Information technology — Business operational view — Part 12: Privacy protection requirements (PPR) on information life cycle management (ILCM) and EDI of personal information (PI)

This document: — provides method(s) for identifying, in Open-edi modelling technologies and development of scenarios, the additional requirements in business operational view (BOV) specifications for identifying the additional external constraints to be applied to recorded information in business transactions relating to personal information of an individual, as required by legal and regulatory requirements of applicable jurisdictional domains; — integrates existing normative elements in support of privacy and data protection requirements as are already identified in ISO/IEC 14662 and ISO/IEC 15944-1, ISO/IEC 15944-2, ISO/IEC 15944-4, ISO/IEC 15944-5, ISO/IEC 15944-8, ISO/IEC 15944-9 and ISO/IEC 15944-10; — provides overarching, operational ‘best practice’ statements for associated (and not necessarily automated) processes, procedures, practices and governance requirements that act in support of implementing and enforcing technical mechanisms which support the privacy/data protection requirements necessary for implementation in Open-edi transaction environments; — focuses on the life cycle management of personal information, i.e. the contents of SPIs (and their SRIs) related to the business transaction interchanged via EDI as Information Bundles (IBs) and their associated Semantic Components (SCs) among the parties to a business transaction. NOTE Privacy protection requirements (PPR) on information life cycle management (ILCM) and EDI of personal information as stated in this document primarily via enumerated rules which serve as a minimum set of ILCM policy and operational requirements for all recorded information pertaining to a business transaction in particular, as well as ILCM implementation in any organization in general. This document does not specify the technical mechanisms, i.e. functional support services (FSV) which are required to support BOV-identified requirements. Detailed exclusions to the scope of this document are provided in Annex H.

Technologies de l'information — Vue opérationnelle d'affaires — Partie 12: Exigences en matière de protection de la vie privée (PPR) relatives à la gestion du cycle de vie de l’information (ILCM) et de l'EDI des renseignements personnels (PI)

General Information

Status
Published
Publication Date
30-Jun-2025
Current Stage
6060 - International Standard published
Start Date
01-Jul-2025
Due Date
22-Mar-2025
Completion Date
01-Jul-2025
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Standard
ISO/IEC 15944-12:2025 - Information technology — Business operational view — Part 12: Privacy protection requirements (PPR) on information life cycle management (ILCM) and EDI of personal information (PI) Released:1. 07. 2025
English language
120 pages
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International
Standard
ISO/IEC 15944-12
Second edition
Information technology — Business
2025-07
operational view —
Part 12:
Privacy protection requirements
(PPR) on information life cycle
management (ILCM) and EDI of
personal information (PI)
Technologies de l'information — Vue opérationnelle d'affaires —
Partie 12: Exigences en matière de protection de la vie privée
(PPR) relatives à la gestion du cycle de vie de l’information
(ILCM) et de l'EDI des renseignements personnels (PI)
Reference number
© ISO/IEC 2025
All rights reserved. Unless otherwise specified, or required in the context of its implementation, no part of this publication may
be reproduced or utilized otherwise in any form or by any means, electronic or mechanical, including photocopying, or posting on
the internet or an intranet, without prior written permission. Permission can be requested from either ISO at the address below
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ISO copyright office
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Published in Switzerland
© ISO/IEC 2025 – All rights reserved
ii
Contents Page
Foreword .v
Introduction .vi
1 Scope . 1
2 Normative references . 1
3 Terms and definitions . 2
4 Abbreviated terms .29
5 Fundamental privacy protection principles .31
5.1 Overview .31
5.2 Primary sources of privacy protection principles .32
5.3 Key eleven (11) privacy protection principles .32
5.4 Link to “consumer protection” and “individual accessibility” requirements . 33
5.5 Privacy protection principles in the context of ILCM requirements . 34
5.6 Requirement for tagging (or labelling) sets of personal information (SPIs) in support of
privacy protection requirements (PPR) . 34
5.7 Requirements for making all personal information (PI) available to the buyer where
the buyer is an individual . 35
5.8 Rules governing ILCM aspects of personal information profiles (PIPs) . 35
6 Integrated set of information life cycle management (ILCM) principles in support of
information law and privacy protection requirements (PPR) .37
6.1 Primary purpose.37
6.2 Information life cycle management (ILCM) principles that support privacy protection
requirements (PPR) . 38
6.2.1 conformance with privacy protection requirements (PPR) and associated
information law requirements . 38
6.2.2 Direct relevance, informed consent and openness . 39
6.2.3 Ensuring that personal information is “under the control of” the organization
throughout its ILCM . 40
6.2.4 Limiting use, disclosure and retention .41
6.2.5 Timely, accurate, relevant .43
6.2.6 Data integrity and quality .45
6.2.7 Safeguards for non-authorized disclosure requirements .45
6.2.8 Back-up, retention and archiving . 46
6.2.9 Disposition and expungement .47
6.2.10 Organizational archiving .47
6.2.11 Historical, statistical and/or research value .47
6.3 Requirement for tagging (or labelling) data elements in support of privacy protection
requirements (PPR) . 48
7 Rules governing ensuring accountability for and control of personal information (PI) .49
7.1 Purpose . 49
7.2 Key aspects of Open-edi requirements . 49
7.3 Key aspects of “under the control of” . 49
7.4 “under the control of” in support of PPR and in an ILCM context . 50
7.5 Implementing “under the control of” and accountability .51
8 Rules governing the specification of ILCM aspects of personal information .56
8.1 Overview . 56
8.2 Rules governing establishing ILCM responsibilities for personal information (PI).57
8.3 Rules governing establishing specifications for retention of personal information
(PI) — applicable “SRI retention triggers” .59
8.4 Rules governing identification and specification of state changes of personal
information (PI) .62
8.4.1 General requirements .62
8.4.2 Specification of state changes allowed to personal information (PI) . 63

© ISO/IEC 2025 – All rights reserved
iii
8.4.3 Specification of store change type . 65
8.4.4 Rules governing specification of source of state changes .67
8.5 Rules governing disposition of personal information (PI). 68
8.6 Rules governing the establishment and maintenance of record retention and disposal
schedules (RRDS) for sets of personal information (SPIs) .71
9 Data conversion, data migration and data synchronization .73
9.1 Purpose . 73
9.2 Rules governing data conversion of set(s) of personal information (SPI) . 73
9.3 Rules governing requirements for data synchronization of sets of personal information
(SPI) .74
10 Rules governing the EDI of personal information (PI) between a primary ILCM Person
and its agent, third party and/or regulator . 76
10.1 General requirements .76
10.2 ILCM rules pertaining to use of an “agent” by a Person . 77
10.3 ILCM rules pertaining to use of a “third party” by a Person . 77
10.4 ILCM rules pertaining to the use of a “regulator” by a Person . 78
11 Conformance statement .79
11.1 Overview . 79
11.2 Conformance to the ISO/IEC 14662 Open-edi reference model and the ISO/
IEC 15944series . 79
11.3 Conformance to ISO/IEC 15944-12 . 79
11.4 Conformance by agents and third parties to ISO/IEC 15944-12 . 80
Annex A (normative) Consolidated controlled vocabulary definitions and associated terms,
as human interface equivalents (HIEs), with cultural adaptability: English and French
language equivalency in an IT standardization context .81
Annex B (normative) Consolidated set of rules in the ISO/IEC 15944 series of particular
relevance to privacy protection requirements (PPR) as external constraints on business
transactions which apply to personal information (PI) in an ILCM requirements context .85
Annex C (informative) Business transaction model (BTM): Classes of constraints .101
Annex D (normative) Linking ILCM rules to process phases rules of a business transaction .104
Annex E (normative) Generic approach to ILCM decisions in a PPR context — ILCM conformance
decision tree and associated rules .106
Annex F (informative) Generic approach to identification of properties and behaviours of
personal information (PI) as transitory records and their disposition/expungement .109
Annex G (informative) Notes on referential integrity and privacy protection transactional
integrity (PPTI) in Open-edi among IT systems .111
Annex H (informative) Exclusions to the scope of ISO/IEC 15944-12 .113
Annex I (informative) Aspects not currently addressed in this document.115
Bibliography .118

© ISO/IEC 2025 – All rights reserved
iv
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.
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 or www.iec.ch/members_experts/refdocs).
ISO and IEC draw attention to the possibility that the implementation of this document may involve the
use of (a) patent(s). ISO and IEC take no position concerning the evidence, validity or applicability of any
claimed patent rights in respect thereof. As of the date of publication of this document, ISO and IEC had not
received notice of (a) patent(s) which may be required to implement this document. However, implementers
are cautioned that this may not represent the latest information, which may be obtained from the patent
database available at www.iso.org/patents and https://patents.iec.ch. ISO and IEC shall not be held
responsible for identifying any or all such patent rights.
Any trade name used in this document is information given for the convenience of users and does not
constitute an endorsement.
For an explanation of 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 www.iso.org/iso/foreword.html.
In the IEC, see www.iec.ch/understanding-standards.
This document was prepared by Joint Technical Committee ISO/IEC JTC 1, Information technology,
Subcommittee SC 32, Data management and interchange.
This second edition cancels and replaces the first edition (ISO/IEC 15944-12:2020), of which it constitutes a
minor revision.
The changes are as follows.
— Annex A was revised to coordinate with other parts of the ISO/IEC 15944 series.
— The whole document was updated and revised according to changes in the ISO/IEC Part 2 Directives and
the introduction of the ISO House Style.
A list of all parts in the ISO/IEC 15944 series can be found on the ISO and IEC websites.
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 and
www.iec.ch/national-committees.

© ISO/IEC 2025 – All rights reserved
v
Introduction
0.1  Purpose and overview
Modelling business transactions using scenarios and scenario components includes specifying the
applicable constraints on the data content using explicitly stated rules. ISO/IEC 14662 identifies two basic
classes of constraints, "internal constraints" and "external constraints". External constraints apply to most
business transactions. External constraints have governance over any processing of personal information
including that exchanged among parties to a business transaction and doing so from an information life
cycle management (ILCM) requirements perspective.
Jurisdictional domains are the primary source of external constraints on business transactions (see
Annex C). Privacy protection requirements in turn are a common requirement of most jurisdictional
domains, although they may also result from explicit scenario demands from or on the parties involved in
a business transaction. (Requirements for secrecy or confidentiality are not addressed in this document,
unless they are implicitly needed to apply privacy protection requirements to data).
The focus of this document is on any kind of recorded information concerning identifiable living individuals
as buyers in a business transaction or whose personal information is used in a business transaction or any
type of commitment exchange.
This document describes the added business semantic descriptive techniques needed to support ILCM
aspects as part of privacy protection requirements when modelling business transactions using the
external constraints of jurisdictional domains. ILCM aspects are central to the ability to ensure that privacy
protection requirements (PPR) are passed on and supported among all the parties to a business transaction
using EDI.
This document applies to any organization which receives, creates, process, maintains, communicates, etc.
personal information (PI) and, in particular, to those who receive, create, capture, maintain, use, store or
dispose of sets of recorded information (SRIs) electronically. This document applies to private and public
sector activities of Persons irrespective of whether such activities are undertaken on a for-profit or not-for-
profit basis.
This document is intended for use by those organizations to which privacy protection requirements apply
and who therefore need to ensure that the recorded information (electronic records and transactions) in
their IT Systems is trustworthy, reliable and recognized as authentic. Typical users of this document include:
a) managers of private and public sector organizations;
b) IT systems and records/information management system professionals;
c) privacy protection officers (PPOs) and other personnel in organizations, including those responsible for
risk management; and
d) legal professionals and others within an organization responsible for information law compliance by
the organization.
0.2  Use of ISO/IEC 14662 and ISO/IEC 15944
1)
0.2.1  ISO/IEC 14662: Open-edi reference model
2)
ISO/IEC 14662 states the conceptual architecture necessary for carrying out electronic business
transactions among autonomous parties. That architecture identifies and describes the need to have two
separate and related views of the business transaction.
1) The Memorandum of Understanding between ISO, IEC, ITU and UN/ECE (2000)
concerning standardization in the field of electronic business is based on this Model.
See https://www.unece.org/fileadmin/DAM/oes/MOU/2000/24March2000_IEC_ISO_ITU.pdf.
2) ISO/IEC 14662 is freely-available at https://standards.iso.org/ittf/PubliclyAvailableStandards/index.html.

© ISO/IEC 2025 – All rights reserved
vi
The first is the business operational view (BOV). The second is the functional service view (FSV).
ISO/IEC 14662:2010, Figure 1, illustrates the Open-edi environment. For definitions of the terms used, see
Clause 3.
Figure 1 — Open-edi reference model environment
ISO/IEC 15944 is a multipart eBusiness standard which is based on and focuses on the BOV perspective of
the ISO/IEC 14662 Open-edi reference model. This document focuses on addressing commonly definable
3)
aspects of external constraints that relate to ILCM in a privacy and data protection context when the
source is a jurisdictional domain. A useful characteristic of external constraints is that, at the sectoral
level, national and international levels, etc., focal points and recognized authorities often already exist.
The rules and common business practices in many sectoral areas are already known. Use of this document
(and related standards) addresses the transformation of these external constraints (business rules) into
specified, registered, and re-useable scenarios and scenario components.
This document is based on ISO/IEC 14662 as well as existing parts of the ISO/IEC 15944 series, which serve
as its key normative references and overall boundaries for the scope of this document. ISO/IEC 15944-5
and ISO/IEC 15944-8, in particular, serve as the basis for this document as they both focus on external
constraints.
0.2.2  ISO/IEC 15944-1: Business operational view (BOV) — Operational aspects of Open-edi for
implementation
ISO/IEC 15944-1 states the requirements of the BOV aspects of Open-edi in support of electronic business
transactions. They are required to be taken into account in the development of business semantic descriptive
techniques for modelling e-business transactions and components thereof as re-useable business objects.
They include:
— commercial frameworks and associated requirements;
3) “Privacy protection” is the common set of worldwide requirements. In the European Union, “data protection” is the
equivalent concept (used mainly due to historical reasons). In many other non-European countries, (Australia, Canada,
New Zealand, USA, etc., "privacy" is the legal term used in applicable legislation and pursuant regulations. This is because
"privacy" applies to not just "data" but any form of recorded information containing "personal information". Thus, from
an international standards perspective "privacy protection" integrates "privacy" and "data protection" requirements. In
many other countries, "privacy" is the legal term used in applicable legislation and pursuant regulations.

© ISO/IEC 2025 – All rights reserved
vii
— legal frameworks and associated requirements;
— public policy requirements particularly which apply to individuals, i.e. are rights of individuals,
which are of a generic nature such as consumer protection, privacy protection, and accessibility (see
ISO/IEC 15944-5:2008, 6.3);
— requirements arising from the need to support cultural adaptability. This includes meeting localization
and multilingual requirements, (e.g. as can be required by a particular jurisdictional domain or desired
to provide a good, service and/or right in a particular market). Here, one needs the ability to distinguish,
the specification of scenarios, scenario components, and their semantics, in the context of making
commitments, between:
a) the use of unique, unambiguous and linguistically neutral identifiers (often as composite identifiers)
at the information technology interface level among the IT systems of participation parties on the
one hand; and, on the other,
b) their multiple human interface equivalent (HIE) expressions in a presentation form appropriate to
the Persons involved in the making of the resulting commitments.
Figure 2, based on ISO/IEC 15944-1:2025, Figure 3, shows an integrated view of these business operational
requirements. Since the focus of this document is that of external constraints for which jurisdictional
domains are the primary source, these primary sources have been shaded in Figure 2.

© ISO/IEC 2025 – All rights reserved
viii
Figure 2 — Integrated view of business operational requirements with an external constraints focus
In electronic business transactions, whether undertaken on a for profit or not-for-profit basis, the key
element is commitment exchange among Persons made through their decision-making applications (DMAs)
of their information technology systems (IT Systems, see ISO/IEC 14662:2010, 5.2) acting on behalf of
"Persons". "Persons" are the only entities able to make commitments.

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ix
There are three categories of Person as a role player in Open-edi, namely: (1) the Person as "individual",
4)
(2) the Person as "organization", and (3) the Person as "public administration" . There are also three basic
(or primitive) roles of Persons in business transactions, namely: "buyer", "seller" and "regulator". When
modelling business transactions, jurisdictional domains prescribe their external constraints in the role of
"regulator" and execute them as "public administration".
0.2.3  Link to ISO/IEC 15944-5 and ISO/IEC 15944-8
ISO/IEC 15944-5 focuses on external constraints the primary source of which is jurisdictional domains, at
various levels. It also identified a common class of external constraints known as “public policy”, which apply
where and when the “buyer” in a business transaction is an “individual”. It identified three key sub-types,
along with applicable rules; of public policy constraints, namely: “consumer protection”, “privacy protection”
and “individual accessibility” (see ISO/IEC 15944-5:2008, 6.3). In addition, ISO/IEC 15944-5 specifies how
and where (common) external constraints of jurisdictional domains impact the “Person”, “process”, and
“data “components of the business transaction model (BTM), as introduced in ISO/IEC 15944-1.
ISO/IEC 15944-8, which is based on ISO/IEC 15944-5, focuses on providing a more detailed identification
and specification of the common privacy protection requirements as they apply to any business transaction
where the buyer is an individual.
This document:
— is based on both ISO/IEC 15944-5 and ISO/IEC 15944-8;
— integrates applicable concepts and definitions, principles, rules, etc., found in both ISO/IEC 15944-5 and
ISO/IEC 15944-8 (as well as applicable elements of the Open-edi reference model and other parts of the
ISO/IEC 15944 series); and
— focuses on information life cycle management (ILCM) aspects at a more granular level, i.e. that required
to be able to support implementation of the same.
0.3  Link to Privacy-by-Design (PbD)approach
5)
The overall purpose of the Privacy-by-Design (PbD) approach is to ensure that privacy protection
requirements (as stated in applicable legal and/or regulatory requirements) are identified and specified in a
systematic and rule-based manner for those developing any IT systems within their organization.
It is noted that although this is the first part in the ISO/IEC 15944 series in which Privacy-by-Design is
formally mentioned, the PbD approach has always been supported and “imbedded” in the development of the
ISO/IEC 15944 series. The need to conform with and support privacy protection requirements was already
incorporated in ISO/IEC 15944-1:2025, D.1.1.
The development of the ISO/IEC 15944 series fully supports the seven “foundation principles” of the PbD
approach. In particular, it provides the detailed rules, definitions and related guidelines necessary to ensure
that privacy protection requirements are identified and implemented not only throughout the entire life
cycle of the recorded information involved, i.e. “cradle-to-grave”, information life cycle management (ILCM)
but especially that for any personal information interchanged via EDI among parities to a particular business
transaction.
0.4 Importance and role of terms and definitions
The ISO/IEC 15944 series sets out the processes for achieving a common understanding of the business
operational view (BOV) from commercial, legal, ICT, public policy and cross-sectoral perspectives. It is
4) While “public administration” is one of the three distinct sub-types of Person, most of the rules in this document
applicable to “organization” also apply to “public administration”. In addition, an unincorporated seller is also deemed
to function as an “organization”. Where it is necessary to bring forward specific rules, constraints, properties, etc., which
apply specifically to “public administration”, this is stated explicitly.
5) The seven foundation principles of “Privacy-by-Design are: 1. Proactive and not reactive; preventative and not
reactive; 2. Privacy as the default setting; 3. Privacy embedded in design; 4. Full functionality – positive-sum, not zero-
sum; 5. End to end security – full lifecycle protection; 6. Visibility and transparency – keep it open; 7. Respect for user
privacy – keep it user-centric.

© ISO/IEC 2025 – All rights reserved
x
therefore important to check and confirm that a “common understanding” in any one of these domains is
also unambiguously understood as identical in the others.
This subclause is included in each part of the ISO/IEC 15944 series to emphasize that harmonized concepts
and definitions (and assigned terms) are essential to the continuity of the overall series.
In order to minimize ambiguity in the definitions and their associated terms, each definition and its
associated term has been made available in at least one language other than English in the document in
which it is introduced. In this context, it is noted that ISO/IEC 15944-7 already also contains human interface
equivalents (HIEs) in Chinese, French, and Russian.
0.5  Based on rules and guidelines
This document is intended to be used by diverse sets of users having different perspectives and needs (see
Figure 2).
The ISO/IEC 15944 series focuses on "other precise criteria to be used consistently as rules, guidelines, or
definitions of characteristics, to ensure that materials, products, processes and services are fit for their
purpose".
Open-edi is based on rules which are predefined and mutually agreed to. They are precise criteria and
agreed-upon requirements of business transactions representing common business operational practices
and functional requirements.
These rules also serve as a common understanding bridging the varied perspectives of the commercial
6)
framework, the legal framework, the information technology framework, standardisers, consumers, etc.
0.6  Use of “Person”, “organization”, “individual” and “party” in the context of business transaction
and commitment exchange
Throughout this document:
— the use of Person with a capital "P" represents Person as a defined term, i.e. as the entity within an Open-
edi Party that carries the legal responsibility for making commitment(s);
— "individual", "organization", and "public administration" are defined terms representing the three
common sub-types of "Person"; and
— the use of the words “person(s)” and “party (ies)” without a capital “P” indicates their use in a generic
context independent of “Person”, as a defined concept in ISO/IEC 14662 and the ISO/IEC 15944 series.
NOTE A "party" to a business transaction has the properties and behaviours of a "Person”.
0.7 Use of “identifier” (in a business transaction) and roles of an individual
ISO/IEC 15944-1:2025, 6.1.4 focuses on the requirement for the unambiguous identification of entities in
business transactions (see also ISO/IEC 15944-1:2025, Annex C). "Unambiguous" is a key issue in business
transactions because states of ambiguity and uncertainty are an anathema from commercial, legal,
consumer and information technology perspectives. Issues of unambiguousness apply to all aspects of a
business transaction and even more so to those which are EDI-based. Open-edi transactions anticipate that
all entities are fully and clearly identified prior to the instantiation of a business transaction.
0.8  Use of "jurisdictional domain" in the context of privacy protection and related ILCM requirements
The term "jurisdiction" has many possible definitions. Some definitions of “jurisdiction” have accepted
international legal status while others do not. It is also common practice to equate "jurisdiction" with
"country", although the two are by no means synonymous. It is also common practice to refer to states,
provinces, länder, cantons, territories, municipalities, etc., as "jurisdictions", and in contract law it is
6) The working principle is that of "coordinated autonomy", i.e. all parties are autonomous. Therefore, the extent to
which they cooperate, agree on common needs, business rules constraints, practices, etc., and reach agreement on the
same in form of precise rules, terms and definitions, etc., is a key influence on the creation of necessary standards as well
as common scenarios, scenario attributes and scenario components.

© ISO/IEC 2025 – All rights reserved
xi
customary to specify a particular court of law as having jurisdiction or a defined national body, or an
international body as having jurisdiction (even if that is not legally enforceable), and so on. Finally, there are
differing "legal" definitions of "jurisdiction". Readers should understand that in this document:
— the use of the term "jurisdictional domain" represents its use as a defined term; and
— the use of the terms “jurisdiction(s)” and/or “country (ies)” represents their use in their generic contexts
and do not imply any legal effect per se.
0.9  Use of “privacy protection” in the context of business transaction, EDI and any type of commitment
exchange
Jurisdictional domains, such as UN member states (and/or their administrative sub-divisions), have enacted
various “privacy” laws, “data protection” laws, “protection of personal information” laws, etc. (as well as
pursuant regulations). Some of these sources of legal requirements focus on the protection of personal
information in IT systems only (e.g. “data protection”), while others focus on the protection of personal
information irrespective of the medium (see ISO/IEC 15944-1:2025, 6.4.1) used for the recording of personal
information and/or its communication to other Persons.
In the case of personal information, this is currently defined by most jurisdictional domains to be a specific
sub-set of recorded information relating to the Person as an “individual” — where the qualities of such type
of Person are that they are required to be an identifiable, living individual. As a consequence, this may only
apply to some proportion of the specific role players in a business transaction (including their personae) and
not others.
The delivery of “privacy protection” requires action both at the business operational level (BOV) and
functional services view (FSV) (or technology levels). Where human beings interact with recorded
information once it has passed through an Open-edi transaction, they have the potential to compromise
technical controls (FSV) that could have been applied. It is essential that business models take into account
the need to establish overarching business processes that address issues that have not been, and/or cannot
be resolved by the technical FSV controls applied so as to provide the overall privacy protection demands of
regulation that are required to be applied to personal data, their use, prescribed dissemination and so on. In
this regard, the interplay of the BOV and FSV views of all organizations is important.
0.10  Use of “set of recorded information” (SRI) and “set of personal information” (SPI) versus record,
document, message, data, etc.
The concepts of “record”, “document”, “data”, “message”, etc., are defined and used in ISO standards and
in different levels of jurisdictional domains. However, multiple differing definitions exist for each of these
terms. To address this polysemy issue, the unifying concept and definition of “set of recorded information”
was introduced and defined in ISO/IEC 15944-5.
In Open-edi, SRIs are modelled as Information Bundles (IBs) and Semantic Components (SCs) when they
are interchanged among participating parties in a business transaction. Within the IT systems of an
organization, and especially within its decision-making applications (DMAs), the recorded information
pertaining to a business transaction is usually maintained as one or more (linked) SRIs.
In order to maximize linkages between Open-edi (external behaviour) aspects and data management
(internal behaviour) aspects of an organization (as well as associated record management and EDIFACT
standards), SRI is used as a common higher level concept, which incorporates essential attributes of the
concepts of “record”, “document”, “message”, etc. as defined in various ways in existing ISO standards.
Where and when an SRI is of the nature of personal information or contains personal information, privacy
protection requirements (PPR) apply. Within the context of PPR and with the focus of ILCM the concept and
definition of “set of personal information (SPI)” is as follows:
— set of personal information (SPI) (see 3.127);
— set of recorded information (SRI) which is of the nature of or contains personal information (see 3.128).

© ISO/IEC 2025 – All rights reserved
xii
This document focuses on ILCM of personal information in support of PPR and as such “set of personal
information (SPI)” is used throughout this document while “set of recorded information (SRI) when referring
to the more generic ILCM aspects.
0.11  Aspects currently not addressed
This first edition of this document focuses on the essential and basic ILCM aspects of privacy protection
requirements.
Many other aspects identified in the development of this document remain to be addressed. For detailed
information, see Annex I.
0.12  IT-systems environment neutrality
This document, like all the other parts of ISO/IEC 15944, does not assume nor endorse any specific system
environment, database management system, database design paradigm, system development methodology,
data definition language, command language, system interface, user interface, syntax, computing platform,
or any technology required for implementation, i.e. it is information technology neutral. At the same
time, this document maximizes an IT-enabled approach to its implementation and maximizes semantic
interoperability.
0.13  Organization and description of this document
This document identifies basic common requirements of information life cycle management (LCM)
requirements in a privacy protection context, as external constraints of jurisdictional domains, on the
modelling of a business transaction through scenarios and scenario components.
For the human interface equivalents (HIEs) of each term in Clause 3 in French, Annex A applies.
Following Clauses 0, 1, 2, 3 and 4, which have a common approach and similar content in the ISO/IEC 15944
series, Clause 5 summarizes the 11 Fundamental privacy protection principles introduced and defined in
detail in ISO/IEC 15944-8:—, Clause 5 along with its associated rules and guidelines. Clause 5 also provides a
link to related “consumer protection” and “individual accessibility” requirements. A key purpose of Clause 5
is to place privacy protection principles in the content of ILCM requirements. A related purpose is to bring
forward the requirement that any and all sets of personal information (SPIs) are identified, i.e. tagged or
labelled, as such in support of privacy protection requirements.
Clause 6 identifies an integrated (minimum) set of ILCM principles along with associated rules and
guidelines required to support both general information law requirements and in particular those required
to be implemented in support of privacy protection requirements.
Clause 7 focuses on the need to ensure accountability for and control of personal information by any
organization (or public administration). Clause 8 expands on this by providing the rules governing
specification of ILCM aspects of personal information, i.e. from an implementation perspective.
The fact that in their “normal” operations organizations need to undertake data conversions and data
migration in the decision-making applications (DMAs) of their IT systems is recognized in Clause 9. However,
it is also important that applicable privacy protection requirements remain being supported, i.e. within and
among, organizations including data synchronization among their IT systems.
Clause 10 summarizes key rules and requirements found in ISO/IEC 15944-1, ISO/IEC 15944-5 and
ISO/IEC 15944-8 which govern EDI of personal information between the primary ILCM Person, i.e. seller,
and its use of agents and/or third parties. The clause concludes with a conformance statement.
Finally, annexes are provided for elaboration of points raised in the main body. Of these, Annexes A and B
are normative, and the remaining annexes are informative.
Annex A is a consolidated list of the definitions and their associated terms introduced in this document in
English and French. For the complete set of French (and Russian and Chinese) equivalents of the entries in
Clause 3, see ISO/IEC 15944-7. As stated in the main body of this document, the issue of semantics and their
importance of identifying the correct interpretation across official aspects is critical.

© ISO/IEC 2025 – All rights reserved
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Annex B identifies rules stated in the other parts of ISO
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