For all those who wish to use EBIOS Risk Manager to conduct a PIA (Privacy Impact Assessment, commonly, or Data Protection Impact Assessment – DPIA, in the specific context of the Article 35 of GDPR), here is an infographic which summarizes the approach:
Broadly speaking, information security / cybersecurity and privacy are both about data protection.
The goal is different: in the information security field, the goal is to protect the organization, while in privacy, the goal is to protect individuals / data subjects.
But the way to manage risk is perfectly compatible!
To conduct a PIA with EBIOS Risk Manager, all you have to do is:
All the information required in a PIA is all found in the study:
Agile Risk Manager is designed to support you in the implementation of risk analysis using the EBIOS Risk Manager method. Take advantage of the strength of an adapted tool to focus on the fundamental values highlighted by the method: knowledge, agility and commitment.
Agile Risk Manager brings you the efficiency and ergonomic facilities of an on-premise solution, while allowing a complete and intuitive collaborative work. From change history to role and access management on your shared analyses, everything is done to enable you to work as a team.
Go even further with the strength of a dedicated software that guides you without restricting you. Agile Risk Manager adapts its presentation to your needs, making recommendations while leaving you in control of your choices.
Customize your experience:
Thanks to an Excel data import and a simple open template, you can directly retrieve your existing analyses in Agile Risk Manager. Preserve your data capital and improve it in our tool, or simply start new analyses.
Agile Risk Manager also allows you to exchange data with customers or colleagues by exporting every table to Excel and every graph and matrix as an image. A global report can also be generated at any point in your analysis. The content of this report is customizable and you can export it in different formats, such as HTML, Word and PDF.
Taking our software in hands is simple and easy. Get started directly with our integrated examples and take advantage of a dedicated support with our online demonstrations and a free evaluation.
For more information or to request your evaluation version, contact us at contact [at] all4tec.net or visit https://www.all4tec.com/.
ALL4TEC designs and distributes risk analysis tools for cybersecurity and operational safety, in order to answer to the twofold “Safe & Secure” issue which is more and more present among large industrials, operators and IT contractors.
The open source PIA software helps to carry out data protection impact assesment.
The PIA software aims to help data controllers build and demonstrate compliance to the GDPR. The tools is available in French and in English (and many other languages). It facilitates carrying out a data protection impact assessment. This tool also intends to ease the use of the PIA guides published by the CNIL.
The following document can be used for determining the baseline of the Workshop 1 of EBIOS Risk Manager, when the scope of the study is a processing of personal data:
It constitutes a declaration of applicability relating to the fundamental principles related to the protection of privacy.
The other Workshops of the study makes it possible to satisfy the obligations of the GDPR in terms of security (cf. art. 32) if you assess the impacts on the data subjects in addition to those on the organization.
You can thus use EBIOS Risk Manager to carry out a PIA (cf. art. 35).
This international standard defines the vocabulary and principles that must be respected by any specific approach to privacy.
This international standard defines the vocabulary that must be respected by any approach specific to information security.
This international standard defines the principles that must be respected by any risk management approach specific to privacy.
This international standard defines the vocabulary and the principles which must be respected by any risk management approach specific to information security.
This international standard defines the vocabulary and the principles which must be respected by any risk management approach, whatever its field of application.
Answer from a Club EBIOS member: “Pay attention to scales using several types of impacts”
EBIOS guide reminder: “This action [scale development] consists of creating a scale describing all possible levels of impacts, just like the scales of needs, a scale of impact levels is usually ordinal (the objects are classified in order of magnitude, the numbers indicate ranks and not quantities) and composed of several levels to classify all risks“.Therefore, it is usual to see users of the method build several ordinal scales depending on the nature of the impact (financial, legal, operations, privacy…) to estimate the severity of the feared events. The construction is then done by individually scaling each type of impact, without worrying about the consistency between the levels.
However, only a global result is used in risk maps to assess the severity of each compared to the others. Information on the nature of the impacts is lost.
To avoid misleading conclusions about the importance of risks, care must be taken to check the transverse coherence of the gradation of impacts in the scales. For example, checking that the estimatation of a level 3 impact on operations will be of the same value for the organization as the financial and legal impacts of the same level.
Where possible, the pivotal criterion (for consistency) may be the financial scale. If this is not the case (often the case), the side-by-side impacts should be presented and their importance assessed by those seeking consensus. In this case, the scales can have empty boxes (level having no equivalence for all types of impacts considered). This can be the case when one estimates the loss of human lives for example.
It is sometimes difficult for managers to establish these scales in a generic way. A good solution is then to ask the stakeholders to prioritize the feared events after identifying the impacts, and build the scales based on this estimate.
Answer from another member: “It is useful to have heterogeneous impact scales, it is an important means of communication with the business”
In addition, the ideal is in my opinion:
This makes it easy to carry out a study of both information security and privacy by presenting side-by-side the impacts to the organization and the impacts to the individuals (data subjects).
Answer from a Club EBIOS member: “Two options”
Several proposals are possible to demonstrate that the problems associated with traceability are treated in an EBIOS study without considering traceability as a criterion:
Another answer’s response: “Traceability is not a security criterion”
The security criteria are used to assess the impacts in case of reaching each of them, and in particular to study the security needs. In information security, only availability, integrity and confidentiality are considered as security criteria (see in particular ISO/IEC 2700x).They should not be confused with the topics of security measures or regulatory references. Indeed, the (false) need for traceability comes from the fact that we want to know what happened after an incident (detection measure) and/or various obligations (legal, regulatory, sectoral or security policy-related). It is therefore useless and even counterproductive to study the need for traceability.
In addition, a scale of needs and a scale of impacts related to traceability should be available. It is often by trying to build them that one realizes that it is a “desire of someone” that falls under security measures or coverage of a legal “risk”.
Finally, this would involve studying all the threats that lead to the loss of traceability! Actually, this is related to the good implementation of a security measure, which is not necessary to treat as a risk (or otherwise it should be done for encryption, access control, etc.).
However, as the study of the needs is a communication tool with business, it is possible to integrate traceability into the security criteria so that business becomes more involved in the process by seeing its point of view taken into account…
Answer from a Club EBIOS member: “We can act on several elements so that the result corresponds to the expectations”
Studies are sometimes criticized because of the combinatorial explosion of the elements to be studied. Therefore, before or at the beginning of any study, it is necessary to wonder what the sponsor is able to accept in terms of readability.Some wish to have as much detail as necessary to treat the risks (and/or justify the measures) in a fine way.
In this case, it is possible to handle the entire combination of events and threat scenarios.
If this is not the case, here are some tips that will help you reduce the entropy of the analysis:
EBIOS, the French reference method, helps organizations to identify and understand their own digital risks. It allows determining security controls that suit to the threat and setting up the monitoring and continuous improvement framework following a risk analysis shared at the highest level.
On the ANSSI website: EBIOS Risk Manager
This guide is the EBIOS* generic approach. It provides a common base to any sector-specific breakdown. Initially designed for information security, EBIOS can be employed in all fields using the appropriate techniques and knowledge bases.
EBIOS allows us to assess and treat risks. It also supplies all the information required for communication within the organization and with its partners, and for validation of the way risks have been treated. It thus constitutes a complete risk management tool.
This is a real toolbox, from which we choose the actions to be implemented and the method of using them according to the objective of the study. It allows us to assess the risks using scenarios and to develop a coherent policy from them, based on concrete and assessable controls.
The CNIL’s PIA Guides have been updated to provide a tool for the General Data Protection Regulation (GDPR).
The methodological approach is a privacy specific instantiation of the EBIOS toolbox.
It allows to build and demonstrate compliance with the GDPR of a processing of personal data.
The guides (the methodology, the templates and the knowledge bases) are provided with a free software, case studies, guidelines, etc.
On the CNIL’s website: Privacy Impact Assessment (PIA)