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• Document privacy training (who, what, when, etc.) in the system knowledge
database
2.2.7 Knowledge of Privacy Subsystem
Please note that the system knowledge database may contain a lot of data pertaining
to stakeholder privacy and organizational business practices. Therefore, it should be
well protected from potential misuse. Only those with the need to know should be
provided access to the knowledge database.
3 System Integration/Optimization
One must bear in mind that the privacy, security, and business process subsystems
must be fully integrated (Fig. 2). This is a highly iterative process. A change in any
of the components in any of the given subsystems requires review of all other
components within the system in order to assure efficiency, security, and privacy of
the system as a whole. This need for system integration further highlights the
necessity of having an updated system knowledge database.
System design knowledge has traditionally been managed via system design
documents and configuration management (CM) systems and processes. Such
mechanisms, however, seldom document information protection objectives and
matrix subsystem design components to those objectives. Traditional configuration
management mechanisms primarily serve as inventory management aids, as well as
organizational tools in software development environments.
Conversely, the systems knowledge database is intended to be a decision support
tool. It helps analysts and developers who have different and sometimes
contradictory information protection goals to make sound subsystem design decisions
by considering the overarching information protection goals and the impact of
changes on other subsystems.
A systems design knowledge database should store security and privacy objectives;
results of the risk analysis, including asset identification and valuation, threats and
vulnerabilities, and risk management decisions; and resultant subsystem design
components implemented. Each design component should be mapped to a set of
technical capabilities, as well as the overarching information protection goal(s)
addressed by each component. This will facilitate better decision making in later
design reviews. When new components are being proposed and legacy components
are being considered for removal from the system design, the system knowledge
database can be polled and assist in providing detailed information regarding the
impact of such system design additions and deletions.
While optimizing the subsystems, the analysts and designers may note conflicts
among the subsystems. Complying with one set of regulations or demands may result
in the unintentional violation of others. Some conflicts can be addressed without
negatively impacting system efficiency, security, and/or privacy, while others may
not. As a result, trade-off decisions must be made, and one or more of the
subsystems may have to be sub-optimized. Which is more important – security,
privacy, or efficiency of the business process? There is no easy answer as to this
question. We must be able to efficiently and securely collect, process, and store data
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