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SERI Conference Proceedings SHORTLISTED PAPERS National Centre of Excellence for Cybersecurity Technology PRESENTS AT Development & Entrepreneurship OUR PARTNERS Promoting Cybersecurity Education, Research and Innovation SERI Conference Proceedings SHORTLISTED PAPERS THEME AUTHORS INSTITUTE/ ORGANIZATION Data Privacy Signify North America Considerations during HARSHA BANAVARA Corporation, Burlington, Requirements Phase of MA USA IoT Product Development ASTRA: A Post AKSHAY JAIN Exploitation Red Teaming DR. BHUVNA J Jain University, Bengaluru tool SUBARNA PANDA zSpaze Technologies, New Space and New RAMESH KUMAR V Bengaluru Threats PRASANNA PHANINDRAN Easwari Engineering College, Chennai Cross-Channel Scripting Attacks (XCS) in Web SHASHIDHAR R Bennett University Applications Quantum Cryptography SANCHALI KSHIRSAGAR UMIT SNDT Women's and Use Cases: A Short DR. SANJYA PAWAR University, Mumbai Survey Paper SHRAVANI SHAHAPURE NCoE-DSCI, New Delhi Securing IoT using Tata Advanced System SHALINI DHULL Permissioned Blockchain Limited, Noida Parul University, Vadodara An Analysis of Internet of YASSIR FAROOQUI Sankalchand Patel University, Things(IoT) Architecture DR. KIRIT MODI Visnagar Zonal advisory at Consumer Cyber Security-Modern Era DR. SUMANTA BHATTACHARYA Challenge to Human Race Rights Organization BHAVNEET KAUR SACHDEV and it’s impact on COVID-19 Indian Institute of Human Data Privacy Considerations during Requirements Phase of IoT Product Development HARSHA BANAVARA Data Privacy Considerations during Requirements Phase of IoT Product Development Harsha Banavara Signify North America Corporation Burlington, MA USA Abstract—This paper addresses the continuing issues of comprehensive consideration and integration of data privacy into II. DATA CLASSIFICATION product and solution development to enable compliance to applicable standards, rules and regulations. The data privacy A. Personally Identifiable Information landscape is in continuous flux with more countries and regional The definition of personal data or Personally Identifiable entities placing increased importance and rigor upon the Information (PII) varies from one country to another. The handling of specific categories of people data: personally authors in [6] define PII as “any information about an identifiable information (PII) or personal data, protected health individual maintained by an agency, including (1) any information (PHI), and sensitive information (SI). A process is information that can be used to distinguish or trace an offered which promotes early consideration of what kinds of data individual ‘s identity, such as name, social security number, need to be collected, processed, and stored; determination of the implications based upon intended geographic locations of sales or date and place of birth, mother ‘s maiden name, or biometric services; and concluding with generation of comprehensive records; and (2) any other information that is linked or security requirements. linkable to an individual, such as medical, educational, financial, and employment information”. Keywords—data privacy, security requirements, standards and Some examples are: regulations, product development lifecycle • Name – e.g. full name, maiden name, alias I. INTRODUCTION • Personal identification number – e.g. social security The ever-expanding desire to collect information on number (SSN), passport number, driver’s license anything and everything has resulted in an enormous amount of number, taxpayer identification number, financial collected, manipulated, and stored data; data gleaned from account, credit card number machines, processes, and most importantly from people [1]. In this paper the authors will bring into discussion the terms of • Address information – e.g. street address, email data privacy and security; how they interrelate and are address connected is at the core of the presented concepts. Privacy • Personal characteristics – e.g. photographic image within the context of data privacy “refers to keeping (especially of face or other identifying characteristic), information confidential;” that is, allowing it to be viewed by fingerprints, handwriting, other biometric data (e.g., only authenticated and authorized individuals and processes. retina scan, voice signature, facial geometry). Typically, information within Data Privacy involves PII, PHI, and SI [2]. To ensure the confidentiality of these data types B. Protected Health Information requires application of security practices and policies, e.g. authentication, authorization, encryption at rest and in motion Protected Health Information (PHI) is a subset of PII. The [3]. definition of PHI is defined in the Privacy Rule published by United States Department of Health and Human Service to This paper will discuss issues and consequences associated implement the requirement of Health Insurance Portability and with data collection, processing, and retention - steps that need Accountability Act (HIPAA) of 1996. PHI includes, but is not to be considered during the early stages of product and solution limited to, all information relative to the patient-practitioner development to minimize organizational exposure relative to relationship [7]: data collection and use legislation and regulation [4]. • The individual’s physical or mental health or A process is offered to address data decisions early-on in condition (past, present or future) development activities to allow lowest costs and highest integration in solutions [5]. The authors’ experience in concert • Services provided and diagnoses defined with referenced contemporary sources provide an unbiased and • Associated payment information (past, present or objective approach to this growing issue. future) • Standard PII (name, address, government issued identification number, etc... In jurisdictions other than the United States, PHI may not of fines collected for data privacy infringements has increased be a separate category but is rather included within the ambit of over 100% YoY 2014 vs 2015 [11]. PII. IV. A PROCESS C. Sensitive Information Introducing security-oriented features earlier in the product Sensitive Information (SI) is also a subset of PII. The development cycle incurs less costs and improves integration definition of SI may vary by jurisdiction, however, some versus later consideration [5]. In order to address this critical categories included are racial, ethnicity, political alliance, issue early on in the development lifecycle, it is important that religion, philosophical beliefs, organizational memberships, we adopt a robust time-tested process. One such process is health conditions, sexual orientation / preferences, geo-location Microsoft’s Security Development Lifecycle (SDL) developed [3]. in 2002 [12]. The process matured quickly and was opened to public use in 2004. III. CHALLENGES According to Microsoft “SDL is a software development Developers of products and solutions involving data process that helps developers build more secure software and collection, processing and storage are faced with many address security compliance requirements while reducing challenges. Among these are a constantly changing regulatory development cost.”. Requirements within SDL is the second environment, cross-border data flow, data localization, and phase of seven, right after training. Building resilient products penalties for non-compliance: is like designing a house - both require a strong foundation; good security requirements help in reducing the ambiguity for A. Regulatory Environments developers [13]. In 1973, Sweden passed the first national data protection The process of coming up with good security requirements law in the world. Since then we have come a long way; as of can be divided into 3 stages: January 2020, approximately 132 countries (out of 194) have enacted data privacy laws with many under development by 1. Collection and harmonization stage their governments. This means that countries without data 2. Filtering stage privacy laws are now in the minority [8]. Some regulations can have a huge impact not only on a region but also globally; 3. Prioritization stage e.g. the European Union General Data Protection Regulation In the first stage, understanding the product along with the (EU GDPR). This legislation superseded the existing EU Data market segments, regions and sectors into which it will be Protection Directive (DPD) of 1995, and was a dramatic offered, is essential in determining the coverage of the paradigm shift [9]. In another 3 years we will be celebrating standards. Sometimes, the target market can be a single country the 50th anniversary of the first national data protection law; (e.g. China, Russia) and organizations can come up with a by then we can expect more laws to be passed by countries, China for China or Russia for Russia strategy wherein they making data privacy compliance even more challenging. leverage the resources within those countries thereby eliminating complex supply chain issues. A plethora of B. Cross-border Data Flow standards, regulations exist and there needs to be a mechanism When considering transfer of personal data across geo- to filter out the ones that are required and the ones that are nice political borders caution should be taken due to the following to have. concerns [3]: In the second stage, the Pareto principle can be used to • Some countries do not have data privacy laws narrow down the number of documents that need to be considered. For example, if a product is to be sold in 10 • Some countries have a very restrictive set of data countries
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