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Privacy Requirements Engineering

To link the existing landscape of privacy—people, process, and technology—techniques as they exist today with the innovations that are required to manage privacy requirements of an increasingly complex world, we start by reexamining privacy policy creation as a means of requirements gathering as well as a basis for rules setting. The next step is to put those requirements into a dynamic creative cycle, as presented in Figure 5-1.

Figure 5-1. Requirements within the privacy engineering development structure

Requirements engineering is the process of determining user needs or expectations for a new or modified solution. A solution in this context can be considered as broad as an enterprise-wide processing system architecture or as small as the addition of a new capability into one small and dedicated process. These features, called requirements, must be quantifiable, relevant, and detailed. In software engineering, such requirements are often called functional specifications.

For privacy engineers, requirements gathering and development can follow the same development path as for other functional specifications, with a twist. The art of privacy policy creation for the enterprise or for the government affairs professional is often stated in aspirational or behavioral terms: reasonable, proportional, no harm options and choices. Here, policy serves as a critical requirements-gathering source or end state upon which to draw certain functional requirements.

The policy must be explored and deconstructed to look for action words and decision trees that lead to the desired outcome. For example, a typical privacy policy may begin with the sentence “Company X respects your desire for privacy and so herein follows the way Company X will manage the personal information that it collects.” Out of this very first seemingly boilerplate or throwaway sentence arises certain possibilities for the makers, owners, or users of systems. Some such systems requirement possibilities are:

• Company X requires certain accountability or measurement or testing to determine that it is providing information protection.

• Company X requires processes to collect information.

• Company X requires collection or awareness mechanisms regarding the desires of its users with respect to data processing in order to judge how to balance protection or collection against this desire.

• Company X requires data management processes.

• Company X requires a granular definition regarding who within Company X and its partners, affiliates, and vendors will carry the ultimate task of managing these requirements throughout the expected lifecycle of any data collected. In other words, Company X requires a specific “who” to manage now granulized “what” assets that will flow through “how” systems.

So, with the very first sentence of a public-facing policy, taking a requirements approach begins to turn nonsystems, noncomponent, nongovernance seeming legalese into functional requirements that may be implemented in a people-, process-, and technology-driven systematic fashion. The privacy engineer is a distinct practitioner because he or she may indeed be teaching the policy teams about the impact of their craft as much as they dictate aspirational requirements to them. Pretty cool stuff.

Requirements engineering involves frequent communication with system users to:

• Determine specific feature expectations

• Resolve conflict or ambiguity in requirements, as demanded by the various users or groups of users

• Avoid feature creep

• Document all aspects of the project development process from start to finish

Energy should be directed toward ensuring that the final system or product conforms to the client's needs rather than attempting to mold user expectations to fit the requirements.

 
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