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Conducting a privacy impact assessment (PIA) should be done first to establish privacy by design when developing a contact-tracing application. A PIA is a systematic process that identifies and evaluates the potential effects of personal data processing operations on the privacy of individuals and the organization. A PIA helps to identify privacy risks and mitigation strategies at an early stage of development and ensures compliance with legal and regulatory requirements. Conducting a development environment review, identifying privacy controls, or identifying differential privacy techniques are important steps in privacy by design, but they should be done after conducting a PIA. References: CDPSE Exam Content Outline, Domain 2, Task 2.1

The most effective way to incorporate privacy by design principles into applications is to include privacy requirements in software development practices, because this ensures that privacy is considered and integrated from the early stages of the design process and throughout the entire lifecycle of the application. Software development practices include activities such as defining the scope, objectives, and specifications of the application, identifying and analyzing the privacy risks and impacts, selecting and implementing the appropriate privacy-enhancing technologies and controls, testing and validating the privacy functionality and performance, and monitoring and reviewing the privacy compliance and effectiveness of the application. By including privacy requirements in software development practices, the organization can achieve a proactive, preventive, and embedded approach to privacy that aligns with the privacy by design principles.

References:

• CDPSE Review Manual, 2023 Edition, Domain 2: Privacy Architecture, Section 2.1.2: Privacy Requirements, p. 75
• CDPSE Review Manual, 2023 Edition, Domain 2: Privacy Architecture, Section 2.2.1: Privacy by Design Methodology, p. 79-80
• The 7 Principles of Privacy by Design | Blog | OneTrust1

Before using data from the organization’s customer database for a new marketing application, the first step should be to determine what data is required by the application and for what purpose. This will help to ensure that the data collection and processing are relevant, necessary, and proportionate to the intended use, and that the data minimization principle is followed. Data minimization means that only the minimum amount of personal data needed to achieve a specific purpose should be collected and processed, and that any excess or irrelevant data should be deleted or anonymized1. This will also help to comply with the data privacy laws and regulations that apply to the organization, such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), which require organizations to inform data subjects about the types and purposes of data processing, and to obtain their consent if needed23.

References:

• ISACA, Data Privacy Audit/Assurance Program, Control Objective 2: Data Minimization, p. 61
• ISACA, GDPR Data Protection Impact Assessments, p. 4-52
• ISACA, CCPA vs. GDPR: Similarities and Differences, p. 1-23