Privacy Risk Assessment for Data Subject-Aware Threat Modeling

Regulatory efforts such as the General Data Protection Regulation (GDPR) embody a notion of privacy risk that is centered around the fundamental rights of data subjects. This is, however, a fundamentally different notion of privacy risk than the one commonly used in threat modeling which is largely agnostic of involved data subjects. This mismatch hampers the applicability of privacy threat modeling approaches such as LINDDUN in a Data Protection by Design (DPbD) context. In this paper, we present a data subject-aware privacy risk assessment model in specific support of privacy threat modeling activities. This model allows the threat modeler to draw upon a more holistic understanding of privacy risk while assessing the relevance of specific privacy threats to the system under design. Additionally, we propose a number of improvements to privacy threat modeling, such as enriching Data Flow Diagram (DFD) system models with appropriate risk inputs (e.g., information on data types and involved data subjects). Incorporation of these risk inputs in DFDs, in combination with a risk estimation approach using Monte Carlo simulations, leads to a more comprehensive assessment of privacy risk. The proposed risk model has been integrated in threat modeling tool prototype and validated in the context of a realistic eHealth application.