Privacy-by-Design Review Template (GDPR Art. 25, ISO 31700-1)
Scope, data inventory, consumer privacy requirements, default decisions, minimisation, user controls, notice and consent, lifecycle, third parties, evidence
Як використовувати: Use it when a product or feature is at concept or design stage and you need a record of the privacy choices built into it. Fill the scope and the data inventory first, then the defaults and minimisation decisions, and screen for a DPIA in section 12. The main pitfall is writing it after launch, when it only documents decisions instead of shaping them. Honest current-state scores matter more than target ambitions.
Перегляд
Privacy-by-Design Review: [Product or feature name]
Record of how privacy was designed into a product, feature or service through its lifecycle, from concept to retirement. It documents the consumer privacy requirements, the privacy-by-default decisions, data minimisation choices, user controls, notice and consent design, the data lifecycle, third parties and the assurance evidence that shows the measures work. It follows Article 25 of the General Data Protection Regulation (Regulation (EU) 2016/679, data protection by design and by default) and the EDPB Guidelines 4/2019 on Article 25 (version 2.0, adopted 20 October 2020). Its requirement areas are aligned with the clause structure of ISO 31700-1:2023 (privacy by design for consumer goods and services, high-level requirements), cited by name only. It sits upstream of the DPIA and the privacy threat model. Replace every
[bracketed]value and every row marked Example. This is a documentation format, not legal advice.
Document control
| Field | Value |
|---|---|
| Document ID | [PBD-REV-001] |
| Product or feature | [Product name], [feature name], [release or epic ID] |
| Controller | [Legal entity name] |
| Lifecycle stage | [Concept / Design / Build / Pre-launch / Live / Change / Retirement] |
| Linked DPIA | [DPIA ID or "Screened out, see section 12"] |
| Linked privacy threat model | [Threat model ID] |
| Linked RoPA entry | [RoPA processing activity ID] |
| Version | [0.1] |
| Status | [Draft / In review / Approved / Superseded] |
| Owner | [@product-owner] |
| Approvers/reviewers | [@privacy-engineer], [@dpo], [@security-architect], [@ux-lead], [@legal] |
| Last updated | YYYY-MM-DD |
| Next review due | YYYY-MM-DD or [lifecycle checkpoint] |
| Classification | [Internal] |
Approvals
| Role | Name | Decision | Date |
|---|---|---|---|
| Product owner (accountable for the feature) | [@name] | [Approve / Approve with conditions / Reject] | YYYY-MM-DD |
| Privacy engineer (author or reviewer) | [@name] | [Decision] | YYYY-MM-DD |
| Data protection officer (advice) | [@name] | [Advice recorded in section 15] | YYYY-MM-DD |
| Security architect | [@name] | [Decision] | YYYY-MM-DD |
Revision history
| Version | Date | Author | Change |
|---|---|---|---|
| 0.1 | YYYY-MM-DD | [@author] | Initial review at concept stage |
| [0.2] | YYYY-MM-DD | [@author] | [Design checkpoint: data model and user interface reviewed] |
| [1.0] | YYYY-MM-DD | [@author] | [Pre-launch sign-off, assurance evidence attached] |
| [1.1] | 2026-10-24 | [@author] | Example: Saved payment details moved to consent (EDPB Recommendations 02/2021); retention and classification aligned with the retention standard and classification policy; DPIA screening extended to the Art. 35(4) list and WP248 criteria |
Contents
- 1. Scope and lifecycle stage
- 2. Positioning: which privacy document to use
- 3. Roles and responsibilities
- 4. Processing overview and data inventory
- 5. Consumer privacy requirements
- 6. Privacy by default decisions
- 7. Data minimisation
- 8. User controls and data subject rights
- 9. Notice and consent design
- 10. Data lifecycle
- 11. Third parties and recipients
- 12. Privacy risk screening and DPIA trigger
- 13. Assurance evidence
- 14. Lifecycle checkpoints and re-review triggers
- 15. Findings, decisions and actions
- 16. Traceability matrix
- 17. Glossary and references
- Standard and licence note
1. Scope and lifecycle stage
Describe the product or feature in two or three sentences, written so that a reviewer who has never seen it understands what data it needs and why.
| Item | Description |
|---|---|
| Feature summary | [What the feature does for the consumer] |
| Consumers affected | [Customers, prospects, children, employees, business contacts] |
| Channels | [Web, iOS, Android, contact centre, in-store, API] |
| Markets and jurisdictions | [EU, UK, other] |
| Components in scope | [Services, data stores, pipelines, vendors] |
| Out of scope | [Components reviewed elsewhere, with the reference] |
| Lifecycle stage at this version | [Concept / Design / Build / Pre-launch / Live / Change / Retirement] |
Example: Corvid Commerce adds "Saved checkout details" so that returning customers can store a delivery address and a payment token and check out in one step. In scope: the web and mobile checkout, the Checkout service, the customer profile store, the payment service provider integration and the "Checkout" data product in the lakehouse. Out of scope: fraud scoring, which has its own DPIA.
2. Positioning: which privacy document to use
This review is the design record. It shows which privacy decisions were taken, when, by whom and with which evidence. It does not replace the documents below; it feeds them.
| Document | Question it answers | Relationship to this review |
|---|---|---|
| This review | Which privacy-protective choices did we design in, and do they work? | Starts at concept stage, updated at each checkpoint |
DPIA (compliance/dpia) | Is the processing likely to result in a high risk, and are the risks reduced to an acceptable level? | Required when the screening in section 12 meets the Article 35 criteria |
Privacy threat model (security/privacy-threat-model) | How could the system be abused or fail to protect individuals? | Uses the data flow from section 4; its mitigations return as requirements in section 5 |
De-identification assessment (compliance/de-identification-assessment) | Is a released or shared dataset adequately de-identified? | Triggered when section 7 relies on pseudonymisation or anonymisation |
PET selection assessment (compliance/pet-selection-assessment) | Which privacy-enhancing technology fits the use case? | Triggered when a requirement needs a PET |
Records of processing (compliance/gdpr-ropa) | What processing do we carry out, on what basis? | Section 4 updates the RoPA entry |
How the sections map to the requirement areas of ISO 31700-1:2023 (described in original words; confirm the clause numbering against your licensed copy):
| ISO 31700-1 requirement area (paraphrased) | Sections of this review |
|---|---|
| General design requirements: consumer rights, preferences, interface design, roles, privacy information | 3, 5, 6, 8 |
| Communicating with consumers about privacy | 9 |
| Privacy risk management | 12, 15 |
| Developing, deploying and operating privacy controls | 7, 10, 13 |
| End of the lifecycle of the personal data | 10, 14 |
3. Roles and responsibilities
| Role | Responsibility in this review | Name |
|---|---|---|
| Product owner | Accountable for the feature and for accepting residual privacy risk | [@name] |
| Privacy engineer | Writes the review, translates principles into requirements, verifies evidence | [@name] |
| Data protection officer | Gives advice, monitors compliance, is consulted on the DPIA | [@name] |
| UX designer | Designs notices, consent flows and controls; runs usability tests | [@name] |
| Engineering lead | Implements the technical measures and provides test evidence | [@name] |
| Data engineer | Implements retention, deletion and pseudonymisation in pipelines | [@name] |
| Security architect | Reviews security measures and the threat model link | [@name] |
| Procurement or vendor manager | Collects contract and assurance evidence for third parties | [@name] |
4. Processing overview and data inventory
4.1 Data flow
Draw every hop the personal data takes, including logs and analytics. The same diagram is the starting point for the privacy threat model.
4.2 Data inventory
| ID | Data element | Source | Purpose | Lawful basis (GDPR Art. 6) | Classification | Store | Retention |
|---|---|---|---|---|---|---|---|
| DE-001 (Example) | Delivery address | Customer | Deliver the current order; prefill later checkouts | Contract (Art. 6(1)(b)) for the current order; consent (Art. 6(1)(a), PBD-CON-002) for keeping it saved | Confidential (CR-05) | Profile store | RET-020: 24 months of inactivity, or at once when the customer removes it; order copies under RET-002 |
| DE-002 (Example) | Payment token reference | PSP | Repeat payment without re-entry of card | Consent (Art. 6(1)(a), PBD-CON-002), following EDPB Recommendations 02/2021; separate from the terms, unticked | Confidential (CR-05; token, so no PAY flag) | Profile store | RET-020: 24 months of inactivity, or at once when removed; token revoked at the PSP |
| DE-003 (Example) | Saved-details consent choice and timestamp | Customer | Proof of consent (Art. 7(1)) | Proof of consent (Art. 7(1)), kept as part of the consent-based processing in DE-001 and DE-002 | Confidential (CR-05) | Profile store | RET-004: [limitation period] after withdrawal or account closure |
| DE-004 (Example) | Pseudonymised checkout event | Checkout service | Conversion reporting in aggregate | Legitimate interests (Art. 6(1)(f)), balancing test ref. LIA-014 | Confidential (CR-05; PD, PSEUDO) | Lakehouse | RET-011: event time + 13 months |
| [DE-005] | [Element] | [Source] | [Purpose] | [Basis] | [Level (CR-NN) per data/data-classification-policy] | [Store] | [RET-NNN: period] |
Lawful basis note: storing card data only to make later purchases easier is not necessary for the sales contract. EDPB Recommendations 02/2021 (adopted 19 May 2021) conclude that consent is the appropriate basis, given separately from the terms of sale and never as a condition of completing the purchase. Corvid stores a PSP token rather than card data, but applies the same reasoning to the saved token and address. Retention values quote the rule IDs and periods of the retention standard; classification values quote the level and criterion ID of the classification policy.
Record special categories (GDPR Art. 9) and data about children separately and flag them for the section 12 screening.
5. Consumer privacy requirements
Write each requirement as a design behaviour with an acceptance test. Group them by the data protection principles in GDPR Article 5, which is also how the EDPB Guidelines 4/2019 organise the key design and default elements. Derive requirements from four inputs: the principles, consumer research (what users expect), the privacy threat model and contractual commitments.
| Req ID | Principle | Requirement | Acceptance test | Source |
|---|---|---|---|---|
| PBD-REQ-001 (Example) | Transparency | Explain at the point of saving what is stored, why and how to remove it, in one short layer with a link to the full notice | Usability test: 8 of 10 participants can say what is stored and how to remove it | Consumer research study RES-07 |
| PBD-REQ-002 (Example) | Lawfulness, fairness | Saving details is optional and based on separate, unticked consent (PBD-CON-002); checkout works without saving | E2E test: guest and non-saving checkout complete successfully; consent record created only on a positive action | Art. 25(2) default; EDPB Recommendations 02/2021 |
| PBD-REQ-003 (Example) | Purpose limitation | Saved addresses are not used for marketing segmentation | Data contract on the Checkout data product excludes the address field; lineage check | Threat model PTM-012 |
| PBD-REQ-004 (Example) | Data minimisation | Store a PSP token, never the card number or security code | Code review and storage scan show no PAN in profile store or logs | PCI scope reduction |
| PBD-REQ-005 (Example) | Accuracy | Customers can edit an address in two steps from the account page | UI test | Section 8 |
| PBD-REQ-006 (Example) | Storage limitation | Purge saved details after 24 months of account inactivity (RET-020) | Scheduled job test with a synthetic account | Retention standard, RET-020 |
| PBD-REQ-007 (Example) | Integrity and confidentiality | Encrypt the profile store at rest and restrict read access to the Checkout service role | Access review evidence, configuration export | Security architecture |
| PBD-REQ-008 (Example) | Accountability | Log each change of the saving choice with timestamp and channel | Audit log sample | Section 13 |
| [PBD-REQ-009] | [Principle] | [Requirement] | [Test] | [Source] |
6. Privacy by default decisions
For each configurable behaviour, record the default state and why it is the most privacy-protective option that still delivers the purpose. A default that is not the most protective option needs a recorded justification and the approval of the product owner and the DPO advice.
| Default ID | Setting or behaviour | Dimension (amount, extent, period, accessibility) | Default state | Reason | Alternative considered |
|---|---|---|---|---|---|
| PBD-DEF-001 (Example) | "Save details for next time" | Amount | Off, unchecked | Saving is a convenience the consumer opts into | Pre-checked box rejected: not a protective default |
| PBD-DEF-002 (Example) | Address visibility to customer service agents | Accessibility | Masked; full view on verified call only | Agents rarely need the full address | Always visible rejected |
| PBD-DEF-003 (Example) | Order events in analytics | Extent | Pseudonymised, aggregate reporting only | Conversion reporting does not need identity | Raw customer ID rejected |
| PBD-DEF-004 (Example) | Retention of saved details | Period | 24 months inactivity (RET-020) | Matches repurchase cycle in research | Indefinite retention rejected |
| [PBD-DEF-005] | [Setting] | [Dimension] | [Default] | [Reason] | [Alternative] |
Record dark-pattern checks here too: no confirm-shaming, no asymmetric buttons, no repeated prompts after a refusal, and an equally easy way to undo a choice.
7. Data minimisation
Run each element in the section 4 inventory through the questions below and record the outcome. Remove, reduce or transform the element when the answer allows it.
- Is the element necessary for the stated purpose, or only useful?
- Can a less precise form serve the purpose (postcode district instead of full address, age band instead of birth date)?
- Can it be derived on demand instead of stored?
- Can it be processed on the device or at the edge instead of centrally?
- Can it be pseudonymised, aggregated or anonymised before it reaches analytics or a third party?
- Can access be limited to a smaller role or a shorter window?
| Min ID | Data element | Decision | Technique | Residual need | Link |
|---|---|---|---|---|---|
| PBD-MIN-001 (Example) | Card number | Not stored | PSP tokenisation | Token reference only | DE-002 |
| PBD-MIN-002 (Example) | Phone number at checkout | Optional field, removed from saved details | Removal | Only for delivery issues on the current order | DE-001 |
| PBD-MIN-003 (Example) | Customer ID in analytics | Replaced by keyed pseudonym rotated yearly | Pseudonymisation | Re-linking restricted to fraud team | DE-004 |
| PBD-MIN-004 (Example) | Full address in logs | Masked at the logging library | Masking | None | PBD-REQ-007 |
| [PBD-MIN-005] | [Element] | [Decision] | [Technique] | [Residual need] | [Link] |
When minimisation relies on pseudonymisation or anonymisation, run the
De-identification Assessment (compliance/de-identification-assessment).
Pseudonymised data remains personal data under the GDPR; record it as
such.
8. User controls and data subject rights
| Control ID | Control | Right supported (GDPR article) | Where in product | Effect and propagation time | Test |
|---|---|---|---|---|---|
| PBD-CTL-001 (Example) | View saved details | Access (Art. 15) | Account, "Saved details" | Immediate | UI test |
| PBD-CTL-002 (Example) | Edit address | Rectification (Art. 16) | Account and checkout | Immediate in profile store | UI test |
| PBD-CTL-003 (Example) | Remove saved details | Erasure (Art. 17) | Account and checkout | Profile store immediate; PSP token revoked within 24 hours; lakehouse pseudonym link removed at next daily run | E2E plus pipeline test |
| PBD-CTL-004 (Example) | Opt out of analytics events | Object (Art. 21) | Privacy settings | Next session | Event capture test |
| PBD-CTL-005 (Example) | Download my data | Portability (Art. 20) | Account, "Privacy" | Export ready within 48 hours, JSON | Integration test |
| [PBD-CTL-006] | [Control] | [Right] | [Location] | [Effect] | [Test] |
Make sure each control is reachable with a keyboard and a screen reader, and that it works the same way in every channel listed in section 1. Requests made through support must reach the same back-end operations as the self-service controls.
9. Notice and consent design
9.1 Notice layers
| Layer | Moment | Content | Owner |
|---|---|---|---|
| Just-in-time | At the "save details" checkbox | What is saved, why, how to remove it, link to full notice | [@ux-lead] |
| Settings page | Account, "Privacy" | All choices and their current state | [@ux-lead] |
| Privacy notice | Footer, account | Full GDPR Art. 13 information, updated for this feature | [@legal] |
| Change notice | On material change | What changed and any new choice | [@product-owner] |
Update the Privacy Policy (legal-lite/privacy-policy) and, where the
feature sets or reads cookies or similar technologies, the Cookie
Policy (legal-lite/cookie-policy).
9.2 Consent records
Use consent only where it is the right lawful basis. Record each consent-based processing activity below.
| Consent ID | Processing | Wording reference | Granularity | Withdrawal path | Record kept |
|---|---|---|---|---|---|
| PBD-CON-001 (Example) | Personalised product suggestions from saved purchase history | Copy deck v3, string consent.suggestions | Separate from saving details | Toggle in Privacy settings, one step | User ID, choice, timestamp, wording version, channel |
| PBD-CON-002 (Example) | Save delivery address and payment token for later purchases | Copy deck v3, string consent.save_details | Separate from the terms of sale and from PBD-CON-001; unticked; not a condition of purchase | "Remove saved details" in the account and at checkout, one step | User ID, choice, timestamp, wording version, channel (DE-003, RET-004) |
| [PBD-CON-003] | [Processing] | [Reference] | [Granularity] | [Path] | [Record] |
Honour browser privacy signals such as Global Privacy Control where the applicable law or your policy requires it, and record how the signal is treated.
10. Data lifecycle
| Stage | Copies and locations | Control | Evidence |
|---|---|---|---|
| Collection | Browser, Checkout service memory | TLS, input validation, no client-side storage of address | Configuration review |
| Storage | Profile store, encrypted | Role-based access, key management | Access review (ops/access-review) |
| Use | Checkout prefill, delivery | Purpose binding in service code | Code review |
| Sharing | PSP, carrier | Contracts in section 11 | DPA or data sharing agreement |
| Analytics | Lakehouse, pseudonymised | Data contract excludes direct identifiers | Contract test |
| Archive and backup | Encrypted backups | Rotation per backup policy | Backup rotation log |
| Deletion | All of the above | Deletion events propagate to downstream stores | Deletion verification report |
Align periods with the Data Retention and Deletion Standard
(data/data-retention-deletion-standard) and the records schedule
(compliance/iso-15489-records-schedule). State how deletion is
verified, not only how it is triggered.
11. Third parties and recipients
| Recipient ID | Recipient | Role | Data | Contract | Location and transfer mechanism | Assurance |
|---|---|---|---|---|---|---|
| PBD-TP-001 (Example) | Payment service provider | Independent controller for card data, processor for tokens (per its terms) | DE-002 | PSP agreement, data sharing terms | EU | PCI DSS attestation |
| PBD-TP-002 (Example) | Delivery carrier (Larkspur Logistics) | Independent controller | DE-001 for the current order | Data Sharing Agreement DSA-001 (compliance/data-sharing-agreement) | EU, no international transfer | Annual questionnaire |
| PBD-TP-003 (Example) | Cloud hosting provider | Processor | All | DPA (legal-lite/dpa) | EU region | ISO/IEC 27001 certificate, SOC 2 report |
| [PBD-TP-004] | [Recipient] | [Role] | [Data] | [Contract] | [Location, mechanism] | [Assurance] |
Check residency and transfer questions with the Data Residency and
Sovereignty Assessment (compliance/data-residency-sovereignty-assessment)
and supplier security with the Supplier Security Assessment
(compliance/supplier-security-assessment).
12. Privacy risk screening and DPIA trigger
Answer each question. A "yes" to any of the first four (the three cases
of Article 35(3) and the supervisory authority list under Article
35(4)) makes a DPIA mandatory. Two or more "yes" answers among the
remaining rows, which follow the WP248 rev.01 criteria, mean you should
run a full DPIA (compliance/dpia) unless the DPO advises otherwise in
writing and the reasons are recorded. Treat the two-indicator rule as
an internal policy example; adapt it to the supervisory authority lists
that apply to you.
| Screening question | Answer | Notes |
|---|---|---|
| Systematic and extensive evaluation with legal or similarly significant effects (Art. 35(3)(a))? | [Yes / No] | [Notes] |
| Large-scale processing of special category or criminal offence data (Art. 35(3)(b))? | [Yes / No] | [Notes] |
| Systematic monitoring of a publicly accessible area on a large scale (Art. 35(3)(c))? | [Yes / No] | [Notes] |
| Listed in the national supervisory authority DPIA list (Art. 35(4))? | [Yes / No] | [List and item] |
| Evaluation or scoring, including profiling and predicting? | [Yes / No] | [Notes] |
| Automated decision with legal or similarly significant effect? | [Yes / No] | [Notes] |
| Systematic monitoring of people? | [Yes / No] | [Notes] |
| Sensitive or highly personal data (including payment and financial data)? | [Yes / No] | [Notes] |
| Vulnerable data subjects, including children? | [Yes / No] | [Notes] |
| New technology or novel use of data? | [Yes / No] | [Notes] |
| Matching or combining datasets from different sources? | [Yes / No] | [Notes] |
| Large scale in number of people, volume, duration or geography? | [Yes / No] | [Notes] |
| Processing that prevents people exercising a right or using a service? | [Yes / No] | [Notes] |
Example: For "Saved checkout details", the first four answers are "No". Two rows need judgement: large scale (2.1 million active customers, of whom 1.2 million are in the EU) is "Yes"; highly personal data is "No", because the card number never reaches Corvid and only a PSP token is stored. One indicator, so the DPO advised that no DPIA is required and the reasoning was recorded; the screening is re-run at the "Change" checkpoint and whenever the token is used for anything beyond repeat checkout.
13. Assurance evidence
The EDPB guidelines stress that measures must be effective, so record evidence of operation, not only of intent. Article 25(3) allows an approved certification under Article 42 to be used as one element of demonstrating compliance; it does not replace this evidence.
| Evidence ID | Requirement or decision | Evidence type | Location | Produced by | Date |
|---|---|---|---|---|---|
| PBD-EVD-001 (Example) | PBD-REQ-002 | E2E test report, guest checkout | CI run 4821 | [@qa] | YYYY-MM-DD |
| PBD-EVD-002 (Example) | PBD-DEF-001 | Production configuration export | Evidence store, folder PBD-REV-001 | [@engineer] | YYYY-MM-DD |
| PBD-EVD-003 (Example) | PBD-CTL-003 | Deletion verification report across profile store, PSP and lakehouse | Evidence store | [@data-engineer] | YYYY-MM-DD |
| PBD-EVD-004 (Example) | PBD-REQ-001 | Usability test summary, 10 participants | Research repository | [@ux-lead] | YYYY-MM-DD |
| [PBD-EVD-005] | [Item] | [Type] | [Location] | [Producer] | YYYY-MM-DD |
Re-test the evidence that depends on configuration at least once a year and after each change that touches the components in section 1.
14. Lifecycle checkpoints and re-review triggers
| Checkpoint | Sections that must be complete | Gate owner |
|---|---|---|
| Concept | 1, 2, 4.1 draft, 12 first screening | [@product-owner] |
| Design | 4, 5, 6, 7, 9 draft, 11 | [@privacy-engineer] |
| Build | 8, 10, evidence plan in 13 | [@engineering-lead] |
| Pre-launch | All sections, evidence for every requirement, approvals | [@product-owner], [@dpo] advice |
| Live (annual) | 12 re-screening, 13 re-test, 11 vendor check | [@privacy-engineer] |
| Retirement | 10 deletion plan, 11 vendor offboarding | [@product-owner] |
Re-review when any of these occur: a new purpose, a new data category, a new recipient or country, a change of lawful basis, a new channel or user group (especially children), a significant incident involving the data, a change in law or regulator guidance, or a substantial rise in scale.
15. Findings, decisions and actions
| Finding ID | Finding | Decision | Action | Owner | Due | Status |
|---|---|---|---|---|---|---|
| PBD-FND-001 (Example) | Customer service tool shows full address by default | Change default to masked | Implement PBD-DEF-002 | [@cs-tools-lead] | YYYY-MM-DD | Done |
| PBD-FND-002 (Example) | Deletion does not reach the carrier | Accept: the carrier holds the address for 90 days after delivery under its own controllership (DSA-001, section 11) | Confirm the Article 19 notification route in the data sharing agreement | [@vendor-manager] | YYYY-MM-DD | Open |
| [PBD-FND-003] | [Finding] | [Decision] | [Action] | [@owner] | YYYY-MM-DD | [Status] |
| DPO advice | Followed? | If not, reason and approver |
|---|---|---|
| [Advice text, date] | [Yes / Partly / No] | [Reason, @approver] |
16. Traceability matrix
| Principle (GDPR Art. 5) | Requirement | Default or minimisation decision | User control | Evidence |
|---|---|---|---|---|
| Transparency (Example) | PBD-REQ-001 | None | PBD-CTL-001 | PBD-EVD-004 |
| Lawfulness, fairness (Example) | PBD-REQ-002 (consent PBD-CON-002) | PBD-DEF-001 | PBD-CTL-003 | PBD-EVD-001, PBD-EVD-002 |
| Purpose limitation (Example) | PBD-REQ-003 | PBD-DEF-003 | PBD-CTL-004 | [Contract test ref] |
| Data minimisation (Example) | PBD-REQ-004 | PBD-MIN-001, PBD-MIN-004 | None | [Storage scan ref] |
| Storage limitation (Example) | PBD-REQ-006 | PBD-DEF-004 | PBD-CTL-003 | PBD-EVD-003 |
| [Principle] | [Req] | [Decision] | [Control] | [Evidence] |
17. Glossary and references
17.1 Glossary
| Term | Meaning in this document |
|---|---|
| Privacy by design | Building privacy-protective measures into the means of processing from the start and keeping them effective during processing |
| Privacy by default | Configuring processing so that, without any action by the person, only the data needed for each purpose is processed |
| Controller | The organisation that decides the purposes and means of processing |
| Processor | An organisation that processes personal data on behalf of a controller |
| Pseudonymisation | Processing so that data can no longer be attributed to a person without separately held additional information |
| Dark pattern | Interface design that pushes people towards choices they would not otherwise make |
| PET | Privacy-enhancing technology |
| DPIA | Data protection impact assessment under GDPR Article 35 |
17.2 References
| Reference | Version or date | Use |
|---|---|---|
| Regulation (EU) 2016/679 (GDPR), OJ L 119, 4.5.2016 | Check the consolidated text | Articles 5, 6, 7, 13, 15 to 17, 20, 21, 25, 35, 42 |
| EDPB Guidelines 4/2019 on Article 25 Data Protection by Design and by Default | Version 2.0, adopted 20 October 2020 | Principle-by-principle design elements, effectiveness |
| EDPB Recommendations 02/2021 on the legal basis for the storage of credit card data for the sole purpose of facilitating further online transactions | Adopted 19 May 2021 | Consent as the basis for saved payment details (DE-002, PBD-CON-002) |
| Article 29 Working Party guidelines on DPIA, WP248 rev.01 | Revised 4 October 2017, endorsed by the EDPB 25 May 2018 | Section 12 screening criteria |
| ISO 31700-1:2023 Consumer protection: Privacy by design for consumer goods and services, Part 1: High-level requirements | Edition 1, January 2023 | Requirement areas, cited by name only |
| ISO/TR 31700-2:2023 (use cases) | 2023 | Illustrative use cases, by name only |
| ISO/IEC 27701:2025 Privacy information management | 2025 | Management system context, by name only |
| National supervisory authority DPIA list | [Checked YYYY-MM-DD] | Section 12 screening |
Standard and licence note
Based on Article 25 of Regulation (EU) 2016/679 (GDPR) as published in the Official Journal of the European Union and on the EDPB Guidelines 4/2019 on Article 25 Data Protection by Design and by Default (version 2.0, adopted 20 October 2020). Structure aligned with ISO 31700-1:2023, which is cited by name only: no ISO text, requirement wording, definition or table is reproduced, and the requirement areas in this template are described in original words. ISO/TR 31700-2:2023 and ISO/IEC 27701:2025 are named for context only. Articles are cited and summarised in original wording; check the consolidated GDPR text, the current EDPB guidance and the national rules that apply before use. The template text is original. This is a documentation format, not legal advice. Template licence: MIT.
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