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Subject: Privacy by design example


All,

After today's TAG call, I thought it might be helpful to share with others a little more insight into how I tackle privacy by design. Most specifically the comment arose that non-data privacy issues were too difficult or expansive to consider within a privacy by design process.Â

I'm attaching an analysis I did for a recent client. The client has agreed to let make the analysis public, and we'll be releasing pushing it out via blog posts, presses releases and on social medial in the next week or two. The TAG is just getting a slightly advanced peek.Â

I will clarify that where I use Jaap-Henk Hoepman's privacy design strategies (and tactics) and the definitions of those strategies and tactics are data-centric, I apply them in a non-data centric way.Â

For instance the controlÂ
ARCHITECT -> Minimize -> exclude is defined by JHH as "Refrain from processing a data subjectâs personal data"
(SUPRA-STRATEGY -> Strategy -> tactic)

I would interpret that as "Refrain from interacting with an individual" for the purposes of preventing non-data privacy violations (surveillance, interrogation, intrusion and decisional interference under the Solove taxonomy).Â

I welcome any questions on the analysis.Â

JasonÂ
.....................................................................
R. Jason CronkÂÂÂÂÂÂÂÂÂÂÂÂÂÂÂÂÂ | Juris DoctorÂ
Privacy and Trust ConsultantÂÂÂ | IAPP Fellow of Information Privacy
Enterprivacy Consulting GroupÂÂ | CIPT, CIPM, CIPP/US, PbD Ambassador
Privacy notices made simple: https://simpleprivacynotice.com
....................................................................
Upcoming Training
Privacy by Design Professional: - English/Russian (July)
Online (coming soon): https://privacybydesign.training

Attachment: Strategic Privacy Design Report -MR YOUNG.pdf
Description: Adobe PDF document



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