Designing Privacy-by-Design

The proposal for a new privacy regulation d.d. January 25th 2012 introduces sanctions of up to 2% of the annual turnover of enterprises. This elevates the importance of mitigation of privacy risks. This paper makes Privacy by Design more concrete, and positions it as the mechanism to mitigate these privacy risks. In this vision paper, we describe how design patterns may be used to make the principle of Privacy by Design specific for relevant application domains. We identify a number of privacy design patterns as examples and we argue that the art is in finding the right level of abstraction to describe a privacy design pattern: the level where the data holder, data subject and privacy risks are described. We give an extended definition of Privacy by Design and, taking Solove's model for privacy invasions as structuring principle, we describe a tool and method to use that tool to generate trust in systems by citizens.