Privacy By Design
MicrosoftOfficialPublished by Microsoft
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- Security
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AutoGineer summary
Written by AutoGineer from the skill’s own files, not by the author
The Privacy by Design (PbD) skill provides a comprehensive knowledge base and assessment protocol for evaluating software systems against the 7 Foundation Principles established by Dr. Ann Cavoukian. It enables users to conduct proactive privacy reviews, identify deficiencies, and map findings to regulatory requirements including GDPR, CCPA/CPRA, and Australian Privacy Principles. The skill includes structured checklists, implementation patterns, and a finding schema to ensure consistent, evidence-based privacy assessments across the development lifecycle.
What it does
- Assesses system designs against the 7 Foundation Principles of Privacy by Design.
- Provides a structured protocol for conducting privacy impact assessments.
- Maps privacy findings to GDPR, CCPA/CPRA, and Australian Privacy Principles.
- Evaluates data retention, disposal, and lifecycle management practices.
- Identifies privacy-related anti-patterns in architecture and configuration.
- Generates actionable remediation items for identified privacy deficiencies.
When to use it
- During the design phase of a new system or feature involving personal data.
- When performing a proactive privacy audit to identify potential compliance gaps.
- To verify that privacy controls are embedded into the architecture rather than added post-deployment.
- When establishing data retention and disposal schedules for sensitive information.
- To generate structured privacy assessment reports for stakeholders.
Advantages
- Promotes a proactive, preventative approach to privacy rather than reactive compliance.
- Standardizes privacy assessments using a clear, evidence-based schema.
- Facilitates cross-jurisdictional compliance mapping.
- Integrates privacy considerations directly into the software development lifecycle.
- Provides clear, actionable remediation guidance for identified risks.
Usage examples
- “Assess our new user registration flow against the 7 Privacy by Design principles.”
- The agent will walk through each of the 7 principles, checking for proactive design, default privacy settings, and end-to-end security, ultimately providing a compliance verdict and specific remediation steps.
- “Check our data retention policy for compliance with PbD-05.”
- The agent will evaluate the current retention and disposal lifecycle against Principle 05, identifying gaps in data minimization or legal hold procedures and suggesting improvements.
Install
Download the skill as a ZIP:
https://autogineer.com/agent-skills/microsoft/privacy-by-design/downloadUnzip it into the cross-client skills folder of your project:
mkdir -p .agents/skills && unzip privacy-by-design.zip -d .agents/skills
Documentation by Microsoft
Privacy by Design
This SKILL.md is the entrypoint for the Privacy by Design skill.
The skill provides structured assessment references for the 7 Foundation Principles of Privacy by Design (Cavoukian, 2009). Consumers that explicitly load it can assess privacy practices across the software lifecycle. It complements privacy-standards with principle-level criteria, retention and disposal checks, regulatory mappings, a finding schema and implementation patterns. Current agent wiring is described under Integration below.
[!NOTE] This skill is a planning aid, not legal advice. Its standards summaries support privacy reasoning and review preparation; they do not substitute for qualified legal counsel or a formal regulatory interpretation.
Goal
Produce an evidence-based assessment against the 7 PbD Foundation Principles, with per-principle verdicts, explicit evidence gaps, deficiency severity, and remediation for established deficiencies. Assessment labels describe this planning rubric, not legal certification.
Success criteria
All 7 principles have a verdict, evidence completeness, and severity (
N/Awhen no deficiency is established).Each FAIL or PARTIAL finding includes a specific, actionable remediation.
Findings use the structured schema defined in
finding-schema.md.Cross-jurisdictional obligations are identified for the applicable regulatory scope.
Retention and disposal are assessed for any system that stores personal data.
An overall assessment verdict (COMPLIANT / PARTIALLY_COMPLIANT / NON_COMPLIANT / INCOMPLETE) is determined without treating missing evidence as a failed control.
Finding, principle, checklist and severity counts reconcile under the finding schema.
When to use this skill
Use when you need to:
Assess a system, feature, or data flow against the 7 PbD Foundation Principles
Verify that privacy is embedded proactively (not bolted on after incidents)
Check data retention schedules, disposal methods, and legal hold procedures
Map privacy requirements across GDPR Art. 25, CCPA/CPRA, and Australian Privacy Principles
Generate per-principle PASS/PARTIAL/FAIL/INSUFFICIENT_EVIDENCE results with evidence-backed severity
Identify code-level and configuration-level privacy patterns or anti-patterns
Produce backlog items from privacy assessment findings
Do not use for:
General privacy standards mapping without principle assessment (use
privacy-standards)Security threat modeling (use
security-planningor OWASP skills)RAI assessment (use
rai-planner)Legal advice or regulatory compliance certification
Stop rules
Stop the assessment if the system boundary cannot be established.
Stop and escalate if processing occurs in a jurisdiction not covered by this skill's mappings.
Do not fabricate evidence; record
INSUFFICIENT_EVIDENCEand the evidence needed. Continue supported checks without inventing deficiency remediation for unknowns.Do not provide legal opinions; frame all findings as planning guidance requiring qualified review.
Do not duplicate security findings that the
security-planningskill already covers; cross-reference them.
Normative references (PbD 7 Foundation Principles)
Operational references
Assessment Protocol — step-by-step protocol for conducting a PbD assessment
Finding Schema — structured output format for findings and backlog handoff
Implementation Patterns — pragmatic code-level and architecture-level verification patterns
Supplementary references
Data Retention and Disposal — Principle 05 deep-dive: retention schedules, disposal methods, legal holds
Cross-Jurisdictional Mapping — regulatory equivalence matrix across GDPR, CCPA/CPRA, and APP
Industry Privacy Profiles — sector-specific principle priorities, checks, and
.pbd-config.ymlcustomization
Skill layout
SKILL.md— this file (skill entrypoint).references/— the PbD normative documents, operational guides, and supplementary material.00-principle-index.md— index of all principle identifiers, categories, source mappings, and cross-references.01through07— one document per PbD Foundation Principle with checklist, controls, anti-patterns, and regulatory mappings.assessment-protocol.md— phased assessment protocol for agents conducting PbD reviews.finding-schema.md— YAML-based finding and summary schema for structured output.implementation-patterns.md— code-level and configuration-level patterns agents can verify.data-retention-and-disposal.md— Principle 05 deep-dive: retention schedules, disposal methods, legal holds.cross-jurisdictional-mapping.md— regulatory equivalence matrix across GDPR, CCPA/CPRA, and APP.industry-privacy-profiles.md— telco, healthcare, financial sector profiles with.pbd-config.ymlcustomization schema.
Citation-field vocabulary
Use these fields when capturing a finding so the reviewer can assert a stable source-control reference:
pbd_principle: Principle number (1–7) with short name, e.g.,PbD-01 Proactive Not Reactivegdpr_article: GDPR article reference, e.g.,Art. 25app_principle: Australian Privacy Principle number, e.g.,APP 1ccpa_section: CCPA/CPRA section reference
Finding severity conventions
| Severity | Meaning |
|---|---|
| CRITICAL | Established deficiency with severe direct risk, or FAIL under an effective CRITICAL industry priority |
| HIGH | Principle is violated with direct risk to data subjects |
| MEDIUM | Principle is partially met; gaps exist that could lead to non-compliance |
| LOW | Minor gap; principle intent is largely met but documentation or controls could improve |
| N/A | No deficiency established, including PASS and unknown-only results |
Data sensitivity informs the impact of a proven deficiency; it does not create one. Preserve CRITICAL in records and summaries. CRITICAL and HIGH map to P1, with CRITICAL ordered first; MEDIUM maps to P2 and LOW to P3. PASS and unknown-only results do not create remediation backlog items.
Finding verdict conventions
| Verdict | Meaning |
|---|---|
| PASS | All applicable checks are MET, with no unresolved evidence or anti-patterns |
| PARTIAL | A deficiency is established but the FAIL threshold is not met |
| FAIL | More than half of applicable checks are NOT MET, or an uncompensated critical anti-pattern is established |
| INSUFFICIENT_EVIDENCE | No deficiency established, but unknown evidence or zero applicable checks prevents PASS |
Apply the ordered rules in the assessment protocol. Record evidence completeness independently so a proven deficiency is not hidden by unknown checks. Suppressions require a documented applicability reason and do not count as MET.
Overall assessment verdicts
| Verdict | Condition |
|---|---|
| NON_COMPLIANT | One or more principles are FAIL; retain any evidence gaps separately |
| INCOMPLETE | No FAIL, but any principle or applicable retention/jurisdiction check has incomplete evidence |
| PARTIALLY_COMPLIANT | Complete evidence, no FAIL, and at least one PARTIAL |
| COMPLIANT | Complete evidence and all 7 principles PASS |
Evaluate these rows in order. Never use null for a verdict or interpret an unknown jurisdictional baseline as met or failed.
Integration with Privacy Planner and Reviewer
This skill complements privacy-standards (which provides the NIST PF, GDPR, CCPA, OWASP backbone). A consumer performing PbD assessment should explicitly load both:
privacy-standards— standards mapping, data-flow reasoning, DPIA thresholdsprivacy-by-design— principle-level assessment, retention/disposal checks, cross-jurisdictional equivalence, implementation pattern verification
The current Privacy Planner and Privacy Reviewer do not explicitly load privacy-by-design. This skill supplies assessment knowledge, not automatic integration; dedicated agent wiring is outside this skill change. It remains background-only (user-invocable: false).
Interaction with other skills
| Skill | Relationship |
|---|---|
privacy-standards | Provides data inventory, DPIA thresholds, and standards backbone; PbD builds on top |
security-planning | Security controls overlap with PbD-05; reference rather than duplicate |
rai-planner | RAI data-use concerns feed into PbD-04 (full functionality) and PbD-07 (user respect) |
secure-by-design | SBD-11 (Secure Deprecation) aligns with PbD-05 lifecycle; cross-reference for decommissioning |
Attribution and licensing posture
SKILL.md and references/ contain original assessment guidance and paraphrased summaries under CC BY 4.0. The cited publications remain authoritative and retain their own rights; this license does not relicense upstream text. Principle names and legal identifiers are preserved for traceability. No upstream document is reproduced or bundled.
Cavoukian PbD Foundation Principles
Author: Dr. Ann Cavoukian, Information and Privacy Commissioner of Ontario
Source: https://www.ipc.on.ca/sites/default/files/legacy/2018/01/pbd.pdf
Modifications: Principles restructured into agent-consumable assessment checklists with cross-references to GDPR, CCPA, and APP; original principle text paraphrased with attribution
Note: The 7 Foundation Principles are widely referenced in academic and regulatory literature; content here is paraphrased for planning use
GDPR Art. 25 (Data Protection by Design and by Default)
Modifications: Mapped to PbD principles as regulatory equivalence; paraphrased with attribution
Australian Privacy Principles (APP)
Source: https://www.oaic.gov.au/privacy/australian-privacy-principles
Copyright: © Commonwealth of Australia
Modifications: Mapped to PbD principles as cross-jurisdictional equivalence; paraphrased with attribution
CCPA/CPRA
Source: https://oag.ca.gov/privacy/ccpa
Modifications: Mapped to PbD principles as cross-jurisdictional equivalence; paraphrased with attribution
Files
- ATTRIBUTION.mdAdded by AutoGineer977 B
- LICENSEAdded by AutoGineer16.6 KiB
- SKILL.md12.9 KiB
- references/00-principle-index.md4.0 KiB
- references/01-proactive-not-reactive.md4.4 KiB
- references/02-privacy-as-the-default.md4.5 KiB
- references/03-privacy-embedded-into-design.md4.7 KiB
- references/04-full-functionality.md4.4 KiB
- references/05-end-to-end-security.md5.8 KiB
- references/06-visibility-and-transparency.md5.6 KiB
- references/07-respect-for-user-privacy.md5.5 KiB
- references/assessment-protocol.md9.7 KiB
- references/cross-jurisdictional-mapping.md13.3 KiB
- references/data-retention-and-disposal.md7.1 KiB
- references/finding-schema.md10.8 KiB
- references/implementation-patterns.md10.1 KiB
- references/industry-privacy-profiles.md11.3 KiB
LICENSE
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Requirements and compatibility
Written for: GitHub Copilot, Claude Code
Works with: Claude Code, Claude apps, OpenAI Codex, GitHub Copilot, Cursor, Gemini CLI, Kiro, OpenCode, Goose, Amp, Roo Code, JetBrains Junie, Factory Droid, Devin (ex-Windsurf), Mistral Vibe, OpenHands, Letta
“Works with” means the tool reads the open Agent Skills format; a skill written for one tool may use features others lack.
Needs: Claude Code frontmatter
Security
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Attribution and licence
- Published by
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- Microsoft (Official)
- Source
- microsoft/hve-core · .github/skills/project-planning/privacy-by-design · commit f425e94
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- LICENSE (written by AutoGineer)
- ATTRIBUTION.md (written by AutoGineer)
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