mgr; and Chuck, Privacy Champ

• Coordinate assessment findings with Product Security Team

• Assist and encourage Alice, PM; Bob, Dev Mgr; and Chuck, Privacy Champ with documenting evidence of privacy

engineering activities

• Plan & schedule final assessment review with Alice, PM

(51)

Security considerations

Define

• OWASP Top-10 Security Threats

• Google Android Developer Security Guidelines

• Japan Smartphone Security Association Guidelines Develop

• Static & dynamic code scanner

• Peer code review

• 3^rd party security review Deploy

• Hardening guidelines

• Vulnerability testing (eg, NMAP)

• Tamper-proofing, security distribution code

• Penetration testing

• Google Hacking

• Reactive vulnerability response

Roles & responsibility for drafting & approval of Privacy Policy should be clearly defined

(52)

Privacy policy template

• Title

• Change control/effective date

• Business privacy vision

• Define categories of applicable personal data

• Organization to which policy applies

• Why the defined categories of personal data is collected

• Limits on collection, use & disclosure of the personal data

• Define circumstance for disclosure of the personal data

• How consent for personal data collection & processing is obtained

• How long the personal data is retained

• How the personal data is secured

• How the accuracy of the personal data is ensured

• How individuals can access their personal data

• How individuals can complain or make an inquiry

• Your identity and contact information

Roles & responsibility for drafting & approval of Privacy Policy should be clearly defined

(53)

Assessment report – Major findings

ID Category Title of finding Description of requirement Action Status

01 Major Notice & Consent Provide notice prior to initial collection,

Provide Opt-Out of data processing Privacy notice and Terms need to be provided in Google Play Store, First User Experience and Settings

Major Notice & Consent Provide notice & consent prior to use of

location data Add notice & consent control for location data

03 Major Data minimization Minimum data collection & processing

for stated primary purposes Conduct data minimization review of data inventory against primary purpose Major Data minimization No cross-border transfer of personal

data without user's Active Consent Include cross-border transfer purpose in Privacy Policy, as needed

Major Use, retention and

disclosure limitation Provide method for consumer requests

for information & redress Data Retention & Deletion Plan, Privacy policy includes instructions for consumer redress

Major Security Provide product security to protection

personal data Verify no open major product security

assessment findings Major 3^rdParty Privacy &

Security Management

Vetting of 3^rdparty service providers Email from PM verifying vetting of 3^rd party vendors by sourcing/legal

Not Ok Ok

(54)

Assessment report – Minor findings

ID Category Title of finding Description of requirement Action Statu

s Minor Service Continuity No service continuity plan Agree on service continuity strategy

and define and resource a plan aligned with strategy

Minor Reactive Vulnerability &

Incident Response Management

No RV&IR plan Agree on reactive vulnerability &

incident response strategy and define and resource a plan aligned with strategy

Minor Requirements

alignment Privacy & security

requirements alignment across GT app teams

Coordinate privacy & security requirements across app Teams

Not Ok Ok

(55)

Assessment report – Recommendations

ID Category Title of finding Description of requirement Action Status

Recommend Requirements alignment Privacy & security requirements

alignment across GT app teams Coordinate privacy & security requirements across app Teams Recommend App Hardening Harden install file with tamper-

detection, encryption of token handling Integrate hardening tool such as DEXGuard

Recommend Security Training &

Awareness Train key team members on product

security Product security training completed for

PM, Dev, QA, Req Mgmt

Recommend Legal Review Comply with local laws & regulations Complete legal review with legal counsel

Not Ok Ok

(56)

Next steps

• Distribute final assessment report with Alice, PM; Bob, Dev Mgr; and Chuck, Privacy Champ

• Work to close open action items with Alice, PM; Bob, Dev Mgr; and Chuck, Privacy Champ

• Schedule and meet to conclude perform final assessment review with Alice, PM

• Share final assessment recommendation with Alice, PM;

Elliot, CPO; and David, VP Programs

• Support Elliot, CPO on any resulting escallation

(57)

Final assessment review

Category Activity Requirement Criteria Status

Development Business Impact Overall product business

criticality & risks assessed Risk assessment report Product information Defined product

description, responsible roles identified

Product description document

Data flows, System

architecture Use cases identified, data

flows documented Data inventory & classification spreadsheet

Threat Analysis Privacy & security threats and mitigating controls documented

Threat assessment report

Code review Security code scan of software. Manual security code reviews also

recommended.

No open major code scan report items or action items from manual code review

Third party privacy &

security management Contracts with 3rd parties reference privacy &

security requirements.

Sign-off email from sourcing/legal counsel

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