Chapter 23 — Privacy in governance

Chapter 23 — Privacy in governance

Lesson map

Lesson 23 published. Map, example, EX067.

flowchart TD
  N0["Learning outcomes"]
  N1["23.1 Privacy principles"]
  N2["23.2 NIST Privacy Framework"]
  N3["23.3 Assessing a new use"]
  N4["23.4 Inventory"]
  N0 --> N1 --> N2 --> N3 --> N4
  N4 --> EX["Worked example"]
  EX --> Q["Exercise EX067"]

Logical drawing

flowchart LR
  N0["Learning outcomes"]
  N1["23.1 Privacy principles"]
  N2["23.2 NIST Privacy Framework"]
  N3["23.3 Assessing a new use"]
  N4["23.4 Inventory"]
  N0 --> N1 --> N2 --> N3 --> N4 --> Q["EX067"]

[Learning outcomes]
    |
    v
[23.1 Privacy principles]
    |
    v
[23.2 NIST Privacy Framework]
    |
    v
[23.3 Assessing a new use]
    |
    v
[23.4 Inventory]
    |
    v
[Worked example] --> [Exercise EX067]

Learning outcomes

You will (1) apply privacy principles to data governance; (2) use the NIST Privacy Framework; (3) assess a new data use.

23.1 Privacy principles

Privacy and governance overlap. Purpose limitation means data collected for loyalty points should not be used for unrelated purposes without a lawful basis. Data minimisation means collecting only what is needed. Amara finds that the loyalty sign-up form asks for gender and marital status, which no process uses. She recommends removing both fields. She explains that data not collected cannot be lost, misused or need protecting, so minimisation reduces risk as well as effort. The loyalty owner agrees, and the fields are removed at the relaunch.

23.2 NIST Privacy Framework

Amara studies the NIST Privacy Framework, which organises privacy activities into functions: identify, govern, control, communicate and protect. She maps Harbourline's practices to each function and finds strengths in protect, where security controls exist, and weaknesses in identify, because there is no full inventory of personal data. She notes that the framework is voluntary and adaptable, which suits a co-operative that needs structure without heavy compliance machinery. Amara recommends starting with the identify function, because the other functions depend on knowing what personal data Harbourline holds and where.

23.3 Assessing a new use

Marketing proposes sharing member purchase data with a partner bakery for joint offers. Amara helps assess it: purpose, lawful basis, data needed, risks to members, safeguards and alternatives. She suggests that Harbourline send the offers itself to members who consent, so the bakery never receives member data. The proposal is revised accordingly. She notes that privacy assessments often find designs that achieve the business goal with less data. The bakery partnership launches with consent-based offers sent by Harbourline, and member feedback is positive in the first month.

23.4 Inventory

Following the framework's identify function, Amara starts an inventory of personal data: what is held, where, why, on which basis, who can access it and how long it is kept. She begins with loyalty, staff and customer service data. The inventory reveals a forgotten survey database with member responses from five years ago. She notes that inventories underpin both privacy compliance and governance, because organisations cannot govern data they do not know they hold. The survey database is reviewed and then deleted with approval.

Worked example

Amara removes unused gender and marital status fields, maps Harbourline to the NIST Privacy Framework, redesigns a bakery partnership so data are not shared and starts an inventory that finds an old survey database.

Synthetic case. Practices are synthetic; the NIST Privacy Framework 1.0 is real.

Errors and limits

Collecting data just in case increases risk without benefit.

Exercises

• EX067 — Removed fields. Which fields did Amara recommend removing? Rubric: 3 = gender and marital status;; 2 = both;; 1 = one;; 0 = none.
• EX068 — Bakery redesign. How was the bakery proposal changed? Rubric: 3 = Harbourline sends offers itself to consenting members;; 2 = partly correct;; 1 = vague;; 0 = none.
• EX069 — Forgotten database. What did the inventory find? Rubric: 3 = an old survey database;; 2 = partly correct;; 1 = vague;; 0 = none.

Continue studying — lesson 23 (chapter 23 of 40)

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