What is Privacy by Design?
A proactive approach to embed data privacy into product and service development to minimize risks and ensure compliance with GDPR.
Key Considerations and Practices
1. Minimize Data Collection
- Consider: Are we collecting only what’s necessary?
- In Practice:
- Develop products requiring minimal data to complete processing tasks.
- Document the specific data fields required for each product.
- Train implementation teams on required vs. optional data fields.
2. Avoid Collecting Unnecessary Data
- Consider: Are there any redundant data fields?
- In Practice:
- Regularly review data collection practices.
- Ensure all unnecessary data fields are removed during development.
- Maintain transparency with documentation on required data points.
3. Anonymize, Pseudonymize, and Encrypt Data
- Consider: Are we safeguarding data through techniques like anonymization?
- In Practice:
- Anonymization: Ensure data cannot be traced back to an individual. Preferred where possible.
- Pseudonymization: Replace personal identifiers with unique codes, reducing privacy risks.
- Encryption: When anonymization isn’t possible, encrypt data to provide additional protection.
4. Manage Data Transfers
- Consider: Are data transfers compliant with GDPR?
- In Practice:
- Notify the Data Protection Committee of new data center locations or transfer destinations.
- Evaluate transfer methods to ensure they meet GDPR standards.
5. Vendor and Product Review
- Consider: Are vendors and new functionalities properly assessed?
- In Practice:
- Complete a vendor questionnaire and submit it to the legal team for approval.
- Provide a data map and a record of processing for any new product or functionality.
Documentation & Risk Management
- Privacy Impact Assessments (PIAs): Required for high-risk activities to evaluate and mitigate data privacy risks.
- Product Development Notes: Highlight privacy considerations and demonstrate compliance in development.
Remember
Adopting Privacy by Design isn’t just about meeting GDPR requirements—it’s about building trust and ensuring robust data protection practices throughout your organization. Consult your privacy team for guidance on high-risk activities.?