Chapter 14 — Privacy foundations

Chapter 14 — Privacy foundations

Lesson map

Lesson 14 published. Map, example, EX040.

flowchart TD
  N0["Learning outcomes"]
  N1["14.1 Principles"]
  N2["14.2 Processing map"]
  N3["14.3 Joining privacy and security"]
  N4["Synthesis"]
  N0 --> N1 --> N2 --> N3 --> N4
  N4 --> EX["Worked example"]
  EX --> Q["Exercise EX040"]

Logical drawing

flowchart LR
  N0["Learning outcomes"]
  N1["14.1 Principles"]
  N2["14.2 Processing map"]
  N3["14.3 Joining privacy and security"]
  N4["Synthesis"]
  N0 --> N1 --> N2 --> N3 --> N4 --> Q["EX040"]

[Learning outcomes]
    |
    v
[14.1 Principles]
    |
    v
[14.2 Processing map]
    |
    v
[14.3 Joining privacy and security]
    |
    v
[Synthesis]
    |
    v
[Worked example] --> [Exercise EX040]

Learning outcomes

You will (1) apply data protection principles to tenant data; (2) map personal data processing; (3) link privacy and security governance.

14.1 Principles

Sofia studies data protection principles common to modern privacy laws: lawful and fair processing, purpose limitation, data minimisation, accuracy, storage limitation, security and accountability. She applies them to Elmfield. Tenant data are collected to manage tenancies and repairs, so using them for unrelated marketing would breach purpose limitation. Old records of former tenants kept for decades breach storage limitation. She notes that these principles overlap with security but also cover fairness and individuals' rights. Fairness, for instance, has no direct security control, so it needs separate attention in Elmfield's governance.

14.2 Processing map

Sofia builds a record of processing activities: what personal data Elmfield holds, why, where they come from, who receives them and how long they are kept. She finds that repairs contractors receive too much data, that support needs are stored in two systems and that nobody knows how long call recordings are kept. The NIST Privacy Framework offers a structure for managing privacy risk that she uses to organise her findings alongside security ones. Not knowing how long call recordings are kept is a storage limitation gap that needs a retention decision and an owner.

14.3 Joining privacy and security

Sofia recommends that Elmfield run privacy and security governance together, with one risk register and shared owners. A misdirected email is both a security incident and a personal data breach that may need reporting. Retention rules reduce the data an attacker could steal. She learns that privacy and security are distinct but strongly linked, and that separate programmes often duplicate effort and miss risks that sit between them, such as excessive data sharing with suppliers. Excessive data sharing with repairs contractors is exactly such a risk, found during both her network and privacy work.

Worked example

Sofia applies privacy principles, maps processing with three gaps and recommends joint privacy and security governance.

Synthetic case. Elmfield's processing is synthetic; the NIST Privacy Framework is real.

Errors and limits

Laws differ by country. Mappings go out of date.

Exercises

• EX040 — Purpose breach. Which use of tenant data would breach purpose limitation? Rubric: 3 = unrelated marketing;; 2 = marketing;; 1 = repairs;; 0 = none.
• EX041 — Processing gaps. Name two gaps found in the processing map. Rubric: 3 = excess contractor data and unknown call recording retention;; 2 = gaps;; 1 = vague;; 0 = none.
• EX042 — Joint example. Why is a misdirected email both a security and privacy matter? Rubric: 3 = it is a security incident and a personal data breach;; 2 = both;; 1 = vague;; 0 = none.

Synthesis

Privacy principles and security governance work best as one programme with shared owners.

Continue studying — chapter 14 of 40

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