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+Privacy-Aware Design |
Privacy-Aware DesignDescriptionMechanisms exist to formally incorporate the organization's data privacy principles into engineering, product and model design requirements to ensure data privacy is built in by default and by design.Possible Solutions & ConsiderationsMicro-Small Business (<10 staff) / BLS Firm Size Classes 1-2∙ Privacy by design principles (basic data minimization practices)∙ NIST Privacy Framework reference Small Business (10-49 staff) / BLS Firm Size Classes 3-4∙ Privacy by design checklist for new systems∙ NIST Privacy Framework or GDPR Art. 25 alignment Medium Business (50-249 staff) / BLS Firm Size Classes 5-6∙ Privacy by design and by default program∙ DPIA for new systems ∙ Privacy engineering practices in SDLC Large Business (250-999 staff) / BLS Firm Size Classes 7-8∙ Enterprise privacy engineering program∙ Privacy by design requirements in system development lifecycle ∙ DPIA for new data processing Enterprise (> 1,000 staff) / BLS Firm Size Class 9∙ Enterprise privacy engineering framework∙ Automated privacy design reviews in SDLC ∙ DPIA for all new data processing ∙ Privacy technology stack (e.g., OneTrust) SCR-CMMLevel 0 Not PerformedPractices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.Level 1 Performed InformallyPrivacy (PRI) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:▪ Policies, standards & procedures associated with PRI domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Data privacy-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ No formal data privacy team exists. Privacy roles are assigned to existing IT / cybersecurity. Level 2 Planned TrackedPrivacy (PRI) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist:▪ Policies and standards associated with PRI domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with PRI domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with PRI domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data privacy management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Data privacy management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. Level 3 Well DefinedPrivacy (PRI) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:▪ Policies and standards associated with PRI domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function. ▪ Standardized Operating Procedures (SOP) associated with PRI domain capabilities are well-documented and kept current by process owners. ▪ A data privacy team, or similar function, is appropriately staffed and supported to implement and maintain PRI domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data privacy operations (e.g., privacy notice management software and customer management solution). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with PRI domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to formally incorporate the organization's data privacy principles into engineering, product and model design requirements to ensure data privacy is built in by default and by design. Level 4 Quantitatively ControlledUtilize SCR-CMM Level 3 criteria definitions:▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control. ▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define. Level 5 Continuously ImprovingUtilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control. ▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies. ▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define. 1. Oversigt
1.1 Referencer1.2 Identificerede krav1.3 Relaterede reguleringer
2. Identificerede krav
3. Relaterede reguleringer
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