• The most direct way for an organization to demonstrate their commitment to privacy is to develop a full-scale privacy program.
• However, going from zero to hero just isn’t realistic for smaller organizations who need a more incremental approach to privacy and data protection, but one that still shows they take these issues seriously.

Our Advice

Critical Insight

1. Data protection by design (DPbD) can be the foundation of a full privacy program.
   • It’ll be a light implementation, but the controls you use for data protection will serve later as building blocks for something larger and more formally laid out.
2. Privacy by design (PbD) and DPbD are not how-to guides.
   • Rather, they provide a functional way of understanding abstract principles, so exactly what each principle pair means will vary by organization and industry.

Impact and Result

• While a full-scale privacy program is nice to have, it is not absolutely necessary to demonstrate commitment to privacy and data protection.
• By planning for data protection by design in your IT systems, you will be able to determine what controls are necessary and then account for privacy protection at every step of the data lifecycle.
• By following this approach, you will also be laying the foundation for a complete privacy program to develop, but with the advantage of knowing that your program is tactically addressing the privacy constraints your organization faces.