Privacy Check Skill
Privacy by Design assessment.
Workflow
7 Foundational Principles (Cavoukian)
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Proactive not Reactive: Are privacy measures built in from the start?
- Privacy considered in design phase, not bolted on
- Risks identified before implementation
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Privacy as Default: Is the most private option the default?
- Data collection opt-in, not opt-out
- Minimum data collected by default
- Sharing disabled by default
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Privacy Embedded in Design: Is privacy integral to the system?
- Privacy controls are core features, not add-ons
- Architecture supports data minimization
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Positive-Sum, not Zero-Sum (originally "Full Functionality"): Privacy without trade-offs?
- Privacy features don't degrade user experience
- Not a false choice between privacy and functionality
- Avoid false dichotomies: privacy vs. security, privacy vs. business value
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End-to-End Security: Data protected throughout its lifecycle?
- Encryption at rest and in transit
- Secure deletion when no longer needed
- Access controls throughout the data lifecycle
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Visibility and Transparency: Is data processing transparent?
- Users know what data is collected and why
- Processing purposes documented and communicated
- Third-party sharing disclosed
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Respect for User Privacy: Are user interests centered?
- Users can access their data
- Users can correct their data
- Users can delete their data
- Consent is informed, specific, and revocable
Data Protection Assessment
- What data is collected? List all personal data fields.
- Why? Lawful basis for each data element.
- How long? Retention period for each data type.
- Who accesses it? List all parties with access.
- Where is it stored? Data residency and cross-border transfers.
- How is it protected? Encryption, access control, monitoring.
- What if breached? Incident response plan exists?
Output
## Privacy Assessment: [Feature/System]
### PbD Principles
| Principle | Status | Notes |
|-----------|--------|-------|
| Proactive | Pass/Fail | ... |
| Default privacy | Pass/Fail | ... |
| Embedded | Pass/Fail | ... |
| Full functionality | Pass/Fail | ... |
| End-to-end security | Pass/Fail | ... |
| Transparency | Pass/Fail | ... |
| User respect | Pass/Fail | ... |
### Data Inventory
| Data | Purpose | Basis | Retention | Protection |
|------|---------|-------|-----------|-----------|
| ... | ... | ... | ... | ... |
### Risks and Recommendations
1. [risk and recommended action]
Decision Log (MANDATORY per G-P4)
APPEND a ### Privacy Assessment entry to .claude/harness/decision-log.md with: principles assessed, data flows identified, risks found, GDPR compliance status.
Theory Citations
- Cavoukian: Privacy by Design (7 principles)
- GDPR: Data protection regulation