John Sabo (email@example.com), Individual
Michael Willett (firstname.lastname@example.org), Individual
Peter F Brown (email@example.com), Individual
Gershon Janssen (firstname.lastname@example.org), Individual
John Sabo (email@example.com), Individual
Michael Willett (firstname.lastname@example.org), Individual
The Privacy Management Reference Model and Methodology (PMRM, pronounced “pim-rim”) provides a model and a methodology for:
· understanding and analyzing privacy policies and their privacy management requirements in defined use cases; and
· selecting the technical services which must be implemented to support privacy controls.
It is particularly relevant for use cases in which personal information (PI) flows across regulatory, policy, jurisdictional, and system boundaries.
This document was last revised or approved by the OASIS Privacy Management Reference Model (PMRM) TC on the above date. The level of approval is also listed above. Check the “Latest version” location noted above for possible later revisions of this document.
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Privacy Management Reference Model and Methodology (PMRM) Version 1.0. 03 July 2013. OASIS Committee Specification 01.
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The Privacy Management Reference Model and Methodology (PMRM) addresses the reality of today’s networked, interoperable capabilities, applications and devices and the complexity of managing personal information (PI) across legal, regulatory and policy environments in interconnected domains. In some jurisdictions, there is a distinction between ‘personal information’ (PI) and ‘personally identifiable information’ (PII) and this is addressed in the Glossary. For clarity in the document, however, the term ‘PI’ is generally used and assumed to cover both. Specific contexts may, however, require that the distinction be made explicit.
The PMRM is a valuable tool that helps improve privacy management and compliance in cloud computing, health IT, smart grid, social networking, federated identity and similarly complex environments where the use of personal information is governed by laws, regulations, business contracts and operational policies, but where traditional enterprise-focused models are inadequate. It can be of value to business and program managers who need to understand the implications of privacy policies for specific business systems and to help assess privacy management risks.
The PMRM is neither a static model nor a purely prescriptive set of rules (although it includes characteristics of both), and implementers have flexibility in determining the level and granularity of analysis required by a particular use case. The PMRM can be used by systems architects to inform the development of a privacy management architecture. Appropriate compliance and conformance criteria will be established after the specification has been exercised and has matured and stabilized. This would include, for example, verifiable criteria that the services outlined in Section 4 would need to follow if they are to be considered trustworthy.
The PMRM may also be useful in fostering interoperable policies and policy management standards and solutions. In many ways, the PMRM enables “privacy by design” because of its analytic structure and primarily operational focus.
Predictable and trusted privacy management must function within a complex, inter-connected set of networks, systems, applications, devices, data, and associated governing policies. Such a privacy management capability is needed both in traditional computing and in cloud computing capability delivery environments. A useful privacy management capability must be able to establish the relationship between personal information (“PI”) and associated privacy policies. Although there may be others according to particular use cases, the main types of policy covered in this document are expressed as classes of Privacy Control: Inherited, Internal or Exported. They in turn must be expressed in sufficient granularity as to enable the assignment of privacy management functionality and compliance controls throughout the lifecycle of the PI and accommodate a changing mix of PI and policies, whether inherited or communicated to and from external domains or imposed internally. It must also include a methodology to carry out a detailed, structured analysis of the application environment and create a custom privacy management analysis (PMA) for the particular use case.
The PMRM is used to analyze complex use cases, to understand and implement appropriate operational privacy management functionality and supporting mechanisms, and to achieve compliance across policy, system, and ownership boundaries. It may also be useful as a tool to inform policy development.
Unless otherwise indicated specifically or by context, the use of the term ‘policy’ or ‘policies’ in this document may be understood as referencing laws, regulations, contractual terms and conditions, or operational policies associated with the collection, use, transmission, storage or destruction of personal information or personally identifiable information.
While serving as an analytic tool, the PMRM can also aid the design of a privacy management architecture in response to use cases and as appropriate for a particular operational environment. It can also be used to help in the selection of integrated mechanisms capable of executing privacy controls in line with privacy policies, with predictability and assurance. Such an architectural view is important, because business and policy drivers are now both more global and more complex and must thus interact with many loosely-coupled systems.
In addition, multiple jurisdictions, inconsistent and often-conflicting laws, regulations, business practices, and consumer preferences, together create huge barriers to online privacy management and compliance. It is unlikely that these barriers will diminish in any significant way, especially in the face of rapid technological change and innovation and differing social and national values, norms and policy interests.
It is important to note that agreements may not be enforceable in certain jurisdictions. And a dispute over jurisdiction may have significant bearing over what rights and duties the Participants have regarding use and protection of PI. Even the definition of PI will vary. The PMRM attempts to address these issues. Because data can in so many cases easily migrate across jurisdictional boundaries, rights cannot necessarily be protected without explicit specification of what boundaries apply. Proper use of the PMRM will however expose the realities of such environments together with any rules, policies and solutions in place to address them.
The Privacy Management Reference Model and Methodology therefore provides policymakers, program and business managers, system architects and developers with a tool to improve privacy management and compliance in multiple jurisdictional contexts while also supporting capability delivery and business objectives. In this Model, the controls associated with privacy (including security) will be flexible, configurable and scalable and make use of technical mechanisms, business process and policy components. These characteristics require a specification that is policy-configurable, since there is no uniform, internationally-adopted privacy terminology and taxonomy.
Analysis and documentation produced using the PMRM will result in a Privacy Management Analysis (PMA) that serves multiple Stakeholders, including privacy officers and managers, general compliance managers, and system developers. While other privacy instruments, such as privacy impact assessments (“PIAs”), also serve multiple Stakeholders, the PMRM does so in a way that is somewhat different from these others. Such instruments, while nominally of interest to multiple Stakeholders, tend to serve particular groups. For example, PIAs are often of most direct concern to privacy officers and managers, even though developers are often tasked with contributing to them. Such privacy instruments also tend to change hands on a regular basis. As an example, a PIA may start out in the hands of the development or project team, move to the privacy or general compliance function for review and comment, go back to the project for revision, move back to the privacy function for review, and so on. This iterative process of successive handoffs is valuable, but can easily devolve into a challenge and response dynamic that can itself lead to miscommunication and misunderstandings.
The output from using the PMRM, in contrast, should have direct and ongoing relevance for all Stakeholders and is less likely to suffer the above dynamic. This is because it should be considered as a “boundary object,” a construct that supports productive interaction and collaboration among multiple communities. Although a boundary object is fully and continuously a part of each relevant community, each community draws from it meanings that are grounded in the group’s own needs and perspectives. As long as these meanings are not inconsistent across communities, a boundary object acts as a shared yet heterogeneous understanding. The PMRM process output, if properly generated, constitutes just such a boundary object. It is accessible and relevant to all Stakeholders, but each group takes from it and attributes to it what they specifically need. As such, the PMRM can facilitate collaboration across relevant communities in a way that other privacy instruments often cannot.
The intended audiences of this document and expected benefits to be realized include:
· Privacy and Risk Officers will gain a better understanding of the specific privacy management environment for which they have compliance responsibilities as well as detailed policy and operational processes and technical systems that are needed to achieve their organization’s privacy compliance;
· Systems/Business Architects will have a series of templates for the rapid development of core systems functionality, developed using the PMRM as a tool.
· Software and Service Developers will be able to identify what processes and methods are required to ensure that personal data is created and managed in accordance with requisite privacy provisions.
· Public policy makers and business owners will be able to identify any weaknesses or shortcomings of current policies and use the PMRM to establish best practice guidelines where needed.
The PMRM consists of:
· A conceptual model of privacy management, including definitions of terms;
· A methodology; and
· A set of operational services,
together with the inter-relationships among these three elements.
Figure 1 – The PMRM Conceptual Model
In Figure 1, we see that the core concern of privacy protection, is expressed by Stakeholders (including data subjects, policy makers, solution providers, etc.) who help, on the one hand, drive policies (which both reflect and influence actual regulation and lawmaking); and on the other hand, inform the use cases that are developed to address the specific architecture and solutions required by the Stakeholders in a particular domain.
Legislation in its turn is a major influence on privacy controls – indeed, privacy controls are often expressed as policy objectives rather than as specific technology solutions – and these form the basis of the PMRM Services that are created to conform to those controls when implemented.
The PMRM methodology covers a series of tasks, outlined in the following sections of the document, concerned with:
· defining and describing use-cases;
· identifying particular business domains and understanding the roles played by all Participants and systems within that domain in relation to privacy issues;
· identifying the data flows and touch-points for all personal information within a privacy domain;
· specifying various privacy controls;
· mapping technical and process mechanisms to operational services;
· performing risk and compliance assessments.
The specification also defines a set of Services deemed necessary to implement the management and compliance of detailed privacy requirements within a particular use case. The Services are sets of functions which form an organizing foundation to facilitate the application of the model and to support the identification of the specific mechanisms which will be incorporated in the privacy management architecture appropriate for that use case. The set of operational services (Agreement, Usage, Validation Certification, Enforcement, Security, Interaction, and Access) is described in Section 4 below.
The core of the specification is expressed in two normative sections: the High Level Privacy Analysis and the Detailed Privacy Management Reference Model Description. The Detailed PMRM Description section is informed by the general findings associated with the High Level Analysis. However, it is much more detail-focused and requires development of a use case which clearly expresses the complete application and/or business environment within which personal information is collected, communicated, processed, stored, and disposed.
It is also important to point out that the model is not generally prescriptive and that users of the PMRM may choose to adopt some parts of the model and not others. They may also address the Tasks in a different order, appropriate to the context or to allow iteration and discovery of further requirements as work proceeds. However, a complete use of the model will contribute to a more comprehensive privacy management architecture for a given capability or application. As such, the PMRM may serve as the basis for the development of privacy-focused capability maturity models and improved compliance frameworks. The PMRM provides a model foundation on which to build privacy architectures.
Use of the PMRM by and within a particular business domain and context (with a suitable Use Case), will lead to the production of a Privacy Management Analysis (PMA). An organization may have one or more PMAs, particularly across different business units, or it may have a unified PMA. Theoretically, a PMA may apply across organizations, states, and even countries or other geo-political regions.
Figure 2 below shows the high-level view of the PMRM methodology that is used to create a PMA. Although the stages are numbered for clarity, no step is an absolute pre-requisite for starting work on another step and the overall process will usually be iterative. Equally, the process of establishing an appropriate privacy architecture, and determining when and how technology implementation will be carried out, can both be started at any stage during the overall process.
Figure 2 - The PMRM Methodology
References are surrounded with [square brackets] and are in bold text.
The key words “MUST”, “MUST NOT”, “REQUIRED”, “SHALL”, “SHALL NOT”, “SHOULD”, “SHOULD NOT”, “RECOMMENDED”, “MAY”, and “OPTIONAL” in this document are to be interpreted as described in [RFC2119].
A glossary of key terms used in this specification as well as operational definitions for sample Fair Information Practices/Principles (“FIPPs”) are included in Section 8 of the document. We note that words and terms used in the discipline of data privacy in many cases have meanings and inferences associated with specific laws, regulatory language, and common usage within privacy communities. The use of such well-established terms in this specification is unavoidable. However we urge readers to consult the definitions in the glossary and clarifications in the text to reduce confusion about the use of such terms within this specification. Readers should also be aware that terms used in the different examples are sometimes more “conversational” than in the formal, normative sections of the text and may not necessarily be defined in the glossary of terms.
[SOA-RM] OASIS Standard, "Reference Model for Service Oriented Architecture 1.0”, 12 October 2006. http://docs.oasis-open.org/soa-rm/v1.0/soa-rm.pdf
[SOA-RAF] OASIS Specification, “Reference Architecture Foundation for SOA v1.0”, November 2012. http://docs.oasis-open.org/soa-rm/soa-ra/v1.0/cs01/soa-ra-v1.0-cs01.pdf
[NIST 800-53] “Security and Privacy Controls for Federal Information Systems and Organizations – Appendix J: Privacy Controls Catalog”, NIST Special Publication 800-53 Draft Appendix J, July 2011.
The first phase in applying the PMRM methodology requires the scoping of the application or business service in which personal information (PI) is associated - in effect, identifying the complete environment in which the application or capabilities where privacy and data protection requirements are applicable. The extent of the scoping analysis and the definitions of “application” or “business capability” are set by the Stakeholders using the PMRM within a particular domain. These may be defined broadly or narrowly, and may include lifecycle (time) elements.
The high level analysis may also make use of privacy impact assessments, previous risk assessments, privacy maturity assessments, compliance reviews, and accountability model assessments as determined by domain Stakeholders. However, the scope of the high level privacy analysis (including all aspects of the capability or application under review and all relevant privacy policies) must correspond with the scope of the second phase, covered in Section 3, “Detailed Privacy Use Case Analysis”, below.
Objective Provide a general description of the Use Case.
Objective Provide an inventory of the capabilities, applications and policy environment under review at the level of granularity appropriate for the analysis covered by the PMRM and define a High Level Use Case which will guide subsequent analysis. In order to facilitate the analysis described in the Detailed Privacy Use Case Analysis in Section 4, the components of the Use Case Inventory should align as closely as possible with the components that will be analyzed in the corresponding detailed use case analysis.
Context The inventory can include applications and business processes; products; policy environment; legal and regulatory jurisdictions; systems supporting the capabilities and applications; data; time; and other factors Impacting the collection, communication, processing, storage and disposition of PI. The inventory should also include the types of data subjects covered by the use case together with specific privacy options (such as policy preferences, privacy settings, etc. if these are formally expressed) for each type of data subject.
Note that whereas Task #2 itemizes the environmental elements relevant to the Use Case, Task #3 focuses on the privacy requirements specifically.
Objective Prepare an initial privacy impact assessment, or as appropriate, a risk assessment, privacy maturity assessment, compliance review, or accountability model assessment applicable within the scope of analysis carried out in sections 2.1 and 2.2 above. Such an assessment can be deferred until a later iteration step (see Section 4.3) or inherited from a previous exercise.
Goal Prepare and document a detailed Privacy Management Analysis of the Use Case which corresponds with the High Level Privacy Analysis and the High Level Use Case Description.
Constraint The Detailed Use Case must be clearly bounded and must include the following components.
Objective Identify Participants having operational privacy responsibilities.
Definition A “Participant” is any Stakeholder creating, managing, interacting with, or otherwise subject to, PI managed by a System within a Privacy Domain.
Objective Identify the Systems where PI is collected, communicated, processed, stored or disposed within a Privacy Domain.
Definition For purposes of this specification, a System is a collection of components organized to accomplish a specific function or set of functions having a relationship to operational privacy management.
Objective Identify the Privacy Domains included in the use case together with the respective Domain Owners.
Definition A “Domain” covers both physical areas (such as a customer site or home) and logical areas (such as a wide-area network or cloud computing environment) that are subject to the control of a particular domain owner.
A “Domain Owner” is the Participant responsible for ensuring that privacy controls and PMRM services are managed in business processes and technical systems within a given Domain.
Context Privacy Domains may be under the control of data subjects or Participants with a specific responsibility within a Privacy Domain, such as data controllers; capability providers; data processors; and other distinct entities having defined operational privacy management responsibilities. Domains can be “nested” within wider, hierarchically structured, domains which may have their own defined ownership, roles and responsibilities.
Rationale Domain Owner identification is important for purposes of establishing accountability.
Objective For any given use case, identify the roles and responsibilities assigned to specific Participants and Systems within a specific privacy domain
Rationale Any Participant may carry multiple roles and responsibilities and these need to be distinguishable, particularly as many functions involved in processing of PI are assigned to functional roles, with explicit authority to act, rather to specific participant.
Objective Identify the touch points at which the data flows intersect with Privacy Domains or Systems within Privacy Domains.
Definition Touch Points are the intersections of data flows with Privacy Domains or Systems within Privacy Domains.
Rationale The main purpose for identifying touch points in the use case is to clarify the data flows and ensure a complete picture of all Privacy Domains and Systems in which PI is used.
Objective Identify the data flows carrying PI and privacy constraints among Domains in the Use Case.
Constraint Data flows may be multidirectional or unidirectional.
Objective Specify the PI collected, created, communicated, processed or stored within Privacy Domains or Systems in three categories.
Definition Incoming PI is PI flowing into a Privacy Domain, or a system within a Privacy Domain.
Constraint Incoming PI may be defined at whatever level of granularity appropriate for the scope of analysis of the Use Case and the Privacy Policies established in Section 2.
Definition Internally Generated PI is PI created within the Privacy Domain or System itself.
Constraint Internally Generated PI may be defined at whatever level of granularity appropriate for the scope of analysis of the Use Case and the Privacy Policies established in Section 2.
Example Examples include device information, time-stamps, location information, and other system-generated data that may be linked to an identity.
Definition Outgoing PI is PI flowing out of one system to another system within a Privacy Domain or to another Privacy Domain.
Constraint Outgoing PI may be defined at whatever level of granularity appropriate for the scope of analysis of the Use Case and the Privacy Policies established in Section 2.
Definition Control is a process designed to provide reasonable assurance regarding the achievement of stated objectives.
Definition Privacy Controls are administrative, technical and physical safeguards employed within an organization or Privacy Domain in order to protect PI. They are the means by which privacy policies are satisfied in an operational setting.
Objective Specify the required Privacy Controls which are inherited from Privacy Domains or Systems within Privacy Domains.
Objective Specify the Privacy Controls which are mandated by internal Privacy Domain policies.
Objective Specify the Privacy Controls which must be exported to other Privacy Domains or to Systems within Privacy Domains.
Privacy controls are usually stated in the form of a policy declaration or requirement and not in a way that is immediately actionable or implementable. Until now, we have been concerned with the real-world, human side of privacy but we need now to turn attention to the digital world and “system-level” concerns. “Services” provide the bridge between those requirements and a privacy management implementation by providing privacy constraints on system-level actions governing the flow of PI between touch points.
A set of operational Services is the organizing structure which will be used to link the required Privacy Controls specified in Section 4.3 to operational mechanisms necessary to implement those requirements.
Eight Privacy Services have been identified, based on the mandate to support an arbitrary set of privacy policies, but at a functional level. The eight Services can be logically grouped into three categories:
· Core Policy: Agreement, Usage
· Privacy Assurance: Security, Validation, Certification, Enforcement
· Presentation and Lifecycle: Interaction, Access
These groupings, illustrated in Table 1 below, are meant to clarify the “architectural” relationship of the Services in an operational design. However, the functions provided by all Services are available for mutual interaction without restriction.
A system architect or technical manager should be able to integrate these privacy Services into a functional architecture, with specific mechanisms selected to implement these functions. In fact, a key purpose of the PMRM is to stimulate design and analysis of the specific functions - both manual and automated - that are needed to implement any set of privacy policies. In that sense, the PMRM is an analytic tool.
The PMRM identifies various system capabilities that are not typically described in privacy practices and principles. For example, a policy management (or “usage and control”) function is essential to manage the PI usage constraints established by a data subject information processor or by regulation, but such a function is not explicitly named in privacy principles/practices. Likewise, interfaces (and agents) are not explicit in the privacy principles/practices, but are necessary to represent other essential operational capabilities.
Such inferred capabilities are necessary if information systems are to be made “privacy configurable and compliant.” Without them, enforcing privacy policies in a distributed, fully automated environment will not be possible, and businesses, data subjects, and regulators will be burdened with inefficient and error-prone manual processing, inadequate privacy governance and compliance controls, and inadequate compliance reporting.
As used here,
- A “Service” is defined as a collection of related functions and mechanisms that operate for a specified purpose;
- An “Actor” is defined as a system-level, digital ‘proxy’ for either a (human) Participant or an (non-human) system-level process or other agent.
The functions of one Service may invoke another Service. In other words, functions under one Service may “call” those under another Service (for example, pass information to a new function for subsequent action). In line with principles of Service-Oriented Architecture (SOA), the Services can thus interact in an arbitrary interconnected sequence to accomplish a privacy management task or set of privacy lifecycle requirements. Use cases will illustrate such interactions and their sequencing as the PMRM is used to solve a particular privacy problem. By examining and by solving multiple use cases, the PMRM can be tested for applicability and robustness.
Table 2 below provides a description of each Service’s functionality and an informal definition of each Service:
Define and document permissions and rules for the handling of PI based on applicable policies, data subject preferences, and other relevant factors; provide relevant Actors with a mechanism to negotiate or establish new permissions and rules; express the agreements for use by other Services
Manage and negotiate permissions and rules
Ensure that the use of PI complies with the terms of any applicable permission, policy, law or regulation,
including PI subjected to information minimization, linking, integration, inference, transfer, derivation, aggregation, and anonymization over the lifecycle of the use case
Control PI use
Evaluate and ensure the information quality of PI in terms of Accuracy, Completeness, Relevance, Timeliness and other relevant qualitative factors
Ensure that the credentials of any Actor, Domain, System , or system component are compatible with their assigned roles in processing PI; and verify their compliance and trustworthiness against defined policies and assigned roles.
Initiate response actions, policy execution, and recourse when audit controls and monitoring indicate that an Actor or System does not conform to defined policies or the terms of a permission (agreement)
Monitor and respond to audited exception conditions
Provide the procedural and technical mechanisms necessary to ensure the confidentiality, integrity, and availability of personal information; make possible the trustworthy processing, communication, storage and disposition of privacy operations
Safeguard privacy information and operations
Provide generalized interfaces necessary for presentation, communication, and interaction of PI and relevant information associated with PI; encompasses functionality such as user interfaces, system-to-system information exchanges, and agents
Information presentation and communication
Enable data-subjects , as required and/or allowed by permission, policy, or regulation, to review their PI that is held within a Domain and propose changes and/or corrections to their PI
View and propose changes to stored PI
· Define and document permissions and rules for the handling of PI based on applicable policies, individual preferences, and other relevant factors.
· Provide relevant Actors with a mechanism to negotiate or establish new permissions and rules.
· Express the agreements for use by other Services.
· Ensure that the use of PI complies with the terms of any applicable permission, policy, law or regulation,
· Including PI subjected to information minimization, linking, integration, inference, transfer, derivation, aggregation, and anonymization,
· Over the lifecycle of the use case.
· Evaluate and ensure the information quality of PI in terms of Accuracy, Completeness, Relevance, Timeliness and other relevant qualitative factors.
· Ensure that the credentials of any Actor, Domain, System, or system component are compatible with their assigned roles in processing PI;
· Verify that an Actor, Domain, System, or system component supports defined policies and conforms with assigned roles.
· Initiate response actions, policy execution, and recourse when audit controls and monitoring indicate that an Actor or System does not conform to defined laws, regulations, policies or the terms of a permission (agreement).
· Make possible the trustworthy processing, communication, storage and disposition of privacy operations;
· Provide the procedural and technical mechanisms necessary to ensure the confidentiality, integrity, and availability of personal information.
· Provide generalized interfaces necessary for presentation, communication, and interaction of PI and relevant information associated with PI;
· Encompasses functionality such as user interfaces, system-to-system information exchanges, and agents.
· Enable data-subjects, as required and/or allowed by permission, policy, or regulation, to review their PI held within a Domain and propose changes and/or corrections to it.
The Services defined in Section 4.1 encompass detailed Functions and Mechanisms needed to transform the privacy controls of section 3.3 into an operational system design for the use case. Since the detailed use case analysis focused on the data flows – incoming, internally generated, outgoing – between Systems (and Actors), the Service selections should be on the same granular basis.
Perform this task for each data flow exchange of PI between systems.
This detailed conversion into Service operations can then be synthesized into consolidated sets of Service actions per System involved in the Use Case.
On further iteration and refinement, the engaged Services can be further delineated by the appropriate Functions and Mechanisms for the relevant privacy controls.
Each Service is composed of a set of operational Functions, reflected in defined business processes and technical solutions.
The Functions step is critical because it necessitates either designating the particular business process or technical mechanism being implemented to support the Services required in the use case or the absence of such a business process or technical mechanism.
Up to this point in the PMRM methodology, the primary focus of the use case analysis has been on the “what” - PI, policies, control requirements, the Services needed to manage privacy. Here the PMRM requires a statement of the “how” – what business processes and technical mechanisms are identified as providing expected functionality.
Objective Once the requirements in the Use Case have been converted into operational Services, an overall risk assessment should be performed from that operational perspective
Constraint Additional controls may be necessary to mitigate risks within Services. The level of granularity is determined by the Use Case scope. Provide operational risk assessments for the selected Services within the use case.
Goal A ‘first pass’ through the Tasks above can be used to identify the scope of the Use Case and the underlying privacy policies and constraints. Additional iterative passes would serve to refine the Use Case and to add detail. Later passes could serve to resolve “TBD” sections that are important, but were not previously developed.
Note that a ‘single pass’ analysis might mislead the PMRM user into thinking the Use Case was fully developed and understood. Iterative passes through the analysis will almost certainly reveal further details. Keep in mind that the ultimate objective is to develop insight into the Use Case sufficient to provide a reference model for an operational, Service-based, solution.
Iterate the analysis in the previous sections, seeking further refinement and detail.
The PMRM as a “model” is abstract and appropriately so because use cases will open up the needed levels of detail. It is also a very richly detailed, multi-step but intentionally open-ended methodology.
The emergence over time of profiles, sector-specific implementation criteria, and interoperability testing, implemented through explicit, executable, and verifiable methods, will lead to the development of detailed compliance and conformance criteria and may be included as part of a separate implementation guide.
In the meantime, the following statements indicate whether, and if so to what extent, each of the Tasks outlined in Sections 3 to 7 above are to be used in a target work product (such as a privacy analysis, privacy impact assessment, privacy management framework, etc.) that can claim conformance with the PMRM as currently documented.
The terms “MUST”, “REQUIRED’, “RECOMMENDED’, and “OPTIONAL” are used below in conformance with [RFC 2119].
Any work product claiming conformance with PMRM v1.0
1. MUST result from the documented performance of the Tasks outlined in Sections 2 to 7 above;
2. Tasks #1-3, 5-18 are REQUIRED;
3. Tasks # 19 and 20 are RECOMMENDED;
4. Task #4 is OPTIONAL.
Note: This section 8 is for information and reference only. It is not part of the normative text of the document
As explained in the introduction, every specialized domain is likely to create and use a domain-specific vocabulary of concepts and terms that should be used and understood in the specific context of that domain. PMRM is no different and this section contains such terms.
In addition, a number of “operational definitions” are intended to be used in the PMRM to support development of the “Detailed Privacy Use Case Analysis” described in Section 4. Their use is completely optional, but may be helpful in organizing privacy policies and controls where there are inconsistencies in definitions across policy boundaries or where existing definitions do not adequately express the operational characteristics associated with Fair Information Practices/Principles.
The following 14 Fair Information Practices/Principles are composite definitions derived from a review of a number of relevant international legislative instruments. These operational FIPPs can serve as a sample set, as needed. Note however that there is no single and globally accepted set of FIPPs and the PMRM does not require use of these composite definitions.
Functionality enabling reporting by the business process and technical systems which implement privacy policies, to the data subject or Participant accountable for ensuring compliance with those policies, with optional linkages to redress and sanctions.
Functionality providing Information, in the context of a specified use, regarding policies and practices exercised within a Privacy Domain including: definition of the Personal Information collected; its use (purpose specification); its disclosure to parties within or external to the domain; practices associated with the maintenance and protection of the information; options available to the data subject regarding the processor’s privacy practices; retention and deletion; changes made to policies or practices; and other information provided to the data subject at designated times and under designated circumstances.
Functionality, including support for Sensitive Information, Informed Consent, Change of Use Consent, and Consequences of Consent Denial, enabling data subjects to agree to the collection and/or specific uses of some or all of their Personal Information either through an affirmative process (opt-in) or implied (not choosing to opt-out when this option is provided).
Collection Limitation and Information Minimization
Functionality, exercised by the information processor, that limits the information collected, processed, communicated and stored to the minimum necessary to achieve a stated purpose and, when required, demonstrably collected by fair and lawful means.
Functionality, exercised by the information processor, that ensures that Personal Information will not be used for purposes other than those specified and accepted by the data subject or provided by law, and not maintained longer than necessary for the stated purposes.
Functionality that enables the transfer, provision of access to, use for new purposes, or release in any manner, of Personal Information managed within a Privacy Domain in accordance with notice and consent permissions and/or applicable laws and functionality making known the information processor’s policies to external parties receiving the information.
Access and Correction
Functionality that allows an adequately identified data subject to discover, correct or delete, Personal Information managed within a Privacy Domain; functionality providing notice of denial of access; and options for challenging denial when specified.
Functionality that ensures the confidentiality, availability and integrity of Personal Information collected, used, communicated, maintained, and stored; and that ensures specified Personal Information will be de-identified and/or destroyed as required.
Functionality that ensures that information collected and used is adequate for purpose, relevant for purpose, accurate at time of use, and, where specified, kept up to date, corrected or destroyed.
Functionality that ensures compliance with privacy policies, agreements and legal requirements and to give data subjects a means of filing complaints of compliance violations and having them addressed, including recourse for violations of law, agreements and policies.
Functionality, available to data subjects, that allows access to an information processors policies and practices relating to the management of their Personal Information and that establishes the existence, nature, and purpose of use of Personal Information held about the data subject.
Functionality that prevents data being collected or used in a manner that can identify a specific natural person.
Functionality that enables the communication of personal information across geo-political jurisdictions by private or public entities involved in governmental, economic, social or other activities.
Functionality that provides special handling, processing, security treatment or other treatment of specified information, as defined by law, regulation or policy.
A system-level, digital ‘proxy’ for either a (human) Participant (or their delegate) interacting with a system or a (non-human) in-system process or other agent.
Processes designed to provide reasonable assurance regarding the effectiveness and efficiency of operations and compliance with applicable policies, laws, and regulations.
A sociological construct that supports productive interaction and collaboration among multiple communities.
A process designed to provide reasonable assurance regarding the achievement of stated objectives.
A Participant having responsibility for ensuring that privacy controls and privacy constraints are implemented and managed in business processes and technical systems in accordance with policy and requirements.
PI flowing into a Privacy Domain, or a system within a Privacy Domain.
Internally Generated PI
PI created within the Privacy Domain or System itself.
To observe the operation of processes and to indicate when exception conditions occur.
PI flowing out of one system to another system within a Privacy Doman or to another Privacy Domain.
A Stakeholder creating, managing, interacting with, or otherwise subject to, PI managed by a System within a Privacy Domain.
Personal Information – any data which describes some attribute of, or that is uniquely associated with, a natural person.
Personally identifiable information – any (set of) data that can be used to uniquely identify a natural person.
Laws, regulations, contractual terms and conditions, or operational rules or guidance associated with the collection, use, transmission, storage or destruction of personal information or personally identifiable information
A collection of proposed policies and practices appropriate for a given domain resulting from use of the PMRM
An operational mechanism that controls the extent to which PII may flow between touch points.
An administrative, technical or physical safeguard employed within an organization or Privacy Domain in order to protect PII.
A physical or logical area within the use case that is subject to the control of a Domain Owner(s)
The collection of policies, processes and methods used to protect and manage PI.
Privacy Management Analysis
Documentation resulting from use of the PMRM and that serves multiple Stakeholders, including privacy officers and managers, general compliance managers, and system developers
Privacy Management Reference Model and Methodology (PMRM)
A model and methodology for understanding and analyzing privacy policies and their management requirements in defined use cases; and for selecting the technical services which must be implemented to support privacy controls.
A collection of related functions and mechanisms that operate for a specified purpose.
A collection of components organized to accomplish a specific function or set of functions having a relationship to operational privacy management.
The intersection of data flows with Privacy Domains or Systems within Privacy Domains.
The following individuals have participated in the creation of this specification and are gratefully acknowledged:
Peter F Brown, Individual Member
Gershon Janssen, Individual Member
Dawn Jutla, Saint Mary’s University
Gail Magnuson, Individual Member
Joanne McNabb, California Office of Privacy Protection
John Sabo, Individual Member
Stuart Shapiro, MITRE Corporation
Michael Willett, Individual Member
Incorporate agreed dispositions to issues raised during Second Public Review
Peter F Brown
Peter F Brown
Addition of conformance section