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Durham University

Information Governance

Data Protection by Design and Default

Data protection by design aims to define and evaluate risks to the personal data to be processed, and to determine and implement appropriate controls to reduce those risks to an appropriate level; Data protection by default aims to ensure that data protection is a natural consideration embodied within the process, not bolted-on as an afterthought.

The GDPR requires that the data controller (and/or data processor) implements appropriate technical and organisational measures that are designed to implement data protection principles in an effective manner. This balances the risks posed by the processing with the cost of implementation of measures and what is possible.

In support of this the University has developed a Data Protection Impact Assessment template to capture key information about the personal data being processed, the risks to that data and the controls to address them. Whilst this is intended to completed as a first step for a new solution or data processing activity, it could be used to understand and document risks to an existing activity. It may be more costly and difficult to implement controls in this way than with a new activity, but the benefits should outweigh the impact of a personal data breach or loss.

It is essential when considering activities processing personal data that the end-to-end processing is considered and that all relevant supply chain activities are included.

The ICO has not yet developed any specific guidance on this subject and will publish something in the future, but does have existing guidance on privacy by design.

Personal Data in Training and IT Development

Using personal data in training materials (e.g. user manuals, Powerpoint presentations) may present a breach of data protection legislation. Employees must ensure that any data used in training materials is fictional data created for the purpose. If this is not practical for any reason please consult the Information Governance Unit for advice prior to developing materials.

Wherever possible, the same precautions should be taken when using IT system development and test environments for both in-house and third party solutions.

In addition, care should be taken when considering reproducing any data that could be commercially sensitive, e.g. financial information.