What is ISO/IEC 27018:2019-Security techniques-Code of practice for protection of personally identifiable information (PII) in public clouds acting as PII processors?
ISO/IEC 27018:2019-Security techniques is an international standard that specifies guidelines and best practices for protecting personally identifiable information (PII) in public cloud computing environments where cloud service providers (CSPs) act as PII processors. PII refers to any information that can be used to identify an individual, such as names, email addresses, social security numbers, and more.
Here are some key points and objectives of ISO/IEC 27018:2019:
- Scope: This standard focuses on cloud service providers (CSPs) and their role in processing PII. It is designed to complement other ISO/IEC 27001 standards for information security management systems (ISMS) and provides specific guidance for PII protection in cloud environments.
- Transparency and Accountability: ISO/IEC 27018 emphasizes transparency and accountability on the part of CSPs. It requires CSPs to disclose their data processing practices to customers and to be accountable for the protection of PII.
- Consent and Control: The standard outlines the importance of obtaining clear and informed consent from individuals whose PII is being processed in the cloud. It also highlights the need for customers (data controllers) to maintain control over the PII they entrust to CSPs.
- Data Minimization: ISO/IEC 27018 encourages CSPs to only process PII that is necessary for the intended purpose. Unnecessary or excessive data collection is discouraged.
- Security Measures: The standard provides guidance on security measures that CSPs should implement to protect PII. This includes encryption, access controls, incident response plans, and more.
- Auditing and Compliance: ISO/IEC 27018 recommends regular auditing and compliance checks to ensure that CSPs are adhering to the standard’s requirements and protecting PII effectively.
- Cross-Border Data Flows: It addresses the challenges of cross-border data transfers and recommends measures to protect PII when it is moved across international boundaries.
- Data Breach Notification: The standard specifies requirements for reporting data breaches and incidents involving PII to both regulatory authorities and affected data subjects.
In summary, ISO/IEC 27018:2019 is valuable for organizations that use public cloud services to process PII, as it provides a framework for assessing and managing the risks associated with cloud-based PII processing. It helps organizations build trust with their customers and demonstrates their commitment to protecting sensitive information in the cloud.
Audit checklist for ISO/IEC 27018:2019-Security techniques
The audit checklist for ISO/IEC 27018:2019, which focuses on “Code of practice for protection of personally identifiable information (PII) in public clouds acting as PII processors,” should be comprehensive and tailored to meet the specific needs of your organization. As a certification body like Pacific Certifications, your audit checklists would ideally encompass a wide range of factors that evaluate an organization’s adherence to this ISO standard.
General Checklist Items
Management Commitment and Policy
- Evidence of Management Commitment: Are there records, meeting minutes, or documented information showing management’s commitment to the PII protection?
- PII Policy: Does the organization have a formally documented policy for PII protection?
- Risk Assessment Methodology: Does the organization have a documented and consistently applied risk assessment methodology?
- Risk Treatment Plans: Are there documents detailing how identified risks are managed?
Organizational Structure and Roles
- Role Identification: Is there a clearly identified person or team responsible for PII protection?
- Training and Awareness: Is there an established program for training employees about their roles in PII protection?
- Data Encryption: Is encryption technology used for PII both at rest and in transit?
- Access Control: Are there measures to ensure that only authorized individuals have access to PII?
- Supplier Assessment: Are there procedures for evaluating the security practices of suppliers and partners?
- Contracts: Do contracts with suppliers include terms that ensure the PII is protected in accordance with ISO/IEC 27018:2019?
- Incident Response Plan: Is there a documented incident response plan?
- Incident Reporting: Is there a mechanism for internal and external incident reporting?
Audits and Reviews
- Internal Audits: Are internal audits conducted to ensure compliance with ISO/IEC 27018:2019?
- Management Review: Is there evidence of periodic management reviews of the PII protection measures?
Legal and Regulatory
- Legal Requirements: Is there an updated list of legal and regulatory requirements regarding PII protection?
- Compliance Checks: Are there regular checks to ensure compliance with these legal and regulatory requirements?
- Documented Policies and Procedures: Every checklist item should be supported by documented policies as well as procedures.
- Technical Logs: Where technology is used to protect PII, logs and configurations should be checked to confirm that they are consistent with policy.
- Interviews: The opinions and awareness levels of staff can be a good indicator of the organization’s commitment and effectiveness in protecting PII.
Overall, these checklists serve as an important tool for auditing, they are most effective when combined with other methods such as interviews, observations, and document reviews. These additional steps can provide a more holistic view of how well an organization is adhering to the ISO/IEC 27018:2019 standard.
The audit checklist will not only serve as a tool for internal assessments but will also prove invaluable during certification audits performed by accredited bodies such as Pacific Certifications.
What are the requirements for ISO/IEC 27018:2019?
ISO/IEC 27018:2019-Security techniques outlines a set of requirements and guidelines for cloud service providers (CSPs) that act as processors of personally identifiable information (PII) in public cloud environments. These requirements are designed to enhance the protection of PII and build trust between CSPs and their customers (data controllers).
Below are some of the key requirements specified in ISO/IEC 27018:2019:
- Consent and Purpose: CSPs must obtain clear and informed consent from data controllers (the organizations or individuals who own the PII) regarding the processing of PII. The purpose of data processing should be specified, and any changes to that purpose should require renewed consent.
- Transparency: CSPs are required to be transparent about their data processing activities. They must provide data controllers with information about where and how their PII is stored, processed, and transferred.
- Data Minimization: CSPs should only process PII that is necessary for the agreed-upon purpose. They are discouraged from collecting excessive or irrelevant PII.
- Security Controls: ISO/IEC 27018 mandates the implementation of security controls to protect PII. This includes encryption, access controls, authentication mechanisms, and measures to prevent data breaches.
- Auditing and Monitoring: CSPs must establish auditing and also monitoring mechanisms to track access to PII and detect any unauthorized activities or breaches.
- Data Portability: Data controllers should have the ability to retrieve their PII from the CSP in a usable format, and the CSP should facilitate this process.
- Subcontractors and Third Parties: CSPs must ensure that any subcontractors or third parties they engage with for PII processing adhere to the same privacy and security standards as outlined in ISO/IEC 27018.
- Data Breach Notification: CSPs must have a data breach notification process in place, and they should promptly notify data controllers, regulatory authorities, and data subjects in the event of a data breach.
- Cross-Border Data Flows: When PII is transferred across international borders, CSPs should comply with relevant data protection regulations and ensure that appropriate safeguards are in place.
- Compliance and Certification: ISO/IEC 27018 encourages CSPs to undergo third-party audits and certification processes to demonstrate compliance with the standard.
- Documentation: CSPs should maintain documentation that demonstrates their compliance with ISO/IEC 27018 requirements. This includes policies, procedures, and records of security measures.
- Contractual Agreements: CSPs and data controllers should have contractual agreements in place that clearly define their respective responsibilities for PII protection.
Overall, ISO/IEC 27018 provides a comprehensive framework for addressing the privacy and security considerations associated with PII processing in public cloud environments. Compliance with these requirements can help organizations demonstrate their commitment to protecting the privacy of individuals and complying with relevant data protection regulations.
What are the benefits of ISO/IEC 27018:2019-Security techniques?
The ISO/IEC 27018:2019 standard offers several benefits to organizations, cloud service providers (CSPs), and individuals when it comes to the protection of personally identifiable information (PII) in public cloud environments acting as PII processors.
Here are some of the key benefits:
- Enhanced Data Privacy: ISO/IEC 27018 provides a clear framework for CSPs to protect PII. This leads to enhanced data privacy for individuals, as their personal information is less likely to be mishandled or compromised when stored or processed in the cloud.
- Increased Trust: Compliance with ISO/IEC 27018 demonstrates a CSP’s commitment to privacy and security. This can help build trust with customers, partners, as well as data controllers who rely on the cloud service for PII processing.
- Legal and Regulatory Compliance: Many countries and regions have data protection laws and regulations, such as the General Data Protection Regulation (GDPR) in Europe. ISO/IEC 27018 aligns with these regulations, making it easier for CSPs to demonstrate compliance and avoid legal issues related to PII processing.
- Risk Mitigation: Implementing the security controls and best practices outlined in ISO/IEC 27018 reduces the risk of data breaches and incidents involving PII. This can prevent reputational damage and financial losses associated with data breaches.
- Improved Security Practices: CSPs are encouraged to adopt robust security measures, including encryption, access controls, and incident response plans. These practices not only protect PII but also enhance overall cybersecurity.
- Transparency: The standard emphasizes transparency in data processing activities. CSPs must provide clear information to data controllers about how PII is handled, which fosters transparency and accountability.
- Data Portability: ISO/IEC 27018 requires CSPs to support data portability, allowing data controllers to retrieve their PII in a usable format. This empowers organizations to switch CSPs or cloud services without significant data migration challenges.
- Efficient Cross-Border Data Flows: For organizations with international operations, ISO/IEC 27018 provides guidance on cross-border data transfers, helping them navigate the complexities of global data protection regulations.
- Reduced Vendor Risk: Organizations that use ISO/IEC 27018-compliant CSPs can reduce vendor risk, as they can be more confident in the CSP’s commitment to data protection and privacy.
- Customer Attraction: ISO/IEC 27018 certification can be a competitive advantage for CSPs, attracting customers who prioritize strong data protection and privacy practices.
- Clear Accountability: The standard clarifies the roles and responsibilities of both CSPs and data controllers in PII processing, reducing ambiguity and potential disputes.
- Continuous Improvement: ISO/IEC 27018 promotes ongoing monitoring, auditing, and improvement of PII protection practices, ensuring that security measures remain effective over time.
- Reduced Legal Costs: By aligning with ISO/IEC 27018, CSPs may reduce the likelihood of legal challenges related to data privacy, potentially saving on legal costs.
In summary, ISO/IEC 27018:2019 provides a comprehensive set of guidelines and requirements that help organizations and CSPs protect PII in public cloud environments while simultaneously fostering trust, compliance, and enhanced data privacy for individuals. It contributes to a more secure and responsible approach to cloud-based PII processing.
Who needs ISO/IEC 27018:2019-Security techniques?
ISO/IEC 27018:2019 is primarily designed for cloud service providers (CSPs) that act as processors of personally identifiable information (PII) in public cloud environments.
However, it is relevant to several stakeholders who have an interest in protecting PII in the cloud:
- Cloud Service Providers (CSPs): CSPs are the primary audience for ISO/IEC 27018. They need to implement the requirements and best practices outlined in the standard to ensure the protection of PII when providing cloud services to customers.
- Data Controllers: Organizations that entrust their PII to CSPs for processing are known as data controllers. Data controllers have a vested interest in ensuring that the CSPs they choose comply with ISO/IEC 27018 to protect the PII they share with the cloud provider.
- Regulatory Authorities: Regulatory bodies responsible for data protection and privacy regulations may also reference ISO/IEC 27018 as a benchmark for cloud-based PII processing practices. Compliance with ISO/IEC 27018 can help CSPs demonstrate adherence to relevant laws and regulations.
- Data Subjects: Individuals whose PII is being processed in the cloud benefit indirectly from ISO/IEC 27018 also, compliance with the standard enhances the protection of their personal information, reducing the risk of data breaches and misuse.
- Auditors and Certification Bodies: Professionals responsible for auditing and certifying CSPs for ISO/IEC 27018 compliance use the standard as a reference to assess whether CSPs meet the required privacy and security standards.
- Legal and Compliance Departments: Organizations’ legal and compliance teams play a crucial role in ensuring that CSP contracts and agreements align with ISO/IEC 27018 and relevant data protection laws.
- IT and Security Professionals: IT and security personnel within CSPs are responsible for implementing the technical and operational controls specified in ISO/IEC 27018 to protect PII.
- Cloud Customers: Organizations that use cloud services for PII processing should have an understanding of ISO/IEC 27018 and consider it when selecting a CSP. They can use the standard as part of their due diligence process.
- Third-Party Assessors: Organizations may engage third-party assessors or consultants to evaluate the compliance of their CSPs with ISO/IEC 27018.
Overall, ISO/IEC 27018 serves as a valuable resource for anyone involved in or concerned about the processing of PII in public cloud environments. It helps establish a framework for responsible and secure PII processing practices, facilitating trust and compliance with data protection laws and regulations.
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