A Critical Analysis of Privacy Design Strategies

Abstract

The upcoming General Data Protection Regulation is quickly becoming of great concern to organizations which process personal data of European citizens. It is however nontrivial to translate these legal requirements into privacy friendly designs. One recently proposed approach to make 'privacy by design' more practical is privacy design strategies. This paper improves the strategy definitions and suggests an additional level of abstraction between strategies and privacy patterns: 'tactics'. We have identified a collection of such tactics based on an extensive literature review, in particular a catalogue of surveyed privacy patterns. We explore the relationships between the concepts we introduce and similar concepts used in software engineering. This paper helps bridge the gap between data protection requirements set out in law, and system development practice.

A Refinement Approach for the Reuse of Privacy Risk Analysis Results

“…In contrast with previous work on privacy by design, "privacy design strategies" or privacy engineering [26], [7], [24,25], [38], we do not propose a new design framework or process here, but a methodology to select an architecture among a range of options and to justify this choice with respect to a privacy risk analysis. Our work is therefore complementary to the above proposals and contributes to establish links between privacy risk analysis and privacy by design.…”

Privacy Shielding by Design — A Strategies Case for Near-Compliance

“…A privacy design strategy "specifies a distinct architectural goal in privacy by design to achieve a certain level of privacy protection" [5]. Privacy design strategies are a technique for achieving privacy by design first noted by Hoepman [4].…”

“…They previously translated the original data protection principles into design goals more accessible to software engineers. These strategies have been extended to make them more relevant in the GDPR context, and provide a direct path from concept to design implementation [5]. This is achieved through privacy patterns, common solutions to recurring design problems in privacy by design.…”

“…They are shown in TABLE I. SEPARATE for instance can be approached through both processing in isolation, and in distributing the data, both logically and physically [5]. The ongoing collection of privacy patterns which the strategies and tactics connect to are found in [11].…”

“…'Strategies' use the GDPR to formulate software design goals, and then suggest 'privacy patterns' (recurring solutions to common design problems in privacy) for implementation [5]. These were initially designed to assist in adhering to the EU Data Protection Directive [4].…”