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Methods	and	Tools	for	GDPR	Compliance	through	
Privacy	and	Data	
Protection	4	Engineering


Methods	and	tools	for


priv...
2
Outline
➢Privacy	and	data	protection	assurance


❑	Problem	and	context


➢Proposed	method


❑	GDPR	modelling


❑	Assuran...
3
10/03/2020 3
GDPR


Article	5


Principles	
relating	to	
processing	of	
personal	data
4
Methods	and	Tools	for	Assurance
A	method	to	support	the	systematic	capture,	
traceability	and	argumentation	of	evidence	...
5
Assurance	-	Definition
10/03/2020 5
Assurance grounds for confidence that the other four security
goals (integrity, avai...
6
Problem	and	context
➢GDPR	became	mandatory	in	May	2018,	but	the	legal	approach	is	not	enough,	we	
need	to	come	along	wit...
7
Context
10/03/2020 7
(Independent )
Safety	Assessment
Safety
Assessment
Certification
Liaison
Privacy


Assessment
(Inde...
7
Context
10/03/2020 7
Product	Engineering
“Project”
Quality
Management
Implementation
Validation	&
Verification
Design
(I...
7
Context
10/03/2020 7
Product	Engineering
“Project”
Quality
Management
Implementation
Validation	&
Verification
Design
(I...
7
Context
10/03/2020 7
Supplier	Chain
Component
Release
Module	Assurance
Case	Development
Product	Engineering
“Project”
Qu...
7
Context
10/03/2020 7
Supplier	Chain
Component
Release
Module	Assurance
Case	Development
Product	Engineering
“Project”
Qu...
8
➢This	is	Alex.	She	is	a	system	
engineer	who	works	as	the	
technical	lead	in	a	company


➢She	is	NOT	a	lawyer	and	she	fi...
9
Modelling	standards
➢Modelling	standards	provides:


❑An	unambiguous	way	to	show	the	explicit	process	for	standards	comp...
10
Assurance	method	concepts
➢Prescriptive	Knowledge	Management	is	the	assurance	area	
concerned	with	the	specification	an...
11
Assurance	method	concepts
➢Equivalence	mappings
10/03/2020 11
RefFramework


Model	


(e.g.	GDPR)
Icon Element
Activity...
11
Assurance	method	concepts
➢Equivalence	mappings
10/03/2020 11
RefFramework


Model	


(e.g.	GDPR)
Icon Element
Activity...
11
Assurance	method	concepts
➢Equivalence	mappings
10/03/2020 11
RefFramework


Model	


(e.g.	GDPR)
Icon Element
Activity...
11
Assurance	method	concepts
➢Equivalence	mappings
10/03/2020 11
RefFramework


Model	


(e.g.	GDPR)
Icon Element
Activity...
11
Assurance	method	concepts
➢Equivalence	mappings
10/03/2020 11
RefFramework


Model	


(e.g.	GDPR)
Icon Element
Activity...
12
10/03/2020 12
➢Alex	is	part	of	a	team


➢How	can	they	provide	justification	for	compliance?


➢How	can	they	trace	the	e...
13
Assurance	cases	approach
➢Assurance	cases	were	originally	used	to	show	that	systems	satisfied	their	safety-
critical	pr...
13
Assurance	cases	approach
➢Assurance	cases	were	originally	used	to	show	that	systems	satisfied	their	safety-
critical	pr...
13
Assurance	cases	approach
➢Assurance	cases	were	originally	used	to	show	that	systems	satisfied	their	safety-
critical	pr...
13
Assurance	cases	approach
➢Assurance	cases	were	originally	used	to	show	that	systems	satisfied	their	safety-
critical	pr...
14
Privacy	argument	fragment
➢Within	the	limits	defined	in	[scope]	the	application	[system	description]	is	
privacy	ensure...
14
Privacy	argument	fragment
➢Within	the	limits	defined	in	[scope]	the	application	[system	description]	is	
privacy	ensure...
15
Argument decomposition
10/03/2020 15
Context Goal
Strategy
Solution
Justification
J
Assumption
A
Solved	by
In	the	conte...
16
10/03/2020 16
16
10/03/2020 16
Security	Requirements	&	Objectives
16
10/03/2020 16
Security	Requirements	&	Objectives
Security	Evidence
16
10/03/2020 16
Security	Requirements	&	Objectives
Security	Evidence
Security	Argument
17
Evidence	model	and	compliance	models
➢Information	required	to	characterize	evidence	artefacts


❑Who	produced	it


❑Rev...
18
Evidence	management
Determine	the	
evidence	to	
provide
Collect	
evidence	item	
information
Specify	traceability	
betwe...
19
Assurance	management	concepts
➢Assurance	Project	Management,	determines	the	baseline	elements	of	an	
assurance	project	...
20
Evidence	model
➢Information	or	objective	artefacts	being	offered	in	support	of	one	or	more	claims	
[SACM]


➢Overall,	t...
21
Concepts	for	accountability
Evidences


Model	
Compliance


Map	Model
Argumentation	


model
Baseline


Model	


(e.g.	...
22
Tool	support	for	the	method
10/03/2020 22
https://www.eclipse.org/opencert/
23
Assurance	
Project	
Definition
Assurance	Case	
Management
Evidence	
Management
Compliance	
Management
Reporting
Regulat...
24
Tool	support	for	the	method
Evidence


Management
Prescriptive


Knowledge


Management
Privacy


Argumentation


Manag...
24
Tool	support	for	the	method
Evidence


Management
Prescriptive


Knowledge


Management
Privacy


Argumentation


Manag...
24
Tool	support	for	the	method
Evidence


Management
Prescriptive


Knowledge


Management
Privacy


Argumentation


Manag...
24
Tool	support	for	the	method
Evidence


Management
Prescriptive


Knowledge


Management
Privacy


Argumentation


Manag...
24
Tool	support	for	the	method
Evidence


Management
Prescriptive


Knowledge


Management
Privacy


Argumentation


Manag...
24
Tool	support	for	the	method
Evidence


Management
Prescriptive


Knowledge


Management
Privacy


Argumentation


Manag...
25
10/03/2020 25
26
10/03/2020 26
27
10/03/2020 27
28
10/03/2020 28
29
10/03/2020 29
30
10/03/2020 30


Methods	and	Tools	for	GDPR	Compliance	through	
Privacy	and	Data	
Protection	4	Engineering


Reference	frameworks


Expli...
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  1. 1. 
 Methods and Tools for GDPR Compliance through Privacy and Data Protection 4 Engineering 
 Methods and tools for 
 privacy and data protection 
 assurance Tecnalia, UPM 10/03/2020
  2. 2. 2 Outline ➢Privacy and data protection assurance ❑ Problem and context ➢Proposed method ❑ GDPR modelling ❑ Assurance cases ❑ Evidence accountability ➢Tool support for the method ❑ Eclipse OpenCert 10/03/2020 2
  3. 3. 3 10/03/2020 3 GDPR Article 5 Principles relating to processing of personal data
  4. 4. 4 Methods and Tools for Assurance A method to support the systematic capture, traceability and argumentation of evidence so as to demonstrate compliance with GDPR (and comply with the principle of accountability), and a tool to guide and partially automate that method 10/03/2020 4
  5. 5. 5 Assurance - Definition 10/03/2020 5 Assurance grounds for confidence that the other four security goals (integrity, availability, confidentiality, and accountability) have been adequately met by a specific implementation. “Adequately met” includes: 1 Functionality that performs correctly, 2 Sufficient protection against unintentional errors (by users or software), and 3 Sufficient resistance to intentional penetration or by-pass. [NIST Special Publication 800-27 Rev A]
  6. 6. 6 Problem and context ➢GDPR became mandatory in May 2018, but the legal approach is not enough, we need to come along with technical measures. ❑How is GDPR translated into operational work items and activities for the development project? ❑Do we have a method for systematic capture of evidences and their association with GDPR derived requirements and artefacts? ❑How can we track evidence evolution? ❑Do we have a method to provide a clear argumentation about compliance? 10/03/2020 6
  7. 7. 7 Context 10/03/2020 7 (Independent ) Safety Assessment Safety Assessment Certification Liaison Privacy Assessment (Independent) Privacy Assessment
  8. 8. 7 Context 10/03/2020 7 Product Engineering “Project” Quality Management Implementation Validation & Verification Design (Independent ) Safety Assessment Safety Assessment Certification Liaison Privacy Assessment (Independent) Privacy Assessment
  9. 9. 7 Context 10/03/2020 7 Product Engineering “Project” Quality Management Implementation Validation & Verification Design (Independent ) Safety Assessment Safety Assessment Certification Liaison Privacy Assessment (Independent) Privacy Assessment Standards & Regulations Information Management Interpretation Standards Specification
  10. 10. 7 Context 10/03/2020 7 Supplier Chain Component Release Module Assurance Case Development Product Engineering “Project” Quality Management Implementation Validation & Verification Design (Independent ) Safety Assessment Safety Assessment Certification Liaison Privacy Assessment (Independent) Privacy Assessment Standards & Regulations Information Management Interpretation Standards Specification
  11. 11. 7 Context 10/03/2020 7 Supplier Chain Component Release Module Assurance Case Development Product Engineering “Project” Quality Management Implementation Validation & Verification Design (Independent ) Safety Assessment Safety Assessment Certification Liaison Privacy Assessment (Independent) Privacy Assessment Assurance “Project” Assurance Case Development Evidence Management Assurance Process Management Compliance Management Standards & Regulations Information Management Interpretation Standards Specification
  12. 12. 8 ➢This is Alex. She is a system engineer who works as the technical lead in a company ➢She is NOT a lawyer and she finds GDPR hard to interpret ➢She has identified 3 privacy related standards: ❑ GDPR ❑ 27001 ❑ NIST ➢What has PDP4E to offer for her work? 8 10/03/2020
  13. 13. 9 Modelling standards ➢Modelling standards provides: ❑An unambiguous way to show the explicit process for standards compliance ❑A systematic way for the different roles to share the same view on standards compliance ❑Mappings between concepts and terminology between standards ❑Models to capture the context in which concepts apply in the standards ❑A way to see where things match, and also identify gaps ➢Main challenges behind ❑GDPR is not a technical standard developed by engineers but by lawyers ❑There is not an explicit process behind ❑Standards ecosystems ▪ Legal à GDPR ▪ Good practices à 27001 ▪ Implementation standards à NIST 10/03/2020 9
  14. 14. 10 Assurance method concepts ➢Prescriptive Knowledge Management is the assurance area concerned with the specification and handling of standards’ and normative information, as well as any other information derived from or based on them (interpretations, tailoring, mapping between standards, etc.) This is done by means of reference assurance frameworks. 10/03/2020 10
  15. 15. 11 Assurance method concepts ➢Equivalence mappings 10/03/2020 11 RefFramework Model (e.g. GDPR) Icon Element Activity Role Artefact Input (Artefact to Activity) Output (Activity to Artefact) Participation (Role to Activity) Precedence (Activity to Activity) N/A (box within box) Containment (Activity to Activity) RefFramework Model (e.g. 27001) Equivalence Map Model RefFramework Model (e.g. NIST) Equivalence Map Model Regulation Modelling Equivalences Modelling
  16. 16. 11 Assurance method concepts ➢Equivalence mappings 10/03/2020 11 RefFramework Model (e.g. GDPR) Icon Element Activity Role Artefact Input (Artefact to Activity) Output (Activity to Artefact) Participation (Role to Activity) Precedence (Activity to Activity) N/A (box within box) Containment (Activity to Activity) RefFramework Model (e.g. 27001) Equivalence Map Model RefFramework Model (e.g. NIST) Equivalence Map Model Regulation Modelling Equivalences Modelling ➢Model Instantiation for a specific project
  17. 17. 11 Assurance method concepts ➢Equivalence mappings 10/03/2020 11 RefFramework Model (e.g. GDPR) Icon Element Activity Role Artefact Input (Artefact to Activity) Output (Activity to Artefact) Participation (Role to Activity) Precedence (Activity to Activity) N/A (box within box) Containment (Activity to Activity) RefFramework Model (e.g. 27001) Equivalence Map Model RefFramework Model (e.g. NIST) Equivalence Map Model Baseline Model (e.g. Smart Grid) Baseline Model (e.g. Connected vehicle) Assurance Project (e.g. Smart Grids or Connected vehicle) Regulation Modelling Equivalences Modelling ➢Model Instantiation for a specific project
  18. 18. 11 Assurance method concepts ➢Equivalence mappings 10/03/2020 11 RefFramework Model (e.g. GDPR) Icon Element Activity Role Artefact Input (Artefact to Activity) Output (Activity to Artefact) Participation (Role to Activity) Precedence (Activity to Activity) N/A (box within box) Containment (Activity to Activity) RefFramework Model (e.g. 27001) Equivalence Map Model RefFramework Model (e.g. NIST) Equivalence Map Model Baseline Model (e.g. Smart Grid) Baseline Model (e.g. Connected vehicle) Assurance Project (e.g. Smart Grids or Connected vehicle) Tailoring (RefFramework subset) Regulation Modelling Equivalences Modelling ➢Model Instantiation for a specific project
  19. 19. 11 Assurance method concepts ➢Equivalence mappings 10/03/2020 11 RefFramework Model (e.g. GDPR) Icon Element Activity Role Artefact Input (Artefact to Activity) Output (Activity to Artefact) Participation (Role to Activity) Precedence (Activity to Activity) N/A (box within box) Containment (Activity to Activity) RefFramework Model (e.g. 27001) Equivalence Map Model RefFramework Model (e.g. NIST) Equivalence Map Model Baseline Model (e.g. Smart Grid) Baseline Model (e.g. Connected vehicle) Assurance Project (e.g. Smart Grids or Connected vehicle) Tailoring (RefFramework subset) Tailoring (RefFramework subset) Regulation Modelling Equivalences Modelling ➢Model Instantiation for a specific project
  20. 20. 12 10/03/2020 12 ➢Alex is part of a team ➢How can they provide justification for compliance? ➢How can they trace the evidences with the supporting requirements and the proposed treatments to solve privacy concerns? ➢Is there a way to reproduce and systematize good practices for compliance and the rationale behind?
  21. 21. 13 Assurance cases approach ➢Assurance cases were originally used to show that systems satisfied their safety- critical properties. In this usage, they were (and are) called safety cases. 10/03/2020 13
  22. 22. 13 Assurance cases approach ➢Assurance cases were originally used to show that systems satisfied their safety- critical properties. In this usage, they were (and are) called safety cases. An assurance case consists of documented body of evidence that provides a convincing and valid argument that a specified set of critical claims regarding a system´s properties are adequately justified for a given application in a given environment. 10/03/2020 13
  23. 23. 13 Assurance cases approach ➢Assurance cases were originally used to show that systems satisfied their safety- critical properties. In this usage, they were (and are) called safety cases. An assurance case consists of documented body of evidence that provides a convincing and valid argument that a specified set of critical claims regarding a system´s properties are adequately justified for a given application in a given environment. ➢Main problems: - It is easy to present long reports referencing evidences but with no real connection on how those evidences relates with the safety requirements à lack of clarity - Some times the reports offers argumentation without evidences that support it à unconvincing - It is hard to inform third parties the rationale behind some developments 10/03/2020 13
  24. 24. 13 Assurance cases approach ➢Assurance cases were originally used to show that systems satisfied their safety- critical properties. In this usage, they were (and are) called safety cases. An assurance case consists of documented body of evidence that provides a convincing and valid argument that a specified set of critical claims regarding a system´s properties are adequately justified for a given application in a given environment. Assurance cases put in relation evidences and objectives ➢Main problems: - It is easy to present long reports referencing evidences but with no real connection on how those evidences relates with the safety requirements à lack of clarity - Some times the reports offers argumentation without evidences that support it à unconvincing - It is hard to inform third parties the rationale behind some developments 10/03/2020 13
  25. 25. 14 Privacy argument fragment ➢Within the limits defined in [scope] the application [system description] is privacy ensured because all identified threats [system threats] and requirements [privacy requirements] have been addressed. Threats have been sufficiently controlled and mitigated [Risk reduction measures] according to the privacy risk exposure [Risk assessment]. Evidence [Privacy analysis/test] is provided that demonstrated the effectiveness and sufficiency of these measures. Appropriate roles, responsibilities and methods were defined throughout the development of this system [Development process justification] [Privacy management system] and defined future operation 10/03/2020 14
  26. 26. 14 Privacy argument fragment ➢Within the limits defined in [scope] the application [system description] is privacy ensured because all identified threats [system threats] and requirements [privacy requirements] have been addressed. Threats have been sufficiently controlled and mitigated [Risk reduction measures] according to the privacy risk exposure [Risk assessment]. Evidence [Privacy analysis/test] is provided that demonstrated the effectiveness and sufficiency of these measures. Appropriate roles, responsibilities and methods were defined throughout the development of this system [Development process justification] [Privacy management system] and defined future operation 10/03/2020 14
  27. 27. 15 Argument decomposition 10/03/2020 15 Context Goal Strategy Solution Justification J Assumption A Solved by In the context of Graphical notation GSN
  28. 28. 16 10/03/2020 16
  29. 29. 16 10/03/2020 16 Security Requirements & Objectives
  30. 30. 16 10/03/2020 16 Security Requirements & Objectives Security Evidence
  31. 31. 16 10/03/2020 16 Security Requirements & Objectives Security Evidence Security Argument
  32. 32. 17 Evidence model and compliance models ➢Information required to characterize evidence artefacts ❑Who produced it ❑Revision and configuration management ❑“Trustworthiness” ➢Links to : ❑Engineering process results, ❑Standard objectives/requirements, ❑And to argument claims 10/03/2020 17
  33. 33. 18 Evidence management Determine the evidence to provide Collect evidence item information Specify traceability between evidence items Evaluate evidence item Is the evidence adequate? Yes No Address issues 10/03/2020 18
  34. 34. 19 Assurance management concepts ➢Assurance Project Management, determines the baseline elements of an assurance project from reference assurance frameworks ➢Evidence Management whose information is mapped to baseline elements for specifying compliance with a reference assurance framework (information to collect) ➢Argumentation Management, which can refer to compliance with a reference assurance framework (compliance argument) 10/03/2020 19
  35. 35. 20 Evidence model ➢Information or objective artefacts being offered in support of one or more claims [SACM] ➢Overall, there are two types of privacy evidence ❑Compliance(process)-based evidence vs. product-based evidence ➢Traceability (and dependency) exists between pieces of evidence ➢Artefacts can be defined at several granularity levels ❑Reqs. specification document vs. single requirement Artefact Evidence Claim used as supports 10/03/2020 20
  36. 36. 21 Concepts for accountability Evidences Model Compliance Map Model Argumentation model Baseline Model (e.g. SmartGrid) Assurance Project (e.g. Smart Grids or Connected vehicle) What is plan to Do What has Been Done Compliance maps are the responsable for tracing standard derived artefacts 10/03/2020 21
  37. 37. 22 Tool support for the method 10/03/2020 22 https://www.eclipse.org/opencert/
  38. 38. 23 Assurance Project Definition Assurance Case Management Evidence Management Compliance Management Reporting Regulation Modelling Equivalences Modelling Assurance methodology 10/03/2020 23
  39. 39. 24 Tool support for the method Evidence Management Prescriptive Knowledge Management Privacy Argumentation Management Assurance Project Lifecycle Management Project Repository Measurement & Transparency Assurance Configuration Management System Management Standards & Understandings Argument Patterns Risk Control Product Engineering Tools Requirements, Models Link Connect 10/03/2020 24
  40. 40. 24 Tool support for the method Evidence Management Prescriptive Knowledge Management Privacy Argumentation Management Assurance Project Lifecycle Management Project Repository Measurement & Transparency Assurance Configuration Management System Management Standards & Understandings Argument Patterns Risk Control Product Engineering Tools Requirements, Models Link Connect 10/03/2020 24
  41. 41. 24 Tool support for the method Evidence Management Prescriptive Knowledge Management Privacy Argumentation Management Assurance Project Lifecycle Management Project Repository Measurement & Transparency Assurance Configuration Management System Management Standards & Understandings Argument Patterns Risk Control Product Engineering Tools Requirements, Models Link Connect 10/03/2020 24
  42. 42. 24 Tool support for the method Evidence Management Prescriptive Knowledge Management Privacy Argumentation Management Assurance Project Lifecycle Management Project Repository Measurement & Transparency Assurance Configuration Management System Management Standards & Understandings Argument Patterns Risk Control Product Engineering Tools Requirements, Models Link Connect 10/03/2020 24
  43. 43. 24 Tool support for the method Evidence Management Prescriptive Knowledge Management Privacy Argumentation Management Assurance Project Lifecycle Management Project Repository Measurement & Transparency Assurance Configuration Management System Management Standards & Understandings Argument Patterns Risk Control Product Engineering Tools Requirements, Models Link Connect 10/03/2020 24
  44. 44. 24 Tool support for the method Evidence Management Prescriptive Knowledge Management Privacy Argumentation Management Assurance Project Lifecycle Management Project Repository Measurement & Transparency Assurance Configuration Management System Management Standards & Understandings Argument Patterns Risk Control Product Engineering Tools Requirements, Models Link Connect 10/03/2020 24
  45. 45. 25 10/03/2020 25
  46. 46. 26 10/03/2020 26
  47. 47. 27 10/03/2020 27
  48. 48. 28 10/03/2020 28
  49. 49. 29 10/03/2020 29
  50. 50. 30 10/03/2020 30
  51. 51. 
 Methods and Tools for GDPR Compliance through Privacy and Data Protection 4 Engineering 
 Reference frameworks Explicit evidences Explicit and clear argumentation Explicit traceability to reference frameworks Jabier Martinez (Tecnalia) jabier.martinez@tecnalia.com

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