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Scott McNealy famously said "You have zero privacy - get over it". The recent stories regarding the loss of personal data have put a sharp perspective on the question of privacy. Polls show that people say they will only deal with organization that they can trust to protect their personal data. What can organizations do to achieve this trust?
Privacy What is privacy and why does it matter? In this context the concern is the capability for people to control what information about themselves is made available to other people. There is no universal agreement on what information is private; different cultures hold different views on this.
Privacy is a balance of the rights of an individual against the good of a group. Sometimes privacy is in the interests of the group as well as the individual; identity theft being one example of this. It is in everyone's interest that information that could be used to impersonate an individual should not be publicly available.
In Europe privacy of personal information is principally governed by two directives 94/96/EC on personal data, and 2002/58/EC on privacy of electronic communications. The Organization for Economic Co-operation and Development has also published a set of principles for data privacy. These principles form the basis for privacy of personal information in Europe.
Trust Trust is important since it forms the basis upon which personal and commercial transactions take place. In the context of information privacy, individuals allow their personal and private information to be held by organizations trusting that it will be stored and processed in accordance with the principals mentioned above. The recent personal data breaches are a breach of trust by the organizations holding the personal information.
What happens when there is a breach of trust? Traditionally commerce depends upon legal enforcement. However, because of difficulties of legal enforcement on the internet, new models of trust are emerging. An example of this is that adopted by eBay' where each buyer and seller has a feedback rating.
Individuals are increasingly making decisions based on their perception of trust. In September 2007 a study, conducted by the independent research consultancy YouGov, showed that concerns over Identity Theft is changing online behaviour and reveals which types of organizations the public trust to protect their personal details. For example, while 60% of respondents answered that they would trust their bank to keep their personal data secure, only 25% would trust the government.
Security Information systems security is what organizations use to ensure privacy of personal information. Models for secure information processing grew out of the needs by government and military agencies to use computing systems to handle sensitive data. These were described in the Orange Book which was replaced by the Common Criteria (ISO/ISEC 15048) for computer security. BS7799 provided a more comprehensive set of standards and best practices for information security management. This was later adopted as ISO 17799 and has now been renamed as two standards ISO 27001/2. Specific industry standards have also emerged such as the Payment Card Industry Data Security Standard (PCI-DSS). These standards are well known and yet a survey conducted by CA across 482 organizations in EMEA found that while 62% of these were holding regulated information in their IT systems:
What needs to be done? If organizations followed the letter and the spirit of the ISO27001/2 standards there would be fewer or no data breaches. It is time for compliance with these standards to become mandatory where personal data is being held and for there to be penalties for non compliance.
The card payment industry has taken a significant step towards improving protection of card data through the creation of the PCI-DSS. Any organization involved in credit card transactions needs to become fully compliant with this standard.
An important advance recommended in the UK House of Lords report on Personal Internet Security would be a data security breach notification law. This should include workable definitions of data security breaches, covering both a threshold for the sensitivity of the data lost, and criteria for the accessibility of that data. Another recommendation of that report is that major companies, particularly the software vendors, must now make the development of more secure technologies their top design priority.
There should be training and formal accreditation for people who are responsible for information security systems. In addition people in organizations who have access to regulated data should have an appropriate level of training on privacy requirements. You cannot drive a car without a driving license - so why should you be able to manage access to the personal data of thousands of people without proper training?
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