GDPR: Checklist

Lawful basis and transparency

• Organizations should keep list of processing activities.

• Organizations should be prepared to show list to regulators upon request.

• Organization shows GDPR compliance via data protection impact assesment.

• Assessment should include:

  • Purposes of processing.
  • What kind of data you processed.
  • Who has access to organization.
  • Any third parties.
  • what you are doing to protect the data.
  • when is planned erase if possible.

• Conduct info audit: determine what info you process and who has access.

• Have legal justification for data processing activities.

• Provide clear legal information about your data processing and legal justification in your privacy policy.

Data Security

• Mandatory follow "data protection by design and default" including "appropriate technical and organizational measures" to protect others personal data you use.
• Technical measures: Encryption.

Accountability and governance:

• By data protection by design and by default

• Make sure someone in your organization is accountable for GDPR compliance.

• The person should evaluate data protection policies and their implementation.

• Sign a data processing agreement between your organization and third parties who process your personal data.

• If your organization is outside EU: appoint representative within one of EU member states.

• If necessary appoint data protection officer.

Privacy rights: customer should have easy access to:

• Personal data about them
• How you use their data.
• How long yo plan to store their data and reason for that period.
• Get first copy of data for free (subsequent copies can be charged)

TIP

• make sure to verify customer requesting their identity.
• you should be able to comply with this request within a month.

Personal Data

Info relating to an identifiable natural person.

Personal Data

1. any information (objective or subjective)
2. relating to
3. an identifiable (ip, cookies, radio frequency)
4. natural person

GDPR applies only to data processed in one of these two ways:

• Personal data processed wholly or partly by automated means.
• Personal data processed in a non-automated manner which forms part of a "filing system".

Privacy Design Strategies

Privacy by design more practical by strategies:

• Bridge gap between data protection and system development.

• GDPR above data protection regulation.

• Taking data protection into account during software development via privacy by design PbD. During development life-cycle.

• Software Architecture highest level of abstraction (functionality and quality attributes)

  • Difficult 'architectural tactics in software architecture domain for quality attributes'
  • attributes: security, privacy protection

GDPR focuses on specification, limitation, proportionality and consent "free flow of info"

Tactic

An approach to privacy by design which contributes to the goal of an overarching privacy design strategy.

Privacy Design Strategy

Specifies a distinct architectural goal in privacy by design to achieve a certain level of privacy protection.

Minimize	Hide	Separate	Abstract	Inform	Control	Enforce	Demonstrate
Exclude, Select, Strip, Destroy	Restrict, Mix, Obfuscate, Dissociate	Distributes, Isolate	Summarize, Group
Supply, Notify, Explain	Consent, Choose, Update, Retract	Create, Maintain, Uphold	Audit, Log, Report

Action	GDPR terms
Operate	Adaptation, Alteration, Retrieval, Consultation, Use, Alignment
Store	Organization, Structuring, Storage
Retain	opposite to Erasure
Collect	Collection, Recording
Share	Transmission, Dissemination
Change	Unauthorized third party (Alteration, Adaptation )
Breach	unauthorized third party (Retrieval)

Other strategies: Hide, demonstrate, obfuscate, enforce (hash, encrypt, test, audit)

Strategies for: limitation, prevention, provision, insurance: agreed upon purposes.

Minimize (Strategy)

• Minimal operation/collection on data
  • All or nothing processing (exclusive)
  • Granular privacy settings (selective)
• Data open to collection (identify types) prior to collection
  • Apply data stripping (remove not needed fields entirely)
  • Means deletion of purposeless data
• Minimize is about data itself rather than access to it: Hide is about the access.
• Tactics exclude, select, strip, destroy.

Hide (Strategy)

• Limits access for storage, sharing and operation on personal data with purpose.
• Tactics: restrict, mix, obfuscate, dissociate.

Separate (Strategy)

• Preventing correlation of personal data
• Tactics: distribute, isolate

Abstract (Strategy)

• Limiting details as much as possible
• Processing correlation instead of data itself

Inform (Strategy)

• Tactics: supply, notify, explain

Control (Strategy)

• Tactics: consent, update, retract provide

Enforce (Strategy)

Tactics:

• Create (acknowledge value of privacy)
• Maintain (considering privacy when updating features)
• Uphold (make sure policies respect privacy)

Demonstrate (Strategy)

• Ensuring evidence of adhering to obligations

Privacy Design Strategies

Ways privacy protection may be breached

Validity of abstract and separate.