Jan 16

A refinement approach for the reuse of privacy risk analysis results

With the adoption of the EU General Data Protection Regulation (GDPR), conducting a data protection impact assessment will become mandatory for certain categories of personal data processing. A large body of literature has been devoted to data protection impact assessment and privacy impact assessment. However, most of these papers focus on legal and organizational aspects and do not provide many details on the technical aspects of the impact assessment, which may be challenging and time consuming in practice. The general objective of [10] was to fill this gap and to propose a methodology which can be applied to conduct a privacy risk analysis in a systematic way, to use its results in the architecture selection process (following the privacy by design approach and to re-use its generic part for different products or deployment contexts. The proposed analysis proceeds in three broad phases: (1) a generic privacy risk analysis phase which depends only on the specifications of the system and yields generic harm trees; (2) an architecture-based privacy risk analysis which takes into account the definitions of the possible architectures of the system and refines the generic harm trees into architecture-specific harm trees. (3) a context-based privacy risk analysis which takes into account the context of deployment of the system (e.g., a casino, an office cafeteria, a school) and further refines the architecture-specific harm trees into context-specific harm trees. Context-specific harm trees can be used to take decisions about the most suitable architectures.