Six Steps for Implementing Privacy by Design at Your Organization
As the importance of data privacy and security increases, everyone is facing pressure to ensure that their data handling practices comply with the latest data privacy laws. From the EU’s GDPR to the newly established ISO 31700, a growing number of regulations are requiring companies to implement strong safeguards for personal data.
One of the most effective ways to ensure that data privacy is thoroughly incorporated into your organization’s operations is by adopting privacy by design (PbD). This framework is especially useful for staying up to date with the ever-shifting regulatory landscape and for avoiding privacy risks as your company grows and scales.
We’ve already covered some of the basics in our posts on privacy by design for the cloud and privacy by design for cross-border compliance. Now, we’ll discuss six key steps for implementing PbD at your organization.
What is privacy by design?
Essentially, privacy by design is a framework for integrating data privacy features into a company’s technology and daily operations in a proactive way. Instead of retroactively adding data protection to existing systems and infrastructure, PbD requires that data protection be implemented in the design of those systems from the outset.
Privacy by design, in other words, embeds data privacy considerations into the initial design of information systems, technologies, processes, and even company culture.
1. Conduct a Privacy Impact Assessment (PIA)
The first step in implementing privacy by design is to conduct a privacy impact assessment (PIA) that identifies your organizations’ existing privacy practices and risks. A PIA analyzes how your company handles personal data, whether it complies with relevant regulations, what risks your IT systems carry, and how those risks can be reduced.
A privacy impact assessment can also document how personal data is collected, processed, stored, and shared in order to assess the impact of those practices on individuals’ privacy rights. It’s a basic first step for understanding risks in the data lifecycle so you can then incorporate privacy elements where they’re needed.
2. Choose the right PbD framework for regulatory compliance
You might be thinking, isn’t privacy by design already a framework? It is, but there are variations in the different PbD approaches mandated by different regulations.
For instance, the GDPR requires organizations to consider privacy from the outset, identify potential risks, and implement measures to mitigate those risks. An organization that processes personal data from or in the EU may want to adopt the original privacy by design framework proposed by the Information and Privacy Commissioner of Ontario, which aligns closely with the GDPR.
On the other hand, businesses that primarily process the data of California residents may be better served by adopting the NIST Privacy Framework, which provides guidelines for addressing privacy risks in compliance with the California Consumer Privacy Act (CCPA).
3. Implement organizational measures
An often-overlooked part of implementing PbD is integrating privacy into not just technology systems but also everyday business processes and company culture. Instead of simply relying on software solutions to protect data, an effective PbD approach will delineate data privacy responsibilities throughout the organization.
Organizational measures for privacy by design may include staff training, data protection policies, incident response procedures, and cybersecurity exercises. Given the wide range of cyberthreats in today’s workplace, even non-IT departments like marketing, HR, and design must be made aware of their data privacy responsibilities.
As IAPP security experts note, these organizational measures must extend to everyone up to and including the C suite. When possible, new privacy processes also should leverage existing workplace tools and resources so they’re easier to adopt.
4. Implement technical measures
Once you’ve created a privacy-conscious culture in your organization, it’s time to implement technological measures. These measures may include encryption, access controls, data anonymization, pseudonymization, noise addition, and much more.
For instance, all sensitive data should be encrypted both in transit and at rest — including backups and databases. Additionally, access controls should be implemented to ensure that only authorized personnel can access sensitive data.
Below, we’ll explore ShardSecure’s technical solution for privacy by design in more depth.
5. Continuously monitor and reassess your policies
Once you’ve assessed your privacy practices and integrated PbD into both your company culture and technologies, it’s not time to sit back and relax. Privacy by design must be regularly monitored to ensure continued success — and this goes double if you’re using it to meet regulatory compliance.
No organization stays the same; departments, vendors, processes, and systems all change as a company grows. As such, it’s important to continuously assess your data privacy practices to ensure they’re evolving along with your organization. Regular audits will help identify data protection risks and compliance problems before they become a major issue.
6. Consider solutions like ShardSecure
ShardSecure’s data control platform offers robust data privacy and security. Our technology works to protect data from unauthorized access on-prem, in the cloud, and in hybrid- and multi-cloud environments. With ShardSecure, data becomes unreadable to third parties, whether they’re well-resourced attackers who have accessed critical files, a vendor who’s been granted the wrong permissions, or simply a storage provider admin.
With high availability and multiple data integrity checks, ShardSecure’s data control platform also offers robust data resilience. We ensure that your data doesn’t just remain private; it also remains accurate and available in the face of outages and attacks.
Implementing privacy by design has become increasingly important for any organization that handles personal data. While any company that’s implementing privacy by design to meet regulatory compliance will want to consult with a legal expert, the six steps above are a good starting place for protecting the privacy rights of individuals and safeguarding personal data.
At the end of the day, adopting PbD is not only good for compliance; it’s also good for building customer trust and keeping your business safe from cyberthreats. Get in touch with ShardSecure to find out how we can help you implement better data privacy and protection today.
ISO 31700-1:2023 | International Organization for Standardization
Creating Risk-Aware Culture Through Privacy by Design | Security Magazine
Privacy Impact Assessments | USDA
What Is Privacy Impact Assessment (PIA)? | TechTarget
Privacy by Design | Information & Privacy Commissioner
CCPA Crosswalk by BakerHostetler | NIST
How To Successfully Embed a Culture of Privacy by Design | Ernst & Young
How To Operationalize Privacy by Design | IAPP
Practical Strategies for Creating a Privacy Culture in Your Organization | IAPP
Privacy by Design for Technology Development Teams | TechGDPR
How To Assess Your Company’s Privacy And Data Protection Readiness | Forbes