Privacy Impact Assessment

A Privacy Impact Assessment (PIA) is a process that identifies and assesses privacy risks of sensitive and personal client information an organization may request, process, share, and store. This provides organizations with transparency and accountability in how they manage personal client information, and also contributes to the public’s confidence behind the organizations brand. Organizations that conduct PIAs on regular basis as a part of their secure operation can avoid or reduce the possible negative effects on their clients’ privacy in the event of an incident or breach by implementing the required governance and security controls and playing a proactive role in protecting their clients’ personal information (PI) or Personal Health Information (PHI). By embedding privacy into the design and architecture of IT systems and business practices the privacy becomes an essential component of the core functionality of the solution. As an industry good practice and standard, strong security measures are essential to privacy prior to any PI or PHI data being collected, transmitted, and stored. This ensures that all private data are secured throughout its lifespan and then destroyed securely at the end.
In order for a PIA to be effective, organizations must first identify all legal and regulatory requirements (i.e. PHIPA, PIPEDA, GDPR, FIPPA, CASL etc.) that apply to the organizations data and operations. Each of these laws and regulations specify their own requirements on how to ensure clients’ privacy and information security.

  InfoTransec’s 10 Privacy Principles
Accountability An organization is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the organization’s compliance with the following principles.
Identifying Purpose The purposes for which personal information is collected shall be identified by the organization at or before the time the information is collected .
Consent The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where inappropriate .
Limited Collection The collection of personal information shall be limited to that which is necessary for the purposes identified by the organization. Information shall be collected by fair and lawful means .
Limits for use, disclosure and retention Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
Accuracy Personal information shall be as accurate, complete and up-to-date as is necessary for the purpose for which it is used. .
Safeguards Personal information shall be as protected by security safeguards appropriate to the sensitivity of the information. A public body must protect personal information by making reasonable security arrangements against such risks as unauthorized access, collection, use, disclosure or disposal .
Openness An organization shall make readily available to individuals specific information about its policies and practices relating to the management of personal information. .
Individual Access Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information, and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Challenge Compliancy An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the organization’s compliance.

Every organization is unique, and there is no one size fits all solution when it comes to a Privacy Impact Assessment. To accommodate for this, InfoTransec leverages a holistic approach which takes into account many factors when determining the privacy requirements and obligations of an organization. We also provide custom and cost-effective recommendation to ensure the success and governance of the organizations privacy and security initiatives. Above all, an effective privacy program requires architects and operators to protect PI and PHI by offering adequate security controls.

InfoTransec’s Approach to Privacy Impact Assessments:

  • Holistic approach to privacy assessment
  • Assesses business and cultural environments into which the program/IT solution is introduced
  • Considers the privacy expectations of individuals/users regarding their personal information
  • Clearly assesses privacy and security-enhancing functionality for IT solutions
  • Includes a comprehensive assessment of governance of, and accountability for, personal information
  • Assesses Privacy and Security in tandem throughout analysis process
  • Methodology may be applied at all stages of a program /IT solution life cycle: conceptual, physical design, and re-design

Holistic approach to privacy assessment