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Where possible, event logs should record access to PII, including by whom, when, which PII principal's PII was accessed, and what if any changes were made additions, modifications or deletions as a result of the event. Where multiple service providers are involved in providing services, there can be varied or shared roles in implementing this guidance. These roles should be clearly defined and included in the documented information, and agreement on any log access between providers should be addressed.

Implementation guidance for PII processors: The organization should define criteria regarding if, when and how log information can be made available to or usable by the customer. These criteria should be made available to the customer.

A procedure, preferably automatic, should be put in place to ensure that logged information is either deleted or de-identified as specified in the retention schedule see 7. The confidentiality agreement, whether part of a contract or separate, should specify the length of time the obligations should be adhered to. When the organization is a PII processor, a confidentiality agreement, in whatever form, between the organization, its employees and its agents should ensure that employees and agents comply with the policy and procedures concerning data handling and protection.

Untrusted networks can include the public internet and other facilities outside of the operational control of the organization. NOTE In some cases e. Clauses 7 and 8 provide control considerations for processing of PII, which can be useful in developing policies for privacy in systems design. For example, an organization that processes PII should ensure that, based on the relevant jurisdiction, it disposes of PII after a specified period.

The system that processes that PII should be designed in a way to facilitate this deletion requirement. Where the use of PII for testing purposes cannot be avoided, technical and organizational measures equivalent to those used in the production environment should be implemented to minimize the risks. Where such equivalent measures are not feasible, a risk-assessment should be undertaken and used to inform the selection of appropriate mitigating controls.

The agreements should call for independently audited compliance, acceptable to the customer. Implementation guidance for PII processors The organization should specify in contracts with any suppliers that PII is only processed on its instructions. Some jurisdictions impose specific regulations regarding breach responses, including notification.

Organizations operating in these jurisdictions should ensure that they can demonstrate compliance with these regulations. An event does not necessarily trigger such a review. These can include, but are not limited to, pings and other broadcast attacks on firewalls or edge servers, port scans, unsuccessful log-on attempts, denial of service attacks and packet sniffing.

When a breach of PII has occurred, response procedures should include relevant notifications and records. Some jurisdictions define cases when the breach should be notified to the supervisory authority, and when it should be notified to PII principals.

Notifications should be clear and can be required. NOTE 2 Notification can contain details such as: � a contact point where more information can be obtained; � a description of and the likely consequences of the breach; � a description of the breach including the number of individuals concerned as well as the number of records concerned; � measures taken or planned to be taken.

In the event that a breach involving PII has occurred, the record should also include a description of the PII compromised, if known; and if notifications were performed, the steps taken to notify PII principals, regulatory agencies or customers.

Implementation guidance for PII processors Provisions covering the notification of a breach involving PII should form part of the contract between the organization and the customer.

The contract should specify how the organization will provide the information necessary for the customer to fulfil their obligation to notify relevant authorities. This notification obligation does not extend to a breach caused by the customer or PII principal or within system components for which they are responsible.

The contract should also define expected and externally mandated limits for notification response times. In some jurisdictions, the PII processor should notify the PII controller of the existence of a breach without undue delay i.

In some jurisdictions, International Standards such as this document can be used to form the basis for a contract between the organization and the customer, outlining their respective security, privacy and PII protection responsibilities.

The terms of the contract can provide a basis for contractual sanctions in the event of a breach of those responsibilities. The organization should retain copies of its privacy policies and associated procedures for a period as specified in its retention schedule see 7. This includes retention of previous versions of these documents when they are updated. The implementation guidance documented in this clause relate to the controls listed in Annex A.

It is the responsibility of the organization to clearly document and communicate this to PII principals. Without a clear statement of the purpose for processing, consent and choice cannot be adequately given.

Documentation of the purpose s for processing PII should be sufficiently clear and detailed to be usable in the required information to be provided to PII principals see 7. This includes information necessary to obtain consent see 7. The legal basis for the processing of PII can include: � consent from PII principals; � performance of a contract; � compliance with a legal obligation; � protection of the vital interests of PII principals; � performance of a task carried out in the public interest; � legitimate interests of the PII controller.

The organization should document this basis for each PII processing activity see 7. The legitimate interests of the organization can include, for instance, information security objectives, which should be balanced against the obligations to PII principals with regards to privacy protection.

PII relating to children the organization should include those categories of PII in its classification schemes. The classification of PII that falls into these categories can vary from one jurisdiction to another and can vary between different regulatory regimes that apply to different kinds of business, so the organization needs to be aware of the classification s that apply to the PII processing being performed.

The use of special categories of PII can also be subject to more stringent controls. It can also require additional consent to be obtained from the PII principal. Implementation guidance Consent can be required for processing of PII unless other lawful grounds apply.

The organization should clearly document when consent needs to be obtained and the requirements for obtaining consent. It can be useful to correlate the purpose s for processing with information about if and how consent is obtained. Some jurisdictions have specific requirements for how consent is collected and recorded e. Additionally, certain types of data collection for scientific research for example and certain types of PII principals, such as children, can be subject to additional requirements.

The organization should take into account such requirements and document how mechanisms for consent meet those requirements. Implementation guidance The organization should obtain and record consent from PII principals in such a way that it can provide on request details of the consent provided for example the time that consent was provided, the identification of the PII principal, and the consent statement.

The information delivered to the PII principal before the consent process should follow the guidance in 7. The consent should be: � freely given; � specific regarding the purpose for processing; and � unambiguous and explicit. These risks should be assessed through a privacy impact assessment. Some jurisdictions define cases for which a privacy impact assessment is mandated.

Criteria can include automated decision making which produces legal effects on PII principals, large scale processing of special categories of PII e.

The organization should determine the elements that are necessary for the completion of a privacy impact assessment. Data flow diagrams and data maps can also be helpful in this context see 7. By default, all controls specified in Annex B should be assumed as relevant. If the organization decides to not require the PII processor to implement a control from Annex B, it should justify its exclusion see 5.

A contract can define the responsibilities of each party differently but, to be consistent with this document, all controls should be considered and included in the documented information. Implementation guidance Roles and responsibilities for the processing of PII should be determined in a transparent manner.

These roles and responsibilities should be documented in a contract or any similar binding document that contains the terms and conditions for the joint processing of PII.

In some jurisdictions, such an agreement is called a data sharing agreement. Such an inventory can include: � the type of processing; � the purposes for the processing; � a description of the categories of PII and PII principals e.

Such an inventory should have an owner who is responsible for its accuracy and completeness. Implementation guidance Obligations to PII principals and the means to support them vary from one jurisdiction to another. The organization should ensure that they provide the appropriate means to meet the obligations to PII principals in an accessible and timely manner.

Clear documentation should be provided to the PII principal describing the extent to which the obligations to them are fulfilled and how, along with an upto-date contact point where they can address their requests. The contact point should be provided in a similar way to that used to collect PII and consent e.

Examples of types of information that can be provided to PII principals are: � information about the purpose of the processing; � contact details for the PII controller or its representative; � information about the lawful basis for the processing; � information on where the PII was obtained, if not obtained directly from the PII principal; � information about whether the provision of PII is a statutory or contractual requirement, and where appropriate, the possible consequences of failure to provide PII; � information on obligations to PII principals, as determined in 7.

The organization should provide updated information if the purposes for the processing of PII are changed or extended. Implementation guidance The organization should provide the information detailed in 7. Where appropriate, the information should be given at the time of PII collection. It should also be permanently accessible. The mechanism used for withdrawal depends on the system; it should be consistent with the mechanisms used for obtaining consent when possible.

For example, if the consent is collected by email or a website, the mechanism for withdrawing it should be the same, not an alternative solution such as phone or fax. Some jurisdictions impose restrictions on when and how a PII principal can modify or withdraw their consent. The organization should record any request to withdraw or change consent in a similar way to the recording of the consent itself.

Any change of consent should be disseminated, through appropriate systems, to authorized users and to relevant third parties. The organization should define a response time and requests should be handled according to it. Additional information When consent for particular processing of PII is withdrawn, all the processing of PII performed before withdrawal should normally be considered as appropriate, but the results of such processing should not be used for new processing.

For example, if a PII principal withdraws their consent for profiling, their profile should not be further used or consulted. The organization should document the legal and regulatory requirements related to objections by the PII principals to processing e.

The organization should provide information to principals regarding the ability to object in these situations. Mechanisms to object can vary, but should be consistent with the type of service provided e. NOTE Records generated by the control specified in 7. Some jurisdictions impose restrictions on when and how a PII principal can request correction or erasure of their PII.

The organization should determine these restrictions as applicable and keep itself up-to-date about them. Implementation guidance The organization should take appropriate steps, bearing in mind the available technology, to inform third parties of any modification or withdrawal of consent, or objections pertaining to the shared PII.

Some jurisdictions impose a legal requirement to inform these third parties of these actions. The organization should determine and maintain active communication channels with third parties. Related responsibilities can be assigned to individuals in charge of their operations and maintenance.

When informing third parties, the organization should monitor their acknowledgement of receipt of the information. NOTE Changes resulting from the obligations to PII principals can include modification or withdrawal of consent, requests for correction, erasure, or restrictions on processing, or objections to the processing of PII as requested by the PII principal.

Implementation guidance The organization should provide a copy of the PII that is processed in a structured, commonly used, format accessible by the PII principal. Some jurisdictions define cases where the organization should provide a copy of the PII processed in a format allowing portability to the PII principals or to recipient PII controllers typically structured, commonly used and machine readable. In cases where the organization is no longer able to identify the PII principal e.

However, in some jurisdictions, legitimate requests can require that additional information should be requested from the PII principal to enable re-identification and subsequent disclosure. Where technically feasible, it should be possible to transfer a copy of the PII from one organization directly to another organization, at the request of the PII principal. Implementation guidance Legitimate requests can include requests for a copy of PII processed, or requests to lodge a complaint.

Some jurisdictions allow the organization to charge a fee in certain cases e. Requests should be handled within the appropriate defined response times. Some jurisdictions define response times, depending on the complexity and number of the requests, as well as requirements to inform PII principals of any delay.

The appropriate response times should be defined in the privacy policy. Organizations operating in these jurisdictions should take compliance with these obligations into account. Implementation guidance The organization should limit the collection of PII to what is adequate, relevant and necessary in relation to the identified purposes.

This includes limiting the amount of PII that the organization collects indirectly e. Privacy by default implies that, where any optionality in the collection and processing of PII exists, each option should be disabled by default and only enabled by explicit choice of the PII principal.

Implementation guidance Limiting the processing of PII should be managed through information security and privacy policies see 6. Processing of PII, including: � the disclosure; � the period of PII storage; and � who is able to access their PII; should be limited by default to the minimum necessary relative to the identified purposes.

Implementation guidance Organizations should identify how the specific PII and amount of PII collected and processed is limited relative to the identified purposes. This can include the use of de-identification or other data minimization techniques. The identified purpose see 7. In other cases, the identified purpose does not require the processing of the original PII, and the processing of PII which has been de-identified can suffice to achieve the identified purpose.

Mechanisms used to minimize PII vary depending on the type of processing and the systems used for the processing. The organization should document any mechanisms technical system configurations, etc. In cases where processing of de-identified data is sufficient for the purposes, the organization should document any mechanisms technical system configurations, etc.

For instance, the removal of attributes associated with PII principals can be sufficient to allow the organization to achieve its identified purpose. In other cases, other de-identification techniques, such as generalization e.

Implementation guidance The organization should have mechanisms to erase the PII when no further processing is anticipated. Alternatively, some de-identification techniques can be used as long as the resulting de-identified data cannot reasonably permit re-identification of PII principals. Other information Information systems can create temporary files in the normal course of their operation. Such files are specific to the system or application, but can include file system roll-back journals and temporary files associated with the updating of databases and the operation of other application software.

Temporary files are not needed after the related information processing task has completed but there are circumstances in which they cannot be deleted. Implementation guidance The organization should develop and maintain retention schedules for information it retains, taking into account the requirement to retain PII for no longer than is necessary.

Such schedules should take into account legal, regulatory and business requirements. Where such requirements conflict, a business decision needs to be taken based on a risk assessment and documented in the appropriate schedule. Implementation guidance The choice of PII disposal techniques depends on a number of factors, as disposal techniques differ in their properties and outcomes for example in the granularity of the resultant physical media, or the ability to recover deleted information on electronic media.

Factors to consider when choosing an appropriate disposal technique include, but are not limited to, the nature and extent of the PII to be disposed of, whether or not there is metadata associated with the PII, and the physical characteristics of the media on which the PII is stored.

Implementation guidance Transmission of PII needs to be controlled, typically by ensuring that only authorized individuals have access to transmission systems, and by following the appropriate processes including the retention of audit logs to ensure that PII is transmitted without compromise to the correct recipients. The organization should document compliance to such requirements as the basis for transfer.

Some jurisdictions can require that information transfer agreements be reviewed by a designated supervisory authority. Organizations operating in such jurisdictions should be aware of any such requirements. Implementation guidance The identities of the countries and international organizations to which PII can possibly be transferred in normal operations should be made available to customers. The identities of the countries arising from the use of subcontracted PII processing should be included.

The countries included should be considered in relation to 7. Outside of normal operations, there can be cases of transfer made at the request of a law enforcement authority, for which the identity of the countries cannot be specified in advance, or is prohibited by applicable jurisdictions to preserve the confidentiality of a law enforcement investigation see 7.

Implementation guidance Recording can include transfers from third parties of PII which has been modified as a result of PII controllers' managing their obligations, or transfers to third parties to implement legitimate requests from PII principals, including requests to erase PII e.

The organization should have a policy defining the retention period of these records. Implementation guidance PII can be disclosed during the course of normal operations. These disclosures should be recorded. Any additional disclosures to third parties, such as those arising from lawful investigations or external audits, should also be recorded. The records should include the source of the disclosure and the source of the authority to make the disclosure.

The implementation guidance documented in this clause relate to the controls listed in Annex B. Implementation guidance The contract between the organization and the customer should include the following wherever relevant, and depending on the customer's role PII controller or PII processor this list is neither definitive nor exhaustive : � privacy by design and privacy by default see 7. Some jurisdictions require that the contract include the subject matter and duration of the processing, the nature and purpose of the processing, the type of PII and categories of PII principals.

Implementation guidance The contract between the organization and the customer should include, but not be limited to, the objective and time frame to be achieved by the service.

For example, in order to efficiently utilize network or processing capacity it can be necessary to allocate specific processing resources depending on certain characteristics of the PII principal.

The organization should allow the customer to verify their compliance with the purpose specification and limitation principles. This also ensures that no PII is processed by the organization or any of its subcontractors for other purposes than those expressed in the documented instructions of the customer.

The organization should not make providing such consent a condition for receiving the service. NOTE This control is in addition to the more general control in 8. Implementation guidance Some jurisdictions can require the organization to record information such as: � categories of processing carried out on behalf of each customer; � transfers to third countries or international organizations; and � a general description of the technical and organizational security measures.

These obligations can include matters where the customer uses the services of the organization for implementation of these obligations. For example, this can include the correction or deletion of PII in a timely fashion. Where a customer depends on the organization for information or technical measures to facilitate meeting the obligations to PII principals, the relevant information or technical measures should be specified in a contract.

Implementation guidance The organization should conduct periodic verification that unused temporary files are deleted within the identified time period.

It should also make its policy available to the customer. Implementation guidance At some point in time, PII can need to be disposed of in some manner. The organization should provide the assurance necessary to allow the customer to ensure that PII processed under a contract is erased by the organization and any of its subcontractors from wherever they are stored, including for the purposes of backup and business continuity, as soon as they are no longer necessary for the identified purposes of the customer.

The organization should develop and implement a policy in respect to the disposal of PII and should make this policy available to customer when requested. The policy should cover the retention period for PII before its disposal after termination of a contract, to protect the customer from losing PII through an accidental lapse of the contract.

NOTE 8. PII transmission controls Control The organization should subject PII transmitted over a data-transmission network to appropriate controls designed to ensure that the data reaches its intended destination. The legitimate Interests ol the organization can Include, or Instance. Information security objectives, which should be balanced against the obligations to P11 principals with regards to privacy protection.

Whenever special categories of P11 are defined, either by the nature of the P11 e. P11 relatIng to children the organization should Include those categories oF P11 in its classification schemes. The classification of P11 that falls Into these categories can vary from one jurisdiction to another and can vary between different regulatory regimes that apply to difterent kInds of business, so the organization needs to be aware of the classification s that apply to the P11 processIng being performed.

It can also require additional consent to be obtained from the P11 prIncipal. Implementation guidance Consent can be required for processing of P11 unless other lawful grounds apply. The organization should clearly document when consent needs to be obtained and the requirements for obtaining consent. It can be useful to correlate the purpose s for processing with Information about if and how consent is obtained. Some jurisdictions have specific requirements for how consent Is collected and recorded eg.

Additionally, certain types of data collection for scientific research For example and certain types of P11 principals, such as children, can be subject to additional requirements. Download infomation Go to download. Note: If you can share this website on your Facebook,Twitter or others,I will share more.

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ISO/IEC 27701, Data Protection, and Risk Management: How do they map?

WebOct 18, �� ISO/IEC is one of the most used ISO standards in the world, with many companies already certified to it. ISO/IEC includes new controller- and . WebISO/IEC ISO Explanation -- General Brief explanation on how requirements of this standard are extended from ISO (basically, where ISO . WebFree PDF download: ISO � Privacy information management systems ISO/IEC is one of the most anticipated standards in information security and privacy .