In the United States, federal and state regulations prescribe stakeholder rights and obligations that must be satisfied by the requirements for software systems. These regulations are typically wrought with ambiguities, making the process of deriving system requirements ad hoc and error prone. In highly regulated domains such as healthcare, there is a need for more comprehensive standards that can be used to assure that system requirements conform to regulations. To address this need, we expound upon a process called Semantic Parameterization previously used to derive rights and obligations from privacy goals. In this work, we apply the process to the Privacy Rule from the U.S. Health Insurance Portability and Accountability Act (HIPAA).We present our methodology for extracting and prioritizing rights and obligations from regulations and show how semantic models can be used to clarify ambiguities through focused elicitation and to balance rights with obligations. The results of our analysis can aid requirements engineers, standards organizations, compliance officers, and stakeholders in assuring systems conform to policy and satisfy requirements.
Information practices that use personal, financial and health-related information are governed by U.S. laws and regulations to prevent unauthorized use and disclosure. To ensure compliance under the law, the security and privacy requirements of relevant software systems must be properly aligned with these regulations. However, these regulations describe stakeholder rules, called rights and obligations, in complex and sometimes ambiguous legal language. These "rules" are often precursors to software requirements that must undergo considerable refinement and analysis before they are implementable. To support the software engineering effort to derive security requirements from regulations, we present a methodology to extract access rights and obligations directly from regulation texts. The methodology provides statement-level coverage for an entire regulatory document to consistently identify and infer six types of data access constraints, handle complex cross-references, resolve ambiguities, and assign required priorities between access rights and obligations to avoid unlawful information disclosures. We present results from applying this methodology to the entire regulation text of the U.S. Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule.
Software requirements, rights, permissions, obligations, and the operational functionality of policy enforcing systems are often misaligned. Our goal is to develop tools and techniques that help requirements engineers and policy makers bring policies and system requirements into better alignment. Goals from requirements engineering are useful for distilling natural language policy statements into structured descriptions of these interactions; however, they are limited in that they are not easy to compare with one another despite sharing common semantic features. In this paper, we describe a process called semantic parameterization that we use to derive semantic models from goals mined from privacy policy documents. We present example semantic models that enable comparing policy statements and present a template method for generating natural language policy statements (and ultimately requirements) from unique semantic models. The semantic models are described by a context-free grammar (CFG) that has been validated within the context of the most frequently expressed goals in over 100 Internet privacy policy documents. The CFG is supported by a policy analysis tool that supports queries and policy statement generation.
Mobile applications frequently access sensitive personal information to meet user or business requirements. Because such information is sensitive in general, regulators increasingly require mobileapp developers to publish privacy policies that describe what information is collected. Furthermore, regulators have fined companies when these policies are inconsistent with the actual data practices of mobile apps. To help mobile-app developers check their privacy policies against their apps' code for consistency, we propose a semi-automated framework that consists of a policy terminology-API method map that links policy phrases to API methods that produce sensitive information, and information flow analysis to detect misalignments. We present an implementation of our framework based on a privacy-policy-phrase ontology and a collection of mappings from API methods to policy phrases. Our empirical evaluation on 477 top Android apps discovered 341 potential privacy policy violations.
Abstract. Government regulations are increasingly affecting the security, privacy and governance of information systems in the United States, Europe and elsewhere. Consequently, companies and software developers are required to ensure that their software systems comply with relevant regulations, either through design or re-engineering. We previously proposed a methodology for extracting stakeholder requirements, called rights and obligations, from regulations. In this paper, we examine the challenges to developing tool support for this methodology using the Cerno framework for textual semantic annotation. We present the results from two empirical evaluations of a tool called "Gaius T" that is implemented using the Cerno framework and that extracts a conceptual model from regulatory texts. The evaluation, carried out on the U.S. HIPAA Privacy Rule and the Italian accessibility law, measures the quality of the produced models and the tool's effectiveness in reducing the human effort to derive requirements from regulations.
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