Seamlessly Integrating Privacy Compliance with Privacy by Design
by Patrick Oh (rewritten by Alvin Ang)
This is part of a series on :
Harmonizing Legal Compliance and Privacy by Design (CPbD): A Strategic Approach to Streamline Application Development
Privacy by Design (PbD) is a proactive approach wherein privacy is an inherent component during the development of new applications or systems. It ensures that privacy considerations are an integral part of the application’s core design, alongside its primary functionalities. In essence, PbD prioritizes privacy as a foundational element.
Conversely, the integration of Privacy Compliance and Privacy by Design (CPbD) represents a comprehensive strategy. It seeks to seamlessly merge the essential aspects of legal compliance with the principles of Privacy by Design. The outcome is a resilient application that not only upholds legal obligations but also prioritizes user privacy. This integration simplifies the compliance aspect for end-users, allowing them to focus more on productivity and marketing.
Given the abundance of literature available on Privacy by Design, this article delves directly into the CPbD approach. The objective is to equip solution designers and developers with a deep understanding of this approach, empowering them to seamlessly integrate it into their design and development processes. Furthermore, it offers insights into enhancing existing applications by adopting the CPbD framework, thereby significantly augmenting their value.
Let’s embark on this journey to explore the CPbD approach and unveil how it can empower solution designers and developers to craft applications that excel in both legal compliance and user privacy, ultimately elevating their competitive edge.
Assessing the Need for CPbD: A Step-by-Step Guide for Personal Data-Handling Applications
To determine the relevance of the CPbD (Privacy Compliance and Privacy by Design) approach, it is crucial to first ascertain whether your application involves the collection of personal data. In this context, we will reference the 11 Obligations outlined in the Singapore Personal Data Protection Act (PDPA) as the foundational framework for compliance considerations. It’s important to note that the discussion here focuses on the practical application of CPbD, while a comprehensive exploration of Privacy by Design’s seven principles can be found through external resources.
Within any data flow process, the following stages warrant careful consideration:
1. **Collection of Data**: Understand whether your application gathers personal data from users or other sources.
2. **Storage of Data**: Evaluate how and where the collected data is stored, including the security measures in place.
3. **Use of Data (Functions) and Disclosure to External Organizations**: Examine the functions your application performs with the collected data and whether it is shared with external entities beyond your organization.
4. **Retention and Disposal**: Determine the policies and procedures governing the retention and eventual disposal of personal data.
These four critical stages serve as the foundation for implementing CPbD effectively. By systematically addressing each of these aspects in alignment with the Singapore PDPA’s 11 Obligations, you can ensure that your application complies with data protection regulations while prioritizing user privacy and data security.
Incorporating CPbD: Enhancing Compliance and Privacy by Design in Application Development
The diagram presented above outlines a comprehensive set of design considerations (highlighted in RED Text) that should be meticulously developed and seamlessly integrated into applications or systems. Correspondingly, the left column aligns these design considerations with the legal obligations outlined in the Personal Data Protection Act (PDPA) of Singapore, creating a clear match with various data flow processes.
The integration of CPbD offers distinct advantages, notably ensuring that organizations adhere to privacy regulations as an inherent component of each data processing stage. CPbD streamlines compliance by generating requisite notifications and seamlessly embedding privacy-conscious features into applications, thereby achieving Compliance while embracing Privacy by Design principles.
CPbD holds particular relevance for several common application types, including:
1. **CRM (Customer Relationship Management) Systems**: Essential for maintaining customer data while adhering to privacy regulations.
2. **ERP (Enterprise Resource Planning) / HRM (Human Resource Management) Systems**: Vital for managing employee and organizational data, necessitating a privacy-centric approach.
3. **Membership Systems**: Crucial for organizations with membership databases, where data protection is paramount.
4. **Events Booking Systems**: Handling personal data related to event registrations requires robust privacy measures.
5. **Sales Funnel Systems**: Managing customer and sales data requires stringent privacy and compliance considerations.
In an era where data privacy and protection have gained paramount importance, widespread awareness and incorporation of Privacy Law and Privacy by Design principles among solution designers and developers can significantly benefit organizations. By embracing these principles, application development aligns seamlessly with legal requirements while ensuring the utmost privacy and safeguarding of personal data — providing organizations with peace of mind in a data-centric landscape.
About Patrick Oh
Patrick is a Singapore Certified Management Consultant providing PDPA compliance consultancy, Performance management and Solutions Design and Development.
https://www.linkedin.com/in/patrick-oh-sglion65/
About Dr. Alvin Ang
Dr. Alvin Ang earned his Ph.D., Masters and Bachelor degrees from NTU, Singapore. Previously he was a Principal Consultant (Data Science) as well as an Assistant Professor. He was also 8 years SUSS adjunct lecturer. His focus and interest is in the area of real world data science. Though an operational researcher by study, his passion for practical applications outweigh his academic background He is a scientist, entrepreneur, as well as a personal/business advisor.
More about him at www.AlvinAng.sg.
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