Privacy by design

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Glossary · GRC and resilience

Privacy by design

Also called data protection by design and by default, privacy by default

Definition

Privacy by design means building data protection into systems, products and processes from the start rather than adding it later. Under GDPR it is a legal duty called data protection by design and by default. Firms must choose measures such as data minimisation and pseudonymisation, and collect only the personal data each purpose needs.

MINIMISE DATAPSEUDONYMISEDEFAULT SETTINGS
Fig. 1 · Privacy by design
GDPR Article 25 · UK GDPR Article 25 · ISO 31700-1
Key rulesGDPR Article 25 · UK GDPR Article 25 · ISO 31700-1
Applies toControllers processing personal data of people in the EU
RegionsEU · UK · Global
01

How it works

At a regulated firm, privacy by design starts when a new product, system or vendor is proposed. The privacy team reviews what personal data is needed and for how long. High-risk processing triggers a data protection impact assessment. Engineers set default settings to the most privacy-protective option, limit access and build in deletion. Decisions are documented so the firm can show accountability.

Financial firms process large volumes of sensitive customer data for onboarding, monitoring and credit decisions. Supervisory authorities can fine controllers that fail to apply Article 25, separately from any breach. The principle also shapes AI projects, where training data, retention and explainability need early design choices. Building controls in early is usually cheaper than rebuilding systems after an audit.

Step 1Screen projectsFlag new systems that process personal data.
Step 2Assess riskRun a DPIA where processing is likely high risk.
Step 3Minimise dataCollect only what each purpose needs, for limited periods.
Step 4Set defaultsConfigure the most privacy-protective settings by default.
Step 5DocumentRecord design decisions to show accountability.
02

The rules

EU · 25 May 2018GDPR Article 25Regulation (EU) 2016/679, Article 25 Data protection by design and by default

Controllers must implement technical and organisational measures to apply data protection principles and process only the personal data needed by default.

Controllers processing personal data of people in the EU
UK · 1 January 2021UK GDPR Article 25UK General Data Protection Regulation, Article 25, as amended by the Data (Use and Access) Act 2025

Keeps the duty of data protection by design and by default. Since 5 February 2026 online services likely to be used by children must also weigh their higher protection needs.

Controllers processing personal data in the UK
Global · 2023ISO 31700-1ISO 31700-1:2023 Consumer protection, Privacy by design for consumer goods and services, Part 1

Sets high-level requirements for building privacy protections into consumer products across their whole lifecycle.

Organisations designing consumer goods and services
03

Common questions

Is privacy by design a legal requirement?

Yes, in the EU and UK. Article 25 of GDPR and UK GDPR requires controllers to build data protection into processing and to apply privacy-protective defaults. Regulators can enforce this duty even where no data breach has occurred.

What does privacy by default mean?

Privacy by default means that, without any action by the user, a system processes only the personal data needed for each specific purpose. It limits how much data is collected, how long it is kept and who can access it.

How does a DPIA relate to privacy by design?

A data protection impact assessment is one of the main tools for privacy by design. GDPR requires it before processing likely to result in high risk to individuals. It records the risks identified and the measures chosen to reduce them.