6.4.3. Privacy Considerations

💡 First Principle: Privacy is the right of individuals to control how their personal information is collected, used, stored, and shared. Privacy overlaps with security but isn't identical — security protects data from unauthorized access; privacy ensures data is handled according to the data subject's rights and applicable laws.

Data types requiring privacy protection:

• Personally Identifiable Information (PII) — any data that identifies an individual
• Protected Health Information (PHI) — PII combined with health data
• Financial data — account numbers, transaction records
• Biometric data — fingerprints, facial geometry, iris patterns

Legal basis for processing — under GDPR, organizations must have a legal basis for processing personal data: consent, contract necessity, legal obligation, vital interests, public interest, or legitimate interests.

Purpose limitation — data collected for one purpose shouldn't be used for another without additional consent.

Data minimization — collect only the data you actually need. Don't collect birthdates "just in case" if your application doesn't require them.

Right to be forgotten (data erasure) — under GDPR, individuals can request deletion of their personal data when it's no longer necessary for its original purpose.

Data Protection Officer (DPO) — some regulations require appointing a DPO responsible for overseeing data protection strategy and compliance.

Data inventory and retention — knowing what personal data you hold, where it's stored, who accesses it, and when it should be deleted. Retention policies ensure data isn't kept longer than necessary.

Privacy Impact Assessment (PIA) — a formal evaluation conducted before launching new systems or processes that handle personal data. The PIA identifies what data is collected, how it flows through the system, what privacy risks exist, and what controls mitigate those risks. Many regulations require PIAs for high-risk processing activities. A PIA should answer: what data do we collect, why do we need it, who accesses it, how long do we keep it, and how do we protect it?

⚠️ Exam Trap: Data minimization means collecting ONLY what you need. If a question describes an application collecting excessive personal data "for future use," data minimization is the privacy principle being violated.