Information Privacy

by Poorva Dange

Introduction

With the rise of a data-saturated world, the issue of information privacy has become a way of paramount concern to an organization of any size and industry. The effects of data breaches, cyberattacks, and the misuse of personally identifiable information (PII) can cause losses, legal penalties, and reputation damage. It is against this background that the ISO 27001 standard offers an internationally recognized framework in managing information security risks with special considerations given on privacy prior.

Information Privacy

Information Privacy: Core Principles ISO 27001

Right at the core, ISO 27001 is intended to safeguard the confidentiality, integrity, and availability of information assets such as personal data and PII. Particular principles direct its policy

1. Confidentiality: Private or sensitive data can be accessed only by authorized persons and processes.

2. Integrity: Data should not be modified, altered, or changed without permission.

3. Accessibility: Information availability must be at the required time but must be accessible to the authorized personnel within the organization given that information security guidelines have been established.

The three are fundamental to all information security management but ISO 27001 has developed its set of controls and requirements to place an emphasis on privacy as new global laws come into effect, and risks around personal data proliferate.

Legal Environment: Privacy Laws and Regulatory

International privacy rules including the General Data Protection Regulation (GDPR) issued by the European Union, the Consumer Privacy Act by California, and the Digital Personal Data Protection Act by India have placed enormous demands on compliance. Organizations are required to follow obligations such as:

  1. A legitimate consent to the processing of personal data

  2. Prompt communication of breach to regulators and victims

  3. Safe international payments

  4. Personal data owners have rights to access, correct, and erase or port their data

Annex A 5.34 Privacy & Protection of PII

Annex A 5.34: Privacy and Protection of Personally Identifiable Information is one of the most important new features in the new versions of ISO 27001. With this control organizations are required to:

  1. Identify and meet the legal, regulatory, contractual and stakeholder requirements (related to privacy and PII)

  2. Implement organizational and technical controls to prevent unauthorized access, disclosure, and modification or destruction of PII

  3. Establish roles and responsibilities, including use of Data Protection Officers or Privacy Officers to oversee privacy

  4. Determine policies to deal with, classify, retain, share and dispose of PII

  5. Keep up with the laws of a county and translate them into the usage of the privacy process of a country, on a regular basis

By incorporating the measures, organizations will be able to not only comply with evolutions around compliance but be confident with their customers and partners.

Information Privacy

The ISO 27001 and Data Privacy: Theory to Practice

Classification and Handling of Data

ISO 27001 demands a clear description of which data is stored, where it is stored, and in what categories (public, internal, confidential and highly confidential). Precise classification leads to sensitive personal information being given appropriate protection and not to excessive or inadequate protections.

  • Implement firewalls, access controls and encryption of confidential or highly confidential categories

  • Train users on the actual methods of handling and disposing sensitive data securely

  • Track traffic flows and possible exposures in the organization.

Policies and Procedures On Privacy

  • All organizations require written guidelines on how to capture, utilize, share and retain personal information.

  • Ensure that privacy policies are consistent with applicable laws and regulations

  • Policy communication to employees, customers, third parties

  • Include privacy as supplier agreement terms and diligence measures 

Technical And Organizational Measures

ISO 27001 requires security measures that integrate both technology and organizational approaches to securing PII:

Technical

  • Personal data protection in transit and at rest
  • Sensitive systems requiring multi-factor authorization to access
  • Real-time detection and notification of data access or transferring without authorization
  • Frequent- earning of vulnerabilities
  • Data masking and anonymization of data to test and use in analytics

Organizational

  • Staff awareness programme privacy training
  • Designation of Privacy/Data Protection Officer
  • Procedures of privacy breach incident response
  • Periodic privacy impact reviews
  • Procedures of change and retention, and disposal of personal data

Privacy Management Extensions (ISO 27701 And Related Standards)

ISO 27701 is based upon ISO 27001, extending it to provide entities with special frameworks and controls to manage PII as controllers and processors of such data.

Other applicable standards are,

ISO / IEC 29100: Privacy Framework and Guidelines

ISO/IEC 27018: Privacy on the public cloud providers

ISO/IEC 29134: Privacy impact assessment guidance

Best Practice In Privacy Implementation In ISO 27001

1. Carry out a Privacy Gap Assessment: find out in what respects work practices are not meeting privacy law or ISO 27001 requirements, and close up those loopholes.

2. Use Privacy by Design: Adopt privacy prescriptions directly into systems and processes, not as an add-on.


3. Adopt a Data Privacy Register: Keep PII type/data flow/access controls/international transfer.

 

4. Continuous Training and Awareness: All staff members need to learn and appreciate the aspect of privacy, know how to identify personal data, and adhere to security measures.

 

5. Supplier Due Diligence: Evaluate privacy practices of suppliers and business partners, including the contract and conformance certifications.

6. Proactive Incident Management: Proactively plan responses to incident situations (useful in protecting against data breaches), including how to contain, notify, and recover.

Issues of Privacy Management and ISO 27001

  • Global Variant: Privacy legislation differs across nations, and controls must change and update regularly.

  • Complexity of Data Mapping: The contemporary organizations are dealing with colossal amounts of data; defining flows and dependencies may be a resource-intensive process.
     
  • Supplier/Third Party Risk: There are additional privacy risks by way of outsourcing processes.

  • Human Error: There still exist training gaps and accidental disclosures, contributing to the leading causes of privacy breaches.

Combating these challenges involves good leadership, good documentation, and culture of vigilance.

Conclusion

The risk of information privacy transcends a technology issue, it is a pillar of trust, compliance, and competitive advantage in the digital age. ISO 27001 is a comprehensive framework to reinforce privacy protection within all of the information security management functions, such as policy and process, technical controls and continuous improvement. Organizations that establish privacy controls in accordance with ISO 27001 as well as extend them using standards, such as ISO 27701 are better placed to prevent breaches, incurring regulatory penalties, and long-lasting trust with customers, regulators, and partners. With the rate of digital change rising and the spread of laws of privacy expanding, there is no end in sight to the strategic value that such effective privacy management holds in the context of ISO 27001.