How do I make privacy by design and by default practical in my dev process?
GDPR Article 25 asks you to bake privacy into the design and pick the most privacy-friendly default. In practice it comes down to routine checks at design, build and release.
Try this first
- 1Add a privacy checkpoint to intake and design review: what data, which purpose, which basis, which retention. A short template, not an essay.
- 2Privacy-friendly defaults. Fields not pre-filled from other systems, marketing opt-in empty, profiles not public by default.
- 3Minimise data in models. Do you really need a birth date or does an age check suffice? Address only where you actually ship.
- 4Logging and analytics: use anonymised or aggregated data where possible. Cookieless or server-side analytics avoids a lot of debate.
- 5Document the privacy choices in release notes. It helps during DPIAs, audits and later changes by other team members.
When to bring us in
Building a product with profiling or automated decision-making? A DPIA up front and a privacy-lawyer review pays off.
See also
- Does NIS2 apply to my company?Two questions decide it: are you in a listed sector, and do you meet the threshold from Recommendation 2003/361/EC (more than 50 FTE and more than EUR 10M turnover or balance sheet). Below that you are only indirectly in scope, via your customers. The threshold determines whether you are an important or essential entity depending on sector.
- What changes with the Dutch Cyber Security Act?The Cyberbeveiligingswet is the Dutch implementation of NIS2. Track NCSC for the exact effective date and the lower regulations.
- Am I personally liable as a director under NIS2?Yes. The board is accountable for approving and overseeing the cyber measures. Severe negligence can become personal.
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