Privacy by Design and Default
Article 25 of the GDPR requires organizations to implement appropriate technical and organizational measures to ensure data protection principles are embedded into processing activities from the design stage and throughout the processing lifecycle.
Privacy by Design
Privacy by Design means that data protection is considered and integrated at every stage of development, from initial planning through to deployment and beyond. Organizations must:
- Consider data protection from the outset of designing systems, services, products and business practices
- Implement appropriate technical and organizational measures (such as pseudonymization)
- Integrate necessary safeguards into processing to meet GDPR requirements
- Protect the rights of data subjects
Privacy by Default
Privacy by Default requires that organizations ensure, by default, only personal data necessary for each specific purpose is processed. This applies to:
- The amount of data collected
- The extent of processing
- The period of storage
- The accessibility of data
For example, privacy settings should be set to the most privacy-friendly option by default, and individuals should have to actively opt-in to allow broader use of their data.
Key Principles
When implementing Privacy by Design and Default, organizations should consider:
- Data minimization: Only collect and process data that is adequate, relevant and necessary
- Purpose limitation: Clearly define purposes and don't use data for incompatible purposes
- Storage limitation: Don't keep data for longer than necessary
- Security: Implement appropriate security measures based on the nature of the data
Benefits
Implementing Privacy by Design and Default can:
- Reduce the risk of data breaches and compliance issues
- Build customer trust and confidence
- Give competitive advantage
- Reduce costs by avoiding retrofitting privacy features