PMRM TC Emergency Responder Use Case Draft: 2 Aug 2011

Copyright © International Security Trust and Privacy Alliance (ISTPA)

Privacy Management Reference Model Services n Core Policy Services l Agreement- agreements, options, permissions l Control – policies – data management n Presentation and Lifecycle Services l Interaction - manages data/preferences/notice l Agent - software that carries out processes l Usage - data use, aggregation, anonymization l Access - individual review/updates to PI n Privacy Assurance Services l Certification - credentials, trusted processes l Audit - independent, verifiable accountability l Validation - checks accuracy of PI l Enforcement - including redress for violations Copyright © International Security Trust and Privacy Alliance (ISTPA)

Syntax for each Service: Functions n DEFINE [SVC] operational requirements n SELECT [SVC] (input, process, and output) data and parameters n INPUT [SVC] data and parameter values in accordance with Select n PROCESS [SVC] data and parameter values within Functions n OUTPUT [SVC] data, parameter values, and actions n LINK [SVC] to other (named) Services n SECURE [SVC] with the appropriate security function s Each USE CASE invokes a sequence of Service “calls” Each Service call executes a sequence of Functions (drawn from these seven Function categories) Copyright © International Security Trust and Privacy Alliance (ISTPA)

Emergency Responder Use Case: On Site Care

ACTOR: ECS PI-In [detailed PI required] Source (Actor) Requirements Services Incident ReportExternal sources  ECS Privacy and Security Policy  jurisdictional regulations  OnStar  Security  Control  Audit  Interaction  Validation  Usage  Certification Situational Awareness Report External Sources  ECS Privacy and Security Policy  jurisdictional regulations  OnStar  Security  Control  Audit  Interaction  Validation  Usage  Certification Patient EHR Information Service Provider and other Healthcare systems  HIPAA security and privacy rules  HITECH  3 rd party inherited policy agreements  Security  Control  Audit  Interaction  Validation  Certification  Usage Situation Assessment On-site Care/Incident Commander  General scene information  None Data Flows TO a Single Actor (ECS) with PMRM Service Invocations

ECSIncident ReportExternal sources  ECS Privacy and Security Policy  jurisdictional regulations  OnStar  Security  Control  Audit  Interaction  Validation  Usage  Certification Consider one ‘row’ in the table:

External Source connects to the ECSSECURITY: establish confidential communication (encryption) CERTIFICATION: check External Source credentials INTERACTION: Provide privacy notice to the External Source, if appropriate Incident Report is transmitted to the ECSVALIDATION: check the PI for reasonableness, veracity, and relevance, possibly against other sources CONTROL and USAGE: Store the PI, together with all appropriate permissions for subsequent PI use AUDIT: record the receipt of the PI and Incident Report Tabular, time-line flow of Service invocations: Services Operational Requirements Time Line

ECS Situational Awareness Report External Sources  ECS Privacy and Security Policy  jurisdictional regulations  OnStar  Security  Control  Audit  Interaction  Validation  Usage  Certification External Source connects to the ECSSECURITY: establish confidential communication (encryption) CERTIFICATION: check External Source credentials INTERACTION: Provide privacy notice to the External Source, if appropriate Situation Awareness Report is transmitted to the ECS VALIDATION: check the PI for reasonableness, veracity, and relevance, possibly against other sources CONTROL and USAGE: Store the PI, together with all appropriate permissions for subsequent PI use AUDIT: record the receipt of the PI and Situation Awareness Report Services Operational Requirements Time Line Additional Row: Question: Separate analysis needed for each policy domain (eg, OnStar)?

ECS Patient EHR Information Service Provider and other Healthcare systems  HIPAA security and privacy rules  HITECH  3 rd party inherited policy agreements  Security  Control  Audit  Interaction  Validation  Certification  Usage ECS connects to Service Provider and other Health Care Systems SECURITY: establish confidential communication (encryption) CERTIFICATION: mutually check credentials INTERACTION: Provide privacy notice to the Provider/other Systems, if appropriate Patient EHR is transmitted to the ECSVALIDATION: check the PI for reasonableness, veracity, and relevance, possibly against other sources CONTROL and USAGE: Store the PI, together with all appropriate permissions for subsequent PI use AUDIT: record the receipt of the PI and Patient EHR Services Operational Requirements Time Line Additional Row :

ECS Situation AssessmentOn-site Care/Incident Commander  General scene information  None (?) Services Operational Requirements Time Line Additional Row: On site Commander records general scene information in the Situation Assessment SECURITY: establish confidential communication or log-in (encryption) CERTIFICATION: mutually check credentials INTERACTION: Any PI contained in general scene information? VALIDATION: check the PI for reasonableness, veracity, and relevance, possibly against other sources CONTROL and USAGE: Store the PI, together with all appropriate permissions for subsequent PI use AUDIT: record the receipt of the PI and Situation Assessment

Data Flows FROM a Single Actor (ECS) with PMRM Service Invocations Actor: ECS PI-OutDestination (Actor) Requirements [ Services Incident Report: PI Instance and enhancements On-site Care/Incident Commander System  ECS Privacy and Security Policy  Jurisdictional regulations  Security  Control  Audit  Interaction  Validation  Usage Situational Awareness ReportOn-site Care/Incident Commander System ECS Privacy and Security Policy - Jurisdictional regulations  Security  Control  Audit  Interaction  Validation  Usage Patient Data RequestService Providers and other healthcare systems  HIPAA security and privacy requirements  Unique healthcare system requirements  Security  Control  Audit  Interaction  Validation  Certification  Usage  Enforcement Health Information from DevicesService Providers and other healthcare systems  HIPAA security and privacy requirements  Unique healthcare system requirements  Security  Control  Audit  Interaction  Validation  Certification  Usage  Enforcement Virtual ConsultOn-site Care/Incident Commander System Virtual ConsultOn-site Care/Incident Commander System

- examine each row of the OUT table, in turn; then, - Move to each Actor, analyzing the IN/OUT flows

Where Does the Reference Model Fit? Copyright © International Security Trust and Privacy Alliance (ISTPA) Privacy Management Reference Model