2. Privacy should be the default setting. “If an individual does nothing, their privacy still remains intact. No action is required” on the part of the individual to protect their privacy. It is built into the system, by default. Ditto with Security by Design: consumers should not have to worry about the security of their data when they make a transaction.
3. Privacy should be embedded into the design and architecture of IT systems and business practices, “not bolted on as an add-on.” Security must be part of the design process, as well.
4. A positive-sum, not zero-sum avoids “false dichotomies, such as privacy vs. security, demonstrating that it is possible to have both.”
5. End-to-end security is “embedded into the system prior to the first element of information being collected, and extends throughout the entire lifecycle of the data involved, from start to finish. This ensures that at the end of the process, all data are securely destroyed, in a timely fashion.” This point would remain virtually unchanged from Cavoukian’s original.
6. Visibility/invisibility and transparency/opacity: The Privacy by Design model says that companies need to tell consumers exactly what they are going to do with the information they collect. While this works for Privacy by Design, it would put a giant target, if you’ll excuse the pun, on a company that touts its security. There’s no greater magnet for a hacker than a good challenge. Security by Design requires invisibility and opacity.
7. Respect for the consumer: As with Privacy by Design, Security by Design “requires architects and operators to keep the interests of the individual uppermost by offering such measures as strong privacy defaults, appropriate notice and empowering user-friendly options.”
Security by Design is an ethos that, implemented correctly, would be directly tied to a company’s success or failure. Unfortunately, even with such an ethos in place, every company, both large and small, still must be prepared for the worst. Because when that one employee inevitably clicks on the wrong link, or that one hacker inevitably finds the slightest crack or crevasse to crawl through and the third certainty in life – a breach – becomes a reality, only companies that have comprehensive damage control plans in place will emerge somewhat battered and bruised, but not down for the count.
It’s my hope that when Target announced the hire of Bob DeRodes, the company ushered in the Security by Design movement. With more than 800 million people suffering breached records last year, it’s way past due.
Adam Levin is chairman and co-founder of Credit.com and Identity Theft 911. His experience as former director of the New Jersey Division of Consumer Affairs gives him unique insight into consumer privacy, legislation and financial advocacy. He is a nationally recognized expert on identity theft and credit.