Analyzing Regulatory Rules for Privacy and Security Requirements

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.