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Privacy by design: Data protection starts in the whiteboard phase – Part 6 of 9

Jul 31, 2022 3:31:16 PM

This is the sixth in a series of nine blog posts on how Consumer Identity and Access Management (CIAM) products can help organisations in their Compliance with the General Data Protection Regulation (GDPR). This blog is part of a series that touches on important topics for CIAM experts who have an interest in the new EU regulation. This week’s topic is about ‘privacy by design’ – resulting in default protection of personal data.

Data Protection - where to start?

Doing business online requires a precise approach as you want customers to have a smooth and comfortable journey, ultimately leading to more sales and customer satisfaction. Well… Let’s say the GDPR adds another requirement to your list: protection of your customers’ data and privacy must be a top priority from the first whiteboard session onwards, known as ‘Data protection by design’ (also referred to as ‘privacy by design’).

In short, this means that organisations are obliged to take into account data privacy from the functional design stage onwards. Newly designed online services must be compliant with the principles of the GDPR from scratch.

The ultimate aim of the ‘data protection by design’ rules in the GDPR is to ensure that, when developing a product or service, appropriate technical and organisational measures are implemented to ensure data protection in line with the GDPR. In other words: doors to personal data that are supposed to be closed according to GDPR, should stay closed because the product or service via which it was gathered was designed that way. This entails strict access control.

Step 1: Start with awareness

Make sure that everyone involved in the development of a product or service is fully aware of the “privacy by design” requirement and, where possible, implements technical and organisational measures to increase privacy. An example of such measures are pseudonymisation and encryption of personal data, but also internal privacy policies.
Also, check your existing products and services to see if changes are necessary. As you can imagine, for existing services the results of such a check may lead to redesigns and software modifications. This can be quite an expensive undertaking.

Step 2: Another requirement - data minimisation

An important requirement that is introduced with this theme is ‘data minimisation’: only the personal data necessary for the indicated purpose should be processed and this principle should be embedded in the design of the product or service. In practice, this means that online retailers, for example, may not store your phone number if they do not require it for a specified purpose. If they do want to obtain and store this piece of information, they must ask the data prospect (i.e. the customer) for specific consent. Using consent given earlier for further processing is permitted, as long as it is for ‘compatible’ reasons (e.g. used for the same purpose as it had been originally collected for). And if a user is asked to provide data that is not necessary for delivering the product or service, then that can no longer be a mandatory field. Moreover, companies need to make clear what the impact is for filling in that field and mention the specific purpose of the processing of these data (as this is a requirement for getting consent).

Step 3: Use common sense when handling personal data

Luckily, your organisation is not alone in this as the new rules apply to everyone handling customer data. Moreover, the European legislators feel that the requirements are more or less ‘common sense’ to organisations that are committed to customer friendliness and privacy protection. And quite frankly: I agree with them.

This also holds if you look at the current state of affairs: some organisations have been compliant with these requirements from the start. However, if you still have some work to do please realise that the GDPR rules are in no way optional. On the contrary: you must act now to avoid enormous fines!

Next time, we will cover the right to erasure (also referred to: the right to be forgotten) under the new GDPR legislation which will be a tough cookie to crack for many organisations.

The GDPR in all official European languages can be found here:

In a series of 9 blogs, we will dive deeper into the specific parts of the GDPR and their effect on CIAM. 

  1. Why CIAM will never be the same with GDPR 
  2. Consent Management with GDPR in mind
  3. Transparency and GDPR 
  4. Strict regulation of automated individual decision making.
  5. What is sensitive personal data?
  6. Privacy by design: Data protection starts in the whiteboard phase 
  7. Right to be forgotten: The right to erasure 
  8. Data breach communication.
  9. Children's privacy under GDPR.

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