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Towards Regulatory Compliance: Extracting Rights and Obligations to Align Requirements with Regulations
- In: Proceedings of the 14th IEEE International Requirements Engineering Conference. (2006
, 2006
"... Abstract. 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 pr ..."
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Cited by 26 (3 self)
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Abstract. 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. 1.
Analyzing regulatory rules for privacy and security requirements
- IEEE Transactions on Software Engineering
, 2008
"... Abstract—Information practices that use personal, financial, and health-related information are governed by US 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 properly be alig ..."
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Cited by 20 (2 self)
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Abstract—Information practices that use personal, financial, and health-related information are governed by US 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 properly be 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 become implementable. To support the software engineering effort to derive security requirements from regulations, we present a methodology for directly extracting access rights and obligations 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 US Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule. Index Terms—Data security and privacy, laws and regulations, compliance, accountability, requirements engineering.
Mining rule semantics to understand legislative compliance
- ACM Workshop on Privacy in Electronic Society
, 2005
"... Privacy legislation in the United States is distributed throughout separate documents that empower different federal authorities to regulate industry. Federal authorities in turn develop corresponding regulations intended to ensure that organizations satisfy legislative objectives. Organizations in ..."
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Cited by 12 (7 self)
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Privacy legislation in the United States is distributed throughout separate documents that empower different federal authorities to regulate industry. Federal authorities in turn develop corresponding regulations intended to ensure that organizations satisfy legislative objectives. Organizations in regulated industries (e.g. healthcare and financial institutions) face significant challenges when developing policies and systems that are properly aligned with relevant privacy regulations. We analyze privacy regulations derived from the Health Insurance Portability and Accountability Act (HIPAA) that affect information sharing practices and consumer privacy in healthcare systems. Our analysis shows specific natural language semantics that formally characterize rights, obligations, and the meaningful relationships between them required to build value into systems. Furthermore, we evaluate semantics for rules and constraints necessary to develop machine-enforceable policies that bridge between laws, policies, practices, and system requirements. We believe the results of our analysis will benefit legislators, regulators and policy and system developers by focusing their attention on natural language policy semantics that are implementable in software systems. 1.
Semantic parameterization: A process for modeling domain descriptions
- ACM TRANSACTIONS ON SOFTWARE ENGINEERING METHODOLOGY
, 2008
"... Software engineers must systematically account for the broad scope of environmental behavior, including nonfunctional requirements, intended to coordinate the actions of stakeholders and software systems. The Inquiry Cycle Model (ICM) provides engineers with a strategy to acquire and refine these re ..."
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Cited by 6 (3 self)
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Software engineers must systematically account for the broad scope of environmental behavior, including nonfunctional requirements, intended to coordinate the actions of stakeholders and software systems. The Inquiry Cycle Model (ICM) provides engineers with a strategy to acquire and refine these requirements by having domain experts answer six questions: who, what, where, when, how, and why. Goal-based requirements engineering has led to the formalization of requirements to answer the ICM questions about when, how, and why goals are achieved, maintained, or avoided. In this article, we present a systematic process called Semantic Parameterization for expressing natural language domain descriptions of goals as specifications in description logic. The formalization of goals in description logic allows engineers to automate inquiries using who, what, and where questions, completing the formalization of the ICM questions. The contributions of this approach include new theory to conceptually compare and disambiguate goal specifications that enables querying goals and organizing goals into specialization hierarchies. The artifacts in the process include a dictionary that aligns the domain lexicon with unique concepts, distinguishing between synonyms and polysemes, and several natural language patterns that aid engineers in mapping common domain descriptions to formal specifications. Semantic Parameterization has been empirically validated in three case studies on policy and regulatory descriptions that govern information systems in the finance and health-care domains.
Enforceability vs. Accountability in Electronic Policies
"... Abstract: Laws, regulations, policies and standards are increasing the requirements complexity of software systems that ensure information resources are both available and protected. To motivate discussions as to how current policy models can address this problem, we surveyed several regulations, st ..."
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Cited by 2 (1 self)
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Abstract: Laws, regulations, policies and standards are increasing the requirements complexity of software systems that ensure information resources are both available and protected. To motivate discussions as to how current policy models can address this problem, we surveyed several regulations, standards and organizational security policies to identify how elements in these documents affect both personnel responsibilities and software system security. We present a resulting taxonomy that distinguishes between enforceable and accountable policies and we discuss the value of both in achieving compliance. 1.
PolicyMorph: Interactive Policy Transformations for a Logical Attribute-Based Access Control Framework ABSTRACT
"... Constraint systems provide techniques for automatically analyzing the conformance of low-level access control policies to high-level business rules formalized as logical constraints. However, there are likely to be priorities for solutions that are not easy to encode formally, so administrator input ..."
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Cited by 2 (2 self)
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Constraint systems provide techniques for automatically analyzing the conformance of low-level access control policies to high-level business rules formalized as logical constraints. However, there are likely to be priorities for solutions that are not easy to encode formally, so administrator input is often important. This paper introduces PolicyMorph, a constraint system that supports interactive development and maintenance of access control policies that respect both formalized and un-formalized business rules and priorities. We provide a mathematical description of the system and an architecture for implementing it. We constructed a prototype that is validated using a case study in which constraints are imposed on a building automation system that controls door locks. PolicyMorph advances the state-of-the-art in constraint systems by suggesting predictable policy model modifications that will resolve specific constraint violations and then allowing policy administrators to select the appropriate modifications using knowledge that is not formally encoded in the constraint system.
Requirements for a policy-enforceable agent architecture
, 2005
"... Abstract. Emerging legislation that governs consumer privacy presents a design challenge to multi-agent systems providing business, health-care and government services. As agents act on behalf of consumers and providers of goods and services, their compliance with laws governing information sharing ..."
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Cited by 1 (0 self)
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Abstract. Emerging legislation that governs consumer privacy presents a design challenge to multi-agent systems providing business, health-care and government services. As agents act on behalf of consumers and providers of goods and services, their compliance with laws governing information sharing and disclosure practices must be transparent and measurable to avoid prohibitive sanctions by regulators. Human-readable and machine-enforceable policies that govern agent behavior offer a promising avenue to safeguard against violations of law and achieve compliance in dynamic environments. We apply software engineering practices to this problem and present requirements for designing an agent-based policy language and agent framework and compare our approach to current practices. We elaborate our requirements using two scenarios demonstrating policy authorship and enforcement in a multi-agent environment. Our proposal is motivated by results from analyzing privacy policies and legislation related to services in e-commerce and health-care. 1
A Distributed Requirements Management Framework for Legal Compliance and Accountability
"... Increasingly, new regulations are governing organizations and their information systems. Individuals responsible for ensuring legal compliance and accountability currently lack sufficient guidance and support to manage their legal obligations within relevant information systems. While software contr ..."
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Increasingly, new regulations are governing organizations and their information systems. Individuals responsible for ensuring legal compliance and accountability currently lack sufficient guidance and support to manage their legal obligations within relevant information systems. While software controls provide assurances that business processes adhere to specific requirements, such as those derived from government regulations, there is little support to manage these requirements and their relationships to various policies and regulations. We propose a requirements management framework that enables executives, business managers, software developers and auditors to distribute legal obligations across business units and/or personnel with different roles and technical capabilities. This framework improves accountability by integrating traceability throughout the policy and requirements lifecycle. We illustrate the framework within the context of a concrete healthcare scenario in which obligations incurred from the Health Insurance Portability and Accountability Act (HIPAA) are delegated and refined into software requirements. Additionally, we show how auditing mechanisms can be integrated into the framework and how auditors can certify that specific chains of delegation and refinement decisions comply with government regulations. 1.
Acquiring Software Compliance Artifacts from Policies and Regulations
, 1996
"... Policies and government regulations impose restrictions on information practices in healthcare and finance. These restrictions govern the use and disclosure of information that spans organizations and their business practices. To comply with policies and the law, organizations must demonstrate that ..."
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Policies and government regulations impose restrictions on information practices in healthcare and finance. These restrictions govern the use and disclosure of information that spans organizations and their business practices. To comply with policies and the law, organizations must demonstrate that they have verifiable procedures in-place to implement these restrictions. To this end, we present techniques that software engineers can use to systematically acquire software artifacts from natural language policies and regulations based on our in-depth analysis of the U.S. Health Insurance Portability and Accountability Act 1 (HIPAA). The techniques apply semantic primitives to regulatory statements to express class structures using the Z notation. From these structures, software engineers distinguish between necessary and discretionary software requirements and acquire the following software artifacts: specifications for transactions including interfaces between software and business processes; data schemas and data maintenance requirements; and event-based test cases for ensuring that systems comply with policies and regulations. 1.
An Algorithm to Generate Compliance Monitors from Regulations
, 2006
"... Developing software systems in heavily regulated industries requires methods to ensure systems comply with regulations and law. An algorithm to generate finite state machines (FSM) from stakeholder rights and obligations for compliance monitoring is proposed. Rights and obligations define what peopl ..."
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Developing software systems in heavily regulated industries requires methods to ensure systems comply with regulations and law. An algorithm to generate finite state machines (FSM) from stakeholder rights and obligations for compliance monitoring is proposed. Rights and obligations define what people are permitted or required to do; these rights and obligations affect software requirements and design. The FSM allows stakeholders, software developers and compliance officers to trace events through the invocation of rights and obligations as pre- and postconditions. Compliance is monitored by instrumenting runtime systems to report these events and detect violations. Requirements and software engineers specify the rights and obligations, and our algorithm performs three supporting tasks: 1) identify ambiguities, 2) balance rights with obligations, and 3) generate finite state machines. Preliminary validation of the algorithm includes FSMs generated from U.S. healthcare regulations and tool support to parse these specifications and generate the FSMs.

