Privacy Engineering: GDPR, Swiss nDSG & Privacy by Design

Privacy engineering turns data protection principles into concrete design decisions: which data a feature collects, at what precision, for how long, who can access it and how users are informed. It complements security, which protects data from attackers, by also asking whether the data should exist and be used that way at all.

Both protect natural persons and share most principles. The GDPR requires one of six legal bases for each processing activity, while under the nDSG private processing is generally permitted if the principles are respected, with a justification where personality is unlawfully infringed. Breach notification thresholds and enforcement also differ. Check details with counsel.

No. A plain hash of an email address can be recomputed by anyone who has a list of candidate addresses, and the organisation can usually link it back. Hashed or keyed-hash identifiers are pseudonymised data and remain personal data under both the GDPR and the nDSG.

It means the default settings process only the personal data necessary for the purpose. Optional features such as being visible to other users start switched off, retention periods start short, and users can choose to share more, but the system does not choose it for them.

Stop logging whole requests and user objects, and add a redaction filter at the source so email addresses, IP host parts and tokens are removed before a line is written. In Python, merge the arguments with getMessage() before redacting, and set retention on every log tier.

Under the GDPR, the controller notifies the supervisory authority without undue delay and, where feasible, within 72 hours, unless the breach is unlikely to result in a risk. Under the Swiss nDSG, the FDPIC is notified as soon as possible when a breach is likely to result in a high risk.