Towards a Principled Approach for Engineering Privacy by Design

Privacy by Design has emerged as a proactive approach for embedding privacy into the early stages of the design of information and communication technologies, but it is no 'silver bullet'. Challenges involved in engineering Privacy by Design include a lack of holistic and systematic methodologies that address the complexity and variability of privacy issues and support the translation of its principles into engineering activities. A consequence is that its principles are given at a high level of abstraction without accompanying tools and guidelines to address these challenges. We analyse three privacy requirements engineering methods from which we derive a set of criteria that aid in identifying data-processing activities that may lead to privacy violations and harms and also aid in specifying appropriate design decisions. We also present principles for engineering Privacy by Design that can be developed upon these criteria. Based on these, we outline some preliminary thoughts on the form of a principled framework that addresses the plurality and contextuality of privacy issues and supports the translation of the principles of Privacy by Design into engineering activities.