PMRM Revision Discussion Slides Illustrations/Figures 1-3 o Model, Methodology, “Scope” options Functions, Mechanisms and “Solutions” Accountability and Enforcement Proposed “Enforcement” Definition Use Case – revision? Relocation to Appendix? Glossary

Proposed New Figure 1 Language: “Landscape View of the PMRM Scope”

Original Figure 2: PMRM Methodology Graphic

3.2 - PI in Use Case Domains and Systems Incoming PI Outgoing PI Internally Generated PI 3/3.1 - Detailed Privacy Use Case Analysis Participants Systems and Business Processes Domains and Owners Roles and Responsibilities in Domains Touch Points Data Flows 2. Initial Use Case Description and Scope Use Case Description and Inventory Privacy Policy Conformance Criteria Initial PIA or Other Assessments Discussion Proposal: New PMRM PMA Methodology

7. – Initiate Iterative Process 6. - Risk and/or Compliance Assessment 5. - Mechanisms Supporting the Selected Services and Functions 4/4.1 - Services and Functions Needed to Implement Privacy Controls AgreementUsageValidation CertificationEnforcement SecurityInteractionAccess Required Privacy Controls Associated with PI InheritedInternalExported

PMRM Services

Possible Inclusion of “Accountability” in Enforcement Service

8 SERVICEFUNCTIONALITY INFORMAL DEFINITION AGREEMENTDefine and document permissions and rules for the handling of PI based on applicable policies, individual preferences, and other relevant factors; provide relevant Actors with a mechanism to negotiate or establish new permissions and rules; express the agreements for use by other Services Manage and negotiate permissions and rules USAGEEnsure that the use of PI complies with the terms of any applicable permission, policy, law or regulation, including PI subjected to information minimization, linking, integration, inference, transfer, derivation, aggregation, and anonymization over the lifecycle of the use case Control PI use VALIDATIONEvaluate and ensure the information quality of PI in terms of Accuracy, Completeness, Relevance, Timeliness and other relevant qualitative factors Check PI CERTIFICATIONValidate the credentials of any Actor, Domain, System or Subsystem, or system component involved in processing PI; verify compliance and trustworthiness of that Actor, Domain, System or Subsystem, or system component against defined policies Check credentials ENFORCEMENT [Accountability?] Initiate monitoring capabilities to ensure the effective operation of all Services. Initiate response actions, policy execution, and recourse when audit controls and monitoring indicate operational faults and failures. Record and report evidence of compliance and accountability to Stakeholders and/or regulators. Monitor and respond to audited exception conditions and demonstrate accountability on request SECURITYProvide the procedural and technical mechanisms necessary to ensure the confidentiality, integrity, and availability of personal information; make possible the trustworthy processing, communication, storage and disposition of privacy operations Safeguard privacy information and operations INTERACTIONProvide generalized interfaces necessary for presentation, communication, and interaction of PI and relevant information associated with PI; encompasses functionality such as user interfaces, system-to- system information exchanges, and agents information presentation and communication ACCESSEnable data-subject Actors, as required and/or allowed by permission, policy, or regulation, to review their PI that is held within a Domain and propose changes and/or corrections to their PI View and propose changes to stored PI Proposed revised Service Definitions