ISO/IEC 29190:2015

INTERNATIONAL ISO/IEC
STANDARD 29190
First edition
2015-08-15
Information technology — Security
techniques — Privacy capability
assessment model
Technologies de l’information — Techniques de sécurité — Modèle
d’évaluation de l’aptitude à la confidentialité
Reference number
©
ISO/IEC 2015
© ISO/IEC 2015, Published in Switzerland
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ii © ISO/IEC 2015 – All rights reserved

Contents Page
Foreword .iv
Introduction .v
1 Scope . 1
2 Normative references . 1
3 Terms and definitions . 1
4 Methodology . 1
4.1 Introduction . 1
4.2 Define a privacy capability assessment model . 2
4.3 Capability scale . 4
4.4 Rate the process’s current capability vs. target capability . 5
4.5 Determine sub-optimal processes . 6
4.6 Identify proposals for changing processes . 6
4.7 Modify processes . 7
5 Capability assessment process . 7
5.1 Introduction . 7
5.2 Plan the assessment . 7
5.3 Identify privacy activities and target capabilities . 8
5.4 Identify privacy-related processes. 9
5.5 Prepare criteria for information collection . 9
5.6 Collect and analyse information .10
5.7 Present results .11
6 Example of a business function approach .11
Bibliography .15
© ISO/IEC 2015 – All rights reserved iii

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 meaning of ISO specific terms and expressions related to conformity
assessment, as well as information about ISO’s adherence to the WTO principles in the Technical
Barriers to Trade (TBT), see the following URL: Foreword — Supplementary information.
The committee responsible for this document is ISO/IEC JTC 1, Information technology, SC 27, Security
techniques.
iv © ISO/IEC 2015 – All rights reserved

Introduction
The aim of this International Standard is to provide organizations with high-level guidance about how
to assess the level of their ability (capability) to manage privacy-related processes. This International
Standard focuses on an approach for assessing the efficiency and effectiveness of privacy-related
processes used by organizations.
Guidance on the issue of privacy management needs is multi-faceted as follows:
— The decision support information useful to a senior executive in formulating and executing a privacy
strategy is different from the decision support useful to operational and line-of-business staff even
though their various activities might all ultimately be directed towards the same goal;
— There are likely to be multiple “privacy stakeholders” (that is, parties who have an interest in the way
the organization manages privacy). Those stakeholders might impose very different requirements,
for example, driven by legal and regulatory compliance requirements, but also by inter-related
“good practice” provisions stipulated, for example, by policies, codes-of-conduct, business risk
assessments, audit findings, reputational, and/or financial imperatives and/or personal privacy
preferences.
A broader, good practice context is important because it is possible for an organization to meet its
legal and regulatory compliance obligations and still suffer significant damage if it fails to address the
requirements of the other stakeholders. An assessment of the organization’s capabilities in this area
will need to meet the following principal sets of criteria:
— It needs to provide the organization with information which is useful to the appropriate level or
levels of management;
— It needs to cater for the fact that “capability” needs to be assessed in many different domains (legal
compliance, risk management, reputation, and so on).
This International Standard is aimed at those individuals responsible for directing, managing, and
operating an organization’s privacy management capabilities, or those responsible for advising
the relevant stakeholder group. Thus, the capability model will consider multiple kinds of privacy
stakeholder requirements and will result in guidance to multiple levels of stakeholders, from enterprise
strategists to operational and line-of-business managers.
This International Standard provides guidance for how to set up a capability assessment program
within an organization. It is expected that the management of the organization will need to apply an
iterative and incremental process of improvement using the criteria defined for assessing their privacy
capability. Once a baseline assessment has been identified and a set of targets for improvement of the
organization’s capability has been agreed, then the assessment will need to be periodically repeated in
order to move the organization, over increments, towards the targeted level of capability desired by the
organization.
This International Standard guides organizations towards the production of several different kinds of
output:
— an overall “score” against a simple capability assessment model;
— a set of metrics indicating assessment against key performance indicators;
— the detailed outputs from privacy process management audits and management practices (for
example, assessment against data protection criteria and data custody best practice) for input into
improving capability in these specific areas.
© ISO/IEC 2015 – All rights reserved v

INTERNATIONAL STANDARD ISO/IEC 29190:2015(E)
Information technology — Security techniques — Privacy
capability assessment model
1 Scope
This International Standard provides organizations with high-level guidance about how to assess their
capability to manage privacy-related processes.
In particular, it
— specifies steps in assessing processes to determine privacy capability,
— specifies a set of levels for privacy capability assessment,
— provides guidance on the key process areas against which privacy capability can be assessed,
— provides guidance for those implementing process assessment, and
— provides guidance on how to integrate the privacy capability assessment into organizations
operations.
2 Normative references
The following documents, in whole or in part, are normatively referenced in this document and are
indispensable for its application. For dated references, only the edition cited applies. For undated
references, the latest edition of the referenced document (including any amendments) applies.
ISO/IEC 29100, Information technology — Security techniques — Privacy framework
ISO/IEC 33001:2015, Information technology — Process assessment — Concepts and terminology
ISO/IEC 33020:2015, Information technology — Process assessment — Process measurement framework
for assessment of process capability
3 Terms and definitions
For the purposes of this document, the terms and definitions given in ISO/IEC 29100 and ISO/IEC 33001
and apply.
4 Methodology
4.1 Introduction
In the current global environment, there is a tendency towards collection, use, disclosure and retention
of more and more personally identifiable information (PII), for purposes ranging from support
for business operations to national security and law enforcement. As is evident from the regular
notification of privacy breaches, much more work is required on the part of organizations to adequately
protect the PII that they are collecting, using, disclosing and retaining, as required by relevant national
regulatory laws.
© ISO/IEC 2015 – All rights reserved 1

One way to develop and refine an organization’s processes is to begin with an assessment of their
existing capabilities in this area. To perform a process assessment in the privacy domain, typically
involves the following activities:
— Define a privacy capability assessment model (see 4.2);
— Define a capability scale (see 4.3);
— Rate the process’s current capability vs. target capability (see 4.4);
— Determine sub optimal processes (see 4.5);
— Identify proposals for changing processes (see 4.6);
— Modify processes (see 4.7);
— Identify the privacy activities and target capability (see 5.1);
— Identify the privacy-related processes (see 5.4);
— Prepare criteria for information collection (see 5.5);
— Collect and analyse information from privacy-related processes (5.6).
An optional additional subsequent action is to map the capability determination (i.e. the target
capability level) to a scale taken from a process assessment model to assist in goal setting, comparative
analysis (i.e. to measure current capability and use as a baseline for assessing an incremental process
improvement target), and continual improvement strategies (i.e. develop a context or business function
improvement strategy to use in planning for a process improvement project).
This International Stand
...