Privacy by Design means that data protection and data minimisation are not added at the end of a development process, but are an integral part of product, service and business‑process design from the very first idea. It is about planning technical and organisational measures so that personal data are protected from the outset, unnecessary collection is avoided, and potential risks to data subjects are minimised. In practice this means: data protection is not an “add‑on”, but a guiding principle for every decision.

Legal background and relevance for companies from Ukraine

The legal basis is Article 25 of the GDPR, which requires “data protection by design and by default.” This is particularly important for Ukrainian providers because the GDPR can apply to companies that offer services in the EU or monitor the behaviour of persons in the EU. Any company bringing software to Europe—whether a SaaS product, a mobile app or telemetry services—should plan for Privacy by Design from the start in order to reduce regulatory risk and build trust with EU customers.

How to implement Privacy by Design in practice

Privacy by Design is not a single measure but a set of interlinked decisions made throughout the product lifecycle. Already in the concept and requirements phase, privacy requirements should be embedded as mandatory user stories: which data does the feature actually need? What alternatives to identifying a person are available? During architecture planning, data‑flow maps are useful to identify where personal data are created, how they move, and where protection is required. Technical measures typically include pseudonymisation, strong encryption in transit and at rest, strict access controls based on the principle of least privilege, and privacy‑aware logging. During development, privacy and security tests should be integrated into CI/CD pipelines and privacy‑threat modelling should be performed regularly.

Third‑party selection is also important: libraries, cloud providers and subprocessors must be reviewed; data processing agreements (DPAs) and evidence of their security posture should be documented. Ultimately, the GDPR requires accountability—document your design decisions, risk assessments and the technical measures you deploy so you can demonstrate them to supervisory authorities and customers.

Concrete examples for developers and product owners

Instead of requiring full address and profile data by default during user registration, collect only the minimum (for example, email, language, country); additional details should be requested only when clearly necessary and explained. Telemetry data can be pseudonymised before aggregation; detailed user data should only be collected with informed consent. For logging, it is often sufficient to store anonymous session IDs and error categories rather than full user profiles. For data‑heavy features such as personalisation, consider a two‑tier design: core functionality without personal data, and enhanced features available only after an opt‑in.

Documentation and proof

Privacy by Design can only be evidenced if it is documented. Use a record of processing activities in accordance with Article 30 GDPR, put decisions about data minimisation and protective measures into writing, and keep Data Protection Impact Assessments (DPIAs) where processing operations involve high risks. These documents simplify audits, commercial and partner discussions, and interactions with data protection authorities.

Why early integration makes business sense

Fixing design mistakes later is often expensive—both financially and in terms of reputational risk. Privacy by Design reduces the likelihood of data breaches, simplifies compliance checks, and sends a positive signal to European partners and end users: that your organisation takes data protection seriously.

Conclusion: what you should do now

For new projects, start with a privacy requirements analysis, review existing products for data minimisation, perform DPIAs for high‑risk functions, and train developers and product managers in privacy‑oriented design. As an EU representative, we can support you with audits, DPIAs, DPA reviews and communication with supervisory authorities.