PMRM Revision
Discussion Slides
• Illustrations/Figures 1-3
o Model, Methodology, “Scope” options
• Functions, Mechanisms and “Solutions”
• Accountability and Enforcement
• Proposed “Enforcement” Definition
• Use Case – revision? Relocation to Appendix?
• Glossary
Proposed New Figure 1 Language:
“Landscape View of the PMRM Scope”
Original Figure 2: PMRM Methodology Graphic
Discussion Proposal: New PMRM
PMA Methodology
2. Initial Use Case Description and Scope
Use Case Description
and Inventory
Privacy Policy
Conformance Criteria
Initial PIA or Other
Assessments
3/3.1 - Detailed Privacy Use Case Analysis
Participants
Systems and
Business
Processes
Domains
and
Owners
Roles and
Responsibilities in
Domains
Touch
Points
Data
Flows
3.2 - PI in Use Case Domains and Systems
Incoming PI
Outgoing PI
Internally Generated PI
3.3 - Required Privacy Controls Associated with PI
Inherited
Internal
Exported
4/4.1 - Services and Functions Needed to Implement
Privacy Controls
Agreement
Usage
Validation
Certification
Enforcement
Security
Interaction
Access
5. - Mechanisms Supporting the Selected Services and
Functions
6. - Risk and/or Compliance Assessment
7. – Initiate Iterative Process
PMRM Services
Possible Inclusion of “Accountability” in
Enforcement Service
Proposed revised Service Definitions
SERVICE
FUNCTIONALITY
AGREEMENT
Define and document permissions and rules for the handling of PI based on applicable policies,
individual preferences, and other relevant factors; provide relevant Actors with a mechanism to
negotiate or establish new permissions and rules; express the agreements for use by other Services
USAGE
Ensure that the use of PI complies with the terms of any applicable permission, policy, law or regulation,
including PI subjected to information minimization, linking, integration, inference, transfer, derivation,
aggregation, and anonymization over the lifecycle of the use case
INFORMAL
DEFINITION
Manage and
negotiate permissions
and rules
Control PI use
VALIDATION
Evaluate and ensure the information quality of PI in terms of Accuracy, Completeness, Relevance,
Timeliness and other relevant qualitative factors
Check PI
CERTIFICATION
Validate the credentials of any Actor, Domain, System or Subsystem, or system component involved in
processing PI; verify compliance and trustworthiness of that Actor, Domain, System or Subsystem, or
system component against defined policies
Check credentials
ENFORCEMENT
Initiate monitoring capabilities to ensure the effective operation of all Services. Initiate response
actions, policy execution, and recourse when audit controls and monitoring indicate operational faults
and failures. Record and report evidence of compliance and accountability to Stakeholders and/or
regulators.
Monitor and respond
to audited exception
conditions and
demonstrate
accountability on
request
SECURITY
Provide the procedural and technical mechanisms necessary to ensure the confidentiality, integrity, and
availability of personal information; make possible the trustworthy processing, communication, storage
and disposition of privacy operations
Safeguard privacy
information and
operations
INTERACTION
Provide generalized interfaces necessary for presentation, communication, and interaction of PI and
relevant information associated with PI; encompasses functionality such as user interfaces, system-tosystem information exchanges, and agents
information
presentation and
communication
ACCESS
Enable data-subject Actors, as required and/or allowed by permission, policy, or regulation, to review
their PI that is held within a Domain and propose changes and/or corrections to their PI
View and propose
8 PI
changes to stored
[Accountability?]