ISO - IEC 29100 2011 - Amd 1 2018 Ed.1 - Id.73722 Publication PDF (En)

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INTERNATIONAL ISO/IEC

STANDARD 29100

First edition
2011-12-15
AMENDMENT 1
2018-06

Information technology — Security


techniques — Privacy framework
AMENDMENT 1: Clarifications
Technologies de l'information — Techniques de sécurité — Cadre privé
AMENDEMENT 1: Clarifications

Reference number
ISO/IEC 29100:2011/Amd.1:2018(E)

© ISO/IEC 2018
ISO/IEC 29100:2011/Amd.1:2018(E)


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ISO/IEC 29100:2011/Amd.1:2018(E)


Foreword
ISO (the International Organization for Standardization) and IEC (the International Electrotechnical
Commission) form the specialized system for worldwide standardization. National bodies that are
members of ISO or IEC participate in the development of International Standards through technical
committees established by the respective organization to deal with particular fields of technical
activity. ISO and IEC technical committees collaborate in fields of mutual interest. Other international
organizations, governmental and non-governmental, in liaison with ISO and IEC, also take part in the
work. In the field of information technology, ISO and IEC have established a joint technical committee,
ISO/IEC JTC 1.
The procedures used to develop this document and those intended for its further maintenance are
described in the ISO/IEC Directives, Part 1. In particular the different approval criteria needed for
the different types of document should be noted. This document was drafted in accordance with the
editorial rules of the ISO/IEC Directives, Part 2 (see www​.iso​.org/directives).
Attention is drawn to the possibility that some of the elements of this document may be the subject
of patent rights. ISO and IEC shall not be held responsible for identifying any or all such patent
rights. Details of any patent rights identified during the development of the document will be in the
Introduction and/or on the ISO list of patent declarations received (see www​.iso​.org/patents).
Any trade name used in this document is information given for the convenience of users and does not
constitute an endorsement.
For an explanation on the voluntary nature of standards, the meaning of ISO specific terms and
expressions related to conformity assessment, as well as information about ISO's adherence to the
World Trade Organization (WTO) principles in the Technical Barriers to Trade (TBT) see the following
URL: www​.iso​.org/iso/foreword​.html.
This document was prepared by Technical Committee ISO/IEC JTC 1, Information technology,
Subcommittee SC 27, IT Security techniques.
Any feedback or questions on this document should be directed to the user’s national standards body. A
complete listing of these bodies can be found at www​.iso​.org/members​.html.

© ISO/IEC 2018 – All rights reserved  iii


ISO/IEC 29100:2011/Amd.1:2018(E)

Information technology — Security techniques — Privacy


framework
AMENDMENT 1: Clarifications
Introduction, third paragraph, first sentence
Replace “international standard” with “document”:
In some jurisdictions, this document’s references to privacy safeguarding requirements might be
understood as being complementary to legal requirements for the protection of PII.

Introduction, last paragraph


Replace “international standard” with “document”:
Some jurisdictions might require compliance with one or more of the documents referenced
in ISO/IEC JTC 1/SC 27 WG 5 Standing Document 2 (WG 5 SD2) — Official Privacy Documents
References [3] or with other applicable laws and regulations, but this document is not intended to
be a global model policy, nor a legislative framework.

2.6
Delete the definition of identify:
2.6
(withdrawn)

2.7
Delete the definition of identity:
2.7
(withdrawn)

© ISO/IEC 2018 – All rights reserved  1


ISO/IEC 29100:2011/Amd.1:2018(E)


2.9
Change the terminological entry as follows:

2.9
personally identifiable information
PII
any information that (a) can be used to establish a link between the information and the natural
person to whom such information relates, or (b) is or can be directly or indirectly linked to a natu-
ral person

NOTE The “natural person” in the definition is the PII principal (2.11). To determine whether a PII
principal is identifiable, account should be taken of all the means which can reasonably be used by
the privacy stakeholder holding the data, or by any other party, to establish the link between the
set of PII and the natural person.

2.20
Change the terminological entry as follows:

2.20
privacy impact assessment
PIA
privacy risk assessment
overall process of identifying, analysing, evaluating, consulting, communicating and planning the
treatment of potential privacy impacts with regard to the processing of personally identifiable
information, framed within an organization's broader risk management framework

[SOURCE: ISO/IEC 29134:2017, 3.7, modified — “privacy risk assessment” has been added as an
admitted term.]

4.5, last paragraph, second item of list


Replace with the following to synchronize item text with the text from Figure 1:

— contractual factors such as agreements between and among several different actors, company
policies and binding corporate rules;

4.5.2, second paragraph


Replace the paragraph with the following:
In principle, any party that has access to PII should be made aware of its obligations by the
respective PII controller(s) in a formalized manner, for example, by entering into third-party
agreements. Such agreements are likely to contain a number of privacy safeguarding requirements
that recipients of PII will have to take into account. In certain jurisdictions, national and regional
authorities might have established legal and contractual instruments that enable the transfer of PII
to third parties.

2  © ISO/IEC 2018 – All rights reserved


ISO/IEC 29100:2011/Amd.1:2018(E)


4.5.3, second paragraph


Replace the paragraph with the following:
Many business factors do not have a direct impact on privacy safeguarding requirements as such.
The envisaged use of PII is likely to affect an organization’s implementation of privacy policies, as
well as the choice of privacy controls. However, the organization should not change the privacy
principles it subscribes to because of that. For example, offering a certain service might require a
service provider to collect additional PII or to allow more of its employees to process certain types
of PII. However, a PII controller that has subscribed to the principles contained in this framework
should still carefully assess which types of PII are strictly needed to provide the service (principle
of collection limitation) and to limit the processing of PII by its employees to that needed in order to
fulfil their duties (principle of data minimization).

5.1, first paragraph, first sentence


Replace “states, countries” with “countries”:
The privacy principles described in this standard were derived from existing principles
developed by a number of countries and international organizations. This framework focuses
on the implementation of the privacy principles in ICT systems and the development of privacy
management systems to be implemented within the organization’s ICT systems. These privacy
principles should be used to guide the design, development, and implementation of privacy
policies and privacy controls. Additionally, they can be used as a baseline in the monitoring and
measurement of performance, benchmarking and auditing aspects of privacy management
programs in an organization.

5.5, bullet list


Replace the list with the following:

— minimize the PII which is processed and the number of privacy stakeholders and people to
whom PII is disclosed or who are allowed to process it;

— ensure adoption of a “need-to-know” principle (i.e., one should be allowed to process only the
PII which is necessary for the conduct of his/her official duties in the framework of the legitimate
purpose of the PII processing);

— use or offer as default options, wherever possible, interactions and transactions which do not
involve the identification of PII principals, reduce the observability of their behaviour and limit the
linkability of the PII collected; and

— securely dispose of PII whenever it is practical to do so, in particular when the purpose for PII
processing has expired and where there are no legal requirements to keep it.

5.8, second list, last item


Replace “PII data” with “PII”:

— the specified PII retention and disposal requirements.

5.9, list, item 3

© ISO/IEC 2018 – All rights reserved  3


ISO/IEC 29100:2011/Amd.1:2018(E)


Replace “personal data” with “PII”:

— providing any amendment, correction or removal to PII processors and third parties to whom
PII had been disclosed, where they are known; and

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ISO/IEC 29100:2011/Amd.1:2018(E)


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