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Privacy by Design as a system design strategy - EIC 2019

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Sagara Gunathunga
Sagara Gunathunga

1) Privacy by Design (PbD) is an approach to system design that emphasizes privacy and data protection through the entire lifecycle. The 7 PbD principles include making privacy the default, embedding privacy into design, and keeping systems user-centric and transparent. 2) To apply PbD, personal data should be separated from other business data and stored securely in a separate system. Standard protocols like SAML and OAuth2 should be used to share personal data securely. 3) When designing a personal data repository, transparency, data minimization, and giving users control over their data through a self-care portal are important considerations.

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Privacy By Design as a System Design Strategy Sagara Gunathunga Director, WSO2 sagara@wso2.com
About Me ● Director of Identity & Access Management at WSO2 ● Mainly focuses on WSO2 Identity and Access Management (IAM) offerings ● Core member of WSO2's effort in making its products and business processes GDPR compliant ● PMC member and committer for a number of Apache projects including Apache Axis2 and Apache Web Services
One Global Market
Global Privacy Outlook D Data Protection Act PIPEDA Privacy Act of 1988 HIPAA, COPPA, CCPA, etc.. Information Technology Act Personal Information Protection Act Personal Data Protection Bill POPI
Privacy is a Fundamental Human Right: GDPR
Take Back Control Of Your Personal Information: Ccpa
7 GDPR CCPA DPA One Way To Look At This Challenge
An Alternative Way to Look at the Problem
Privacy by Design (PbD) Principles 1 2 3 4 5 6 7 Proactive not reactive - preventative not remedical Lead with privacy as the default setting Embed privacy into design Retain full functionality(positive-sum, not zero-sum) Ensure end-to-end security Maintain visibility and transparency-keep it open Respect user privacy-keep it user-centric
Well… How can we Put These Principles into ACTION
Separate Personal Data (PII) from Other Business Data
12 Personal Data (PII)
A Typical System of a Business Organization Personal information is scattered all over the system
A Typical System of a Business Organization Personal information (user data) is scattered all over the system
● Number of systems to protect ● Number of systems to modify and replace to support privacy standards ● Personal data removal needs changes in multiple places ● Increased chance of personal data breaches A Typical System Of A Business Organization
Solution Move all the personal information (user data) into a separate system so that other applications can look-up user data on demand
● Reduce development and maintenance cost ● Reduce development and maintenance time ● Reduce system complexity ● Reduce the chance of personal data breaches ● Can adopt to future expansions easily Solution
Wait... My Organization Uses A Number Of Cloud Applications ?
Solution Most cloud applications today facilitate connecting to your corporate user management system as a trusted identity provider (trusted IdP)
Apply Anonymization and Pseudonymization into your Design
Anonymization Vs Pseudonymization Anonymization X Medical Report Medical Report John Doe SID536262 Pseudonymization Medical Report Medical Report John Doe SID536262 Name SID John Doe SID536262
Apply Anonymization and Pseudonymization into your Design System-Id Identity and Access Management System
Use Standard Protocols and Security Tokens for PII Sharing
Standard Protocols and Security Tokens ● Use standard transport security protocols and latested tools ○ TLS/SSL ○ Strong algorithm and key for hashing/encryption ● Use standard protocols ○ SAML ○ OAuth2/OIDC ○ WS-Federation ● Use standard security tokens over custom tokens ○ SAML tokens ○ JWT, OIDC IDToken
Standard Protocols and Security Tokens
Pick the Correct Token Type ● OAuth2 Bearer By Reference ● SAML 2.0 ● JWT ● OIDC IDToken By Value
Consideration for PII Repository Design
Provide Transparency Be transparent on ‘why’ you need specific PII data, how do you going to store and process, how long you retain those data. Source : https://startwithwhy.com/
Provide Transparency Source : https://startwithwhy.com/ Example, in a mobile application, ● Clearly show ‘location service’ icon when the app utilize customer location. ● Clearly show ‘bluetooth’ icon when the app communicate with another device via bluetooth.
Minimize PII data collection and storing ● Make sure to capture absolutely necessary set of PII only for current purposes. ● Consider data retention policy and implement data removal logic as a core requirement. ● Preference on storing results instead of raw PII data. ● Try to depend on system generated ids for identification. ● Use hashing and encryption whenever possible on PII data.
Minimize PII Data Collection and Storing Example : In a restaurant recommendation application, capture nearest city for processing instead of exact coordination of the user. Example : In a mobile application, use system generated id to track usages data of the application instead of mobile number or IMEI id.
Focus on Consent Management
Focus on Consent Management
Make Customer in Control on Own Data
Make Customer in Control on Their Data
Solution Provide a self-care user portal for users so that they can exercise their individual rights
Solution ● Individuals can access, modify, and remove their personal information ● Data processing activities can be informed and made transparent ● Individuals can download a copy of their personal data ● Can have a medium to submit ‘forget-me’ requests
References ● https://wso2.com/solutions/regulatory-compliance/gdpr/ ● https://docs.wso2.com/display/IS550/General+Data+Protection+Regulation ● https://ec.europa.eu/justice/smedataprotect/index_en.htm ● https://www.smashingmagazine.com/2017/07/privacy-by-design-framework/
THANK YOU wso2.com

More Related Content

Privacy by Design as a system design strategy - EIC 2019

  • 1. Privacy By Design as a System Design Strategy Sagara Gunathunga Director, WSO2 sagara@wso2.com
  • 2. About Me ● Director of Identity & Access Management at WSO2 ● Mainly focuses on WSO2 Identity and Access Management (IAM) offerings ● Core member of WSO2's effort in making its products and business processes GDPR compliant ● PMC member and committer for a number of Apache projects including Apache Axis2 and Apache Web Services
  • 4. Global Privacy Outlook D Data Protection Act PIPEDA Privacy Act of 1988 HIPAA, COPPA, CCPA, etc.. Information Technology Act Personal Information Protection Act Personal Data Protection Bill POPI
  • 5. Privacy is a Fundamental Human Right: GDPR
  • 6. Take Back Control Of Your Personal Information: Ccpa
  • 7. 7 GDPR CCPA DPA One Way To Look At This Challenge
  • 8. An Alternative Way to Look at the Problem
  • 9. Privacy by Design (PbD) Principles 1 2 3 4 5 6 7 Proactive not reactive - preventative not remedical Lead with privacy as the default setting Embed privacy into design Retain full functionality(positive-sum, not zero-sum) Ensure end-to-end security Maintain visibility and transparency-keep it open Respect user privacy-keep it user-centric
  • 10. Well… How can we Put These Principles into ACTION
  • 11. Separate Personal Data (PII) from Other Business Data
  • 13. A Typical System of a Business Organization Personal information is scattered all over the system
  • 14. A Typical System of a Business Organization Personal information (user data) is scattered all over the system
  • 15. ● Number of systems to protect ● Number of systems to modify and replace to support privacy standards ● Personal data removal needs changes in multiple places ● Increased chance of personal data breaches A Typical System Of A Business Organization
  • 16. Solution Move all the personal information (user data) into a separate system so that other applications can look-up user data on demand
  • 17. ● Reduce development and maintenance cost ● Reduce development and maintenance time ● Reduce system complexity ● Reduce the chance of personal data breaches ● Can adopt to future expansions easily Solution
  • 18. Wait... My Organization Uses A Number Of Cloud Applications ?
  • 19. Solution Most cloud applications today facilitate connecting to your corporate user management system as a trusted identity provider (trusted IdP)
  • 21. Anonymization Vs Pseudonymization Anonymization X Medical Report Medical Report John Doe SID536262 Pseudonymization Medical Report Medical Report John Doe SID536262 Name SID John Doe SID536262
  • 22. Apply Anonymization and Pseudonymization into your Design System-Id Identity and Access Management System
  • 23. Use Standard Protocols and Security Tokens for PII Sharing
  • 24. Standard Protocols and Security Tokens ● Use standard transport security protocols and latested tools ○ TLS/SSL ○ Strong algorithm and key for hashing/encryption ● Use standard protocols ○ SAML ○ OAuth2/OIDC ○ WS-Federation ● Use standard security tokens over custom tokens ○ SAML tokens ○ JWT, OIDC IDToken
  • 25. Standard Protocols and Security Tokens
  • 26. Pick the Correct Token Type ● OAuth2 Bearer By Reference ● SAML 2.0 ● JWT ● OIDC IDToken By Value
  • 28. Provide Transparency Be transparent on ‘why’ you need specific PII data, how do you going to store and process, how long you retain those data. Source : https://startwithwhy.com/
  • 29. Provide Transparency Source : https://startwithwhy.com/ Example, in a mobile application, ● Clearly show ‘location service’ icon when the app utilize customer location. ● Clearly show ‘bluetooth’ icon when the app communicate with another device via bluetooth.
  • 30. Minimize PII data collection and storing ● Make sure to capture absolutely necessary set of PII only for current purposes. ● Consider data retention policy and implement data removal logic as a core requirement. ● Preference on storing results instead of raw PII data. ● Try to depend on system generated ids for identification. ● Use hashing and encryption whenever possible on PII data.
  • 31. Minimize PII Data Collection and Storing Example : In a restaurant recommendation application, capture nearest city for processing instead of exact coordination of the user. Example : In a mobile application, use system generated id to track usages data of the application instead of mobile number or IMEI id.
  • 32. Focus on Consent Management
  • 33. Focus on Consent Management
  • 34. Make Customer in Control on Own Data
  • 35. Make Customer in Control on Their Data
  • 36. Solution Provide a self-care user portal for users so that they can exercise their individual rights
  • 37. Solution ● Individuals can access, modify, and remove their personal information ● Data processing activities can be informed and made transparent ● Individuals can download a copy of their personal data ● Can have a medium to submit ‘forget-me’ requests
  • 38. References ● https://wso2.com/solutions/regulatory-compliance/gdpr/ ● https://docs.wso2.com/display/IS550/General+Data+Protection+Regulation ● https://ec.europa.eu/justice/smedataprotect/index_en.htm ● https://www.smashingmagazine.com/2017/07/privacy-by-design-framework/