A data privacy approach for cyber-physical systems

Abstract

The European General Data Protection Regulation (GDPR), which has been in effect since 25th May, 2018, tightens the requirements regarding data protection for anyone collecting or processing personal data within the European Union (EU) and is connected with heavy fines in case of violations. The topic of data privacy for cyber-physical systems and the related requirements towards development and operation are, however, not new. Many regional laws and regulations pursuing the goals of confidentiality, integrity, availability, storage and purpose limitation, minimisation, transparency and accuracy of personal data have already been in place long before the introduction of the GDPR. But for many companies, dealing with the formal requirements defined by the GDPR is a new and challenging task. We developed a clearly structured approach based on established and proven workflows aimed at integrating data protection topics into existing development processes and thereby achieving compliance with data protection regulations. This approach follows the widely used V-model for development and is inspired by concepts from functional safety development. Both the discipline of functional safety and that of data privacy aim to protect the end-user against harm caused by malfunctions of the system they are using. In the first case this refers to physical harm, while in the second to harm due to violations of fundamental rights and freedoms of natural persons. In the age of digitalisation there are currently indications for a paradigm shift that puts both kinds of harm on the same level. The approach starts by defining the scope of collection and processing of private data as well as the relevant functions and interfaces. Based on this, the threats related to the loss or breach of personal data are analysed and corresponding goals are formulated. A high-level strategy for reaching those goals and preventing data privacy infringements is then derived. This strategy is further refined into concrete technical and process solutions for which verification and validation criteria are defined.