Closing the gap between policy and ECM implementation using privacy by design: this article provides a framework for converting legal requirements for personal information into functional requirements for procuring or implementing an electronic content management (ECM) solution.

AuthorMooradian, Norman
PositionEnterprise content management

The core idea of the Privacy by Design (PbD) software engineering approach is that privacy controls should be built into information systems that capture and manage personal information. Its focus is on consumer-facing applications and platforms, such as social media and interactive websites, as well as on big data applications that process masses of personal information.

PbD concepts are especially important to enterprise content management (ECM) because ECM systems often capture personal information. This includes unstructured content, such as word processing documents and e-mail, which makes their privacy requirements much less predictable than for systems that capture structured content, such as the data fields in a financial system's database.

Because records and information management (RIM) professionals are key stakeholders in the procurement, configuration, and management of ECM solutions--typically shaping system requirements, creating and implementing policies, and overseeing daily operations--they can use PbD as an interface between the policy creation and ECM implementation processes.

Identifying Relevant PbD Principles

The PbD approach is articulated by seven principles (see Sidebar 1), the full text of which is published on the website of the Information and Privacy Commissioner of Ontario, Canada, a long-time champion of PbD. Three of these are especially relevant to RIM professionals.

Privacy Embedded into Design

The third principle of PbD, "Privacy Embedded into Design," sums up the approach by calling on developers to build privacy features into the product. It applies well to ECM solutions because their focus on capturing records requires privacy-relevant features, such as robust audit trails and fine-grained security controls. Also, ECM solutions tend to be configurable, which means that many functional components can be implemented through the selection of settings and the creation of system objects.

For RIM professionals, this means that ECM systems can be evaluated on how they address privacy concerns through their inherent features and how they can be configured to provide compliance with policies and regulations.

Positive Sum

The fourth principle, "Positive Sum," contains the idea that information privacy is a feature of a system, not a constraint on it. It sets an expectation that good engineering can avert tradeoffs, and it has backing from developers and regulators. This is important for RIM professionals because they can invoke it if there is push back from the IT or vendor side.

Full Lifecycle Protection

The fifth principle, "Full Lifecycle Protection," reflects a core competence of RIM professionals: managing records throughout their lifecycle.

Understanding the Solution Development Cycle

To use PbD as a bridge between organizational policy and the development of information solutions, RIM professionals must be familiar with the software development cycle. As described below, RIM professionals will contribute heavily during the first stages of the development cycle, but they need visibility into the entire process to be better able to specify what they need and to advocate for it with confidence. (See Diagram 1.)

RIM-Shared Responsibilities

Within the privacy context, the first steps of the cycle are developing policy based on ethical norms and legal requirements. RIM professionals, who presumably do legal research in retention and confidentiality, should certainly be at the policy creation table when information privacy is at issue.

The next step is to develop the ECM solution's privacy-related business requirements, which state at a fairly high level the capabilities the system needs to have. They should take into account what is a programmed, or built-in...

To continue reading

Request your trial

VLEX uses login cookies to provide you with a better browsing experience. If you click on 'Accept' or continue browsing this site we consider that you accept our cookie policy. ACCEPT