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Privacy By Design

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Privacy by Design (PbD) knowledge base for assessing proactive privacy practices against the 7 Foundation Principles, with data retention and disposal lifecycle checks and cross-jurisdictional mappings (GDPR, CCPA, APP).
— the description by Microsoft

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

  1. Download the skill as a ZIP:

    https://autogineer.com/agent-skills/microsoft/privacy-by-design/download

  2. Unzip 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/A when 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-planning or 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_EVIDENCE and 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-planning skill already covers; cross-reference them.

Normative references (PbD 7 Foundation Principles)

  1. 00 Principle Index

  2. 01 Proactive Not Reactive

  3. 02 Privacy as the Default

  4. 03 Privacy Embedded into Design

  5. 04 Full Functionality

  6. 05 End-to-End Security

  7. 06 Visibility and Transparency

  8. 07 Respect for User Privacy

Operational references

Supplementary references

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.

    • 01 through 07 — 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.yml customization 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 Reactive

  • gdpr_article: GDPR article reference, e.g., Art. 25

  • app_principle: Australian Privacy Principle number, e.g., APP 1

  • ccpa_section: CCPA/CPRA section reference

Finding severity conventions

SeverityMeaning
CRITICALEstablished deficiency with severe direct risk, or FAIL under an effective CRITICAL industry priority
HIGHPrinciple is violated with direct risk to data subjects
MEDIUMPrinciple is partially met; gaps exist that could lead to non-compliance
LOWMinor gap; principle intent is largely met but documentation or controls could improve
N/ANo 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

VerdictMeaning
PASSAll applicable checks are MET, with no unresolved evidence or anti-patterns
PARTIALA deficiency is established but the FAIL threshold is not met
FAILMore than half of applicable checks are NOT MET, or an uncompensated critical anti-pattern is established
INSUFFICIENT_EVIDENCENo 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

VerdictCondition
NON_COMPLIANTOne or more principles are FAIL; retain any evidence gaps separately
INCOMPLETENo FAIL, but any principle or applicable retention/jurisdiction check has incomplete evidence
PARTIALLY_COMPLIANTComplete evidence, no FAIL, and at least one PARTIAL
COMPLIANTComplete 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 thresholds

  • privacy-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

SkillRelationship
privacy-standardsProvides data inventory, DPIA thresholds, and standards backbone; PbD builds on top
security-planningSecurity controls overlap with PbD-05; reference rather than duplicate
rai-plannerRAI data-use concerns feed into PbD-04 (full functionality) and PbD-07 (user respect)
secure-by-designSBD-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)
Australian Privacy Principles (APP)
CCPA/CPRA

Files

references/industry-privacy-profiles.md

title: Industry Privacy Profiles description: Industry-specific PbD principle emphasis, regulatory priorities, and assessment focus areas

Industry Privacy Profiles

This reference maps the 7 PbD Foundation Principles to industry-specific contexts, highlighting which principles demand elevated attention, what industry-specific regulatory obligations apply, and which assessment checks should be prioritized per sector.

How to use industry profiles

  1. Identify the system's industry context (from .pbd-config.yml or package analysis).

  2. Load the matching profile to prioritize checks and escalate established deficiencies, not to change evidence counts.

  3. Apply industry-specific checks alongside the universal principle checklist.

  4. Flag industry-mandatory controls that go beyond the universal requirements.

Telecommunications

Principle emphasis
PrincipleIndustry priorityRationale
PbD-01 ProactiveHIGHMetadata retention laws require privacy planning before system design
PbD-02 DefaultCRITICALLocation and communication data must be protected by default (ePrivacy)
PbD-05 End-to-EndCRITICALCDR, location history, and content have mandated retention and disposal
PbD-06 TransparencyHIGHSubscribers must know what metadata is retained and for how long
PbD-07 User-CentricHIGHOpt-in required for location-based services beyond network operation
Industry-specific checks

  • Location data collection defaults to OFF for value-added services (PbD-02)

  • CDR retention period matches regulatory mandate (not indefinite) (PbD-05)

  • Subscriber consent mechanism exists for location-based services (PbD-07)

  • Network metadata anonymized before analytics use (PbD-02)

  • Roaming data sharing governed by transfer agreements (PbD-05)

  • Lawful interception isolated from general access (PbD-03)

  • Device identifiers (IMEI, IMSI) not correlated across services without purpose binding (PbD-03)

Key regulations

  • ePrivacy Directive (EU) — consent for location, confidentiality of communications

  • Telecommunications (Interception and Access) Act 1979 (AU) (Part 5-1A metadata retention, interception warrants); Telecommunications Act 1997 (AU) (Part 13 confidentiality of customer information)

  • CPNI Rules 47 CFR § 64.2001 (US) — customer network information protection

Healthcare

Principle emphasis
PrincipleIndustry priorityRationale
PbD-02 DefaultCRITICALHealth data requires maximum protection by default (HIPAA minimum necessary)
PbD-03 EmbeddedCRITICALPrivacy must be architectural (segmentation, de-identification, break-the-glass)
PbD-04 Full FunctionalityHIGHPatients exercising rights must not lose care quality
PbD-05 End-to-EndCRITICALHealth records have complex retention (clinical vs. research vs. billing)
PbD-07 User-CentricHIGHPatient access rights (21st Century Cures), correction, consent withdrawal
Industry-specific checks

  • Minimum necessary principle applied to all health data disclosures (PbD-02)

  • HIPAA de-identification method applied for research/analytics (Safe Harbor or Expert Determination) (PbD-03)

  • Break-the-glass mechanism exists with mandatory post-access audit (PbD-03)

  • 42 CFR Part 2 segmentation for substance use disorder and mental health records (PbD-03)

  • Patient portal provides electronic access to health records (PbD-07)

  • DICOM de-identification strips patient metadata from medical images (PbD-05)

  • Genetic data handled with GINA non-discrimination controls (PbD-04)

  • Clinical research consent separate from treatment consent (PbD-07)

Key regulations

  • HIPAA Privacy and Security Rules (US) — minimum necessary, patient rights, safeguards

  • 42 CFR Part 2 (US) — substance use disorder record consent requirements

  • My Health Records Act 2012 (AU) — digital health record controls

  • GDPR Art. 9 (EU) — health data as special category

Financial Services

Principle emphasis
PrincipleIndustry priorityRationale
PbD-02 DefaultHIGHDefault data minimization for KYC (collect only what regulation requires)
PbD-03 EmbeddedCRITICALPCI DSS requires privacy embedded in architecture (CDE isolation, tokenization)
PbD-04 Full FunctionalityHIGHCustomers opting out of profiling must retain full service access (PSD2, CCPA §1798.125)
PbD-05 End-to-EndCRITICALFinancial records have regulatory retention minimums AND deletion obligations
PbD-06 TransparencyHIGHAutomated credit decisions require explainability (GDPR Art. 22, FCRA)
Industry-specific checks

  • PCI DSS cardholder data environment (CDE) architecturally isolated (PbD-03)

  • Card data tokenized outside payment processing (PbD-03)

  • CVV never stored (even encrypted) (PbD-02)

  • KYC documents retained only for regulatory minimum, then destroyed (PbD-05)

  • Credit scoring logic transparent to consumers with dispute mechanism (PbD-06)

  • No service degradation for customers who opt out of profiling (PbD-04)

  • AML/CTF monitoring does not create overbroad surveillance beyond regulatory mandate (PbD-02)

  • Transaction data segregated from marketing analytics (PbD-03)

  • Strong customer authentication for payment initiation (PbD-05)

Key regulations

  • PCI DSS v4.0.1 (Global): cardholder data protection architecture

  • PSD2/SCA (EU) — strong customer authentication, open banking consent

  • FCRA (US) — credit reporting accuracy, consumer rights

  • APRA CPS 234 (AU) — information security for regulated entities

  • AML/CTF Act 2006 (AU) — customer identification, transaction monitoring

Profile configuration

Projects can specify their industry profile and override principle priorities in .pbd-config.yml:

# .pbd-config.yml — placed at repository root
version: "1.0"

# Industry profile (loads matching section above)
industry: "telco"  # Options: telco, healthcare, financial

# Override principle priorities for your org
principle_overrides:
  - principle: "PbD-04"
    priority: "CRITICAL"
    justification: "Our telco offers essential services; accessibility during privacy exercise is mandatory"

# Additional industry-specific checks beyond the profile
custom_checks:
  - principle: "PbD-03"
    check: "5G network slice identifiers treated as subscriber PII"
    severity: "HIGH"

  - principle: "PbD-05"
    check: "eSIM profile data destroyed within 30 days of deactivation"
    severity: "MEDIUM"

# Suppress checks that don't apply
suppressions:
  - check: "DICOM de-identification"
    reason: "Not a healthcare system; no medical imaging"

  - check: "PCI DSS CDE isolation"
    reason: "No payment card processing; payments handled by external gateway"

Configuration schema

version

Required. Currently "1.0".

industry

Required. Activates the matching industry profile. Values: telco, healthcare, financial.

principle_overrides

Optional. Override the default priority for a principle within the selected industry.

FieldRequiredDescription
principleYesPbD principle ID (e.g., PbD-04)
priorityYesNew priority: CRITICAL, HIGH, MEDIUM, LOW
justificationYesWhy this override exists
custom_checks

Optional. Add org-specific checks beyond the industry profile.

FieldRequiredDescription
principleYesWhich principle this check maps to
checkYesDescription of the check
severityYesFinding severity if check fails: CRITICAL, HIGH, MEDIUM, LOW
suppressions

Optional. Suppress checks that don't apply to this system.

FieldRequiredDescription
checkYesThe check description or keyword to suppress
reasonYesWhy it doesn't apply

Assessment integration

When an assessment loads this skill, the assessor follows this sequence:

  1. Load .pbd-config.yml if present (or infer industry from codebase).

  2. Resolve effective principle priorities from justified overrides, then the selected profile, then the base severity rules. Priority does not weight checklist counts or create a deficiency.

  3. Add industry-specific checks to the assessment protocol.

  4. Apply custom checks from the configuration.

  5. Match suppressions to specific checks in the effective universal, industry and custom checklist. Record the exact excluded check and applicability reason before scoring. A suppression that matches no active check has no scoring effect; an ambiguous match requires clarification rather than silently excluding multiple controls. Suppress only inapplicable checks, not known deficiencies or mandatory obligations that still apply.

  6. Report findings with industry context (which regulation triggers the requirement).

A principle marked CRITICAL in the industry profile that receives a FAIL verdict produces a CRITICAL-severity finding (elevated from the default tier-based severity).

Apply a custom check's configured severity only when that check establishes a deficiency. Never downgrade a justified severity. PASS and unknown-only results remain N/A regardless of industry priority or data sensitivity. Exclude justified suppressions from applicable counts, list them separately, and do not award PASS when every check is suppressed. See the assessment protocol and finding schema for verdict, completeness and aggregation rules.

Industry profiles are original content (CC BY 4.0) synthesized from sector-specific privacy engineering practices. Regulatory references are paraphrased with attribution for planning use, not legal interpretation.

Source principles: IPC Ontario, Privacy by Design. Verify sector applicability against the relevant regulator's current requirements; a profile priority is an assessment rule, not a legal conclusion.

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

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Attribution and licence

Published by
Microsoft
Publisher
Microsoft (Official)
Source
microsoft/hve-core · .github/skills/project-planning/privacy-by-design · commit f425e94
Licence
Creative Commons Attribution 4.0 International (redistribution allowed)
  • LICENSE (written by AutoGineer)
  • ATTRIBUTION.md (written by AutoGineer)
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