Posted by Wayne on March 2, 2012
Next approach was to try something that I figured this would be an easy step – run a few searches on the Internet and I’d probably have too many privacy assessments to choose from. Instead what I got was a lot of commercial consulting companies that have all developed their own assessments. Now what? More searches – only directed and emails to friends and friends of friends! I found three that seemed to be pretty good choices and also finding them detailed in an article written by Roger Clarke on Privacy Impact Assessments helped support the use of them.
DHS/DOJ Privacy Impact Assessment – The first one is the only mandated privacy assessment in the US which is mandated by the DHS/DOJ when deploying a new government system (also someone government specific as well). Since it is a privacy impact assessment it is designed to be used as a ‘pre-assessment’ before a system is implemented. I couldn’t determine the provenance of the DHS/DOJ PIA but I had to assume that it is a ‘best practice’ and is reviewed by the office of the CPO. Also the DHS/DOJ PIA only has 40 questions in it making it the briefest of assessments.
ISO/IEC 22307:2008 Financial Services Privacy Impact Assessment – This is an international standard and is financial services biased. It is also a pre-assessment instrument and has a total of 102 questions. I had to purchase this assessment for my research from ANSI who manages ISO standards here in the US.
SharedAssessments Privacy Assessment – Shared Assessments is a not-for-profit group that was created by leading financial institutions and accounting firms. The instrument I used was an earlier version and was freely available. However if you wish to access the tools today you have to become a member.The SharedAssessments tool that I used has 127 questions.
So these the three assessments I used. In my next post I’ll talk about the cloud providers I choose and why.
p.s. There is a bit of irony that I want to mention – a complete book on privacy impact assessments was published just recently that may be useful if you are interested in knowing more about this topic: Privacy Impact Assessment (Law, Governance, and Technology Series).
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Posted by Wayne on February 11, 2012
Over the next few months I’ll finally be able to come out of hiding … not that I’ve been doing anything stealthy or that exciting even. I’ve been working on completing the hardest thing I’ve ever under taken in my life – a PhD. Four and a half calendar years and literally well over a thousand hours of time. For some I guess this is something they know they are going to do when they are young and full of energy and strong of heart and mind but for me this was my mid-life-crises.
Anyway – the coolest outcomes are: I definitely think a little different about things and the research that I got to do has some interesting and (I think) valuable results.
My initial goal was to do something epic, far reaching, and somehow alter the way we think about things. Did I accomplish that? Yes for me I did. I had some outstanding help from some great minds on my dissertation committee that helped me to explore a few things that will add to the science regarding privacy. I learned a lot from the body of knowledge already out there, from and about myself, and from those who supported me through the process.
The topic of study was “An Empirical Study of Privacy Risk Assessment Methodologies in Cloud Computing Environments” the initial abstract was published here and it has changed to look more like this. The abstract is not the only thing to change – the hypothesis changed, the research questions changed, and even the methodology changed. Fortunately what didn’t change was the data.
For this post I’m just going to share the research questions:
Q1.Do existing privacy assessment methods adequately assess privacy risk exposures of cloud computing for the enterprise?
Q2.By using the scoring system (outlined in the methodology section) are the new characteristics in cloud computing such as on-demand/self-service, broad network access, measured services, shared resources, and elasticity adequately evaluated or accommodated in existing privacy assessment methods?
The drivers for these questions were based on some basic phenomena that I had observed 4 years ago when I started looking for problems to explore. First and foremost I was (and still am) so excited about cloud computing. In my opinion Cloud is the most interesting technical thing to happen since the 80’s and Vax/VMS clusters ruled the computing world. The second thing that I realized was that privacy was also a domain that seemed to be important and was so incredibly polarizing with my peers in school and colleagues at work. The last thing that I noticed was that we seem to have this blind belief system and trust in assessment methods. Security folk call it checklist compliance – find a good checklist, check things off, and everything will be fine.
In the privacy domain risk assessments are very immature compared to the security world. Also what got me thinking about all this was – who says we’re asking the right questions? When we’re done why can’t we have a risk score like with our credit card score? I found some work done by Dr. George Yee (Estimating the Privacy Protection Capability of a Web Service Provider) that became the basis for my inquiry – how do we get assurances of privacy when we connect with web service providers?
More to come soon …
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