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Data Protection & Privacy Engineering

While the European Union General Data Protection Regulation (EU GDPR) continues to make headlines for its requirements and the looming California Consumer Protection Act (CCPA) approaches, there are many other reasons to have program-level documentation to demonstrate how cybersecurity and privacy principles are designed and implemented by default. It goes beyond compliance and is just good business practice.

Key Takeaways - Data Protection, Privacy & Secure Engineering
  • Data privacy is now a multi-jurisdiction compliance problem: GDPR in the EU, CCPA/CPRA in California, and dozens of state-level privacy laws across the US create complex documentation requirements.
  • Two focused products: Data Privacy Program (DPP) for privacy programs, Secure Engineering & Data Privacy (SEDP) for engineering integration.
  • The DPP addresses the GDPR, CCPA, HIPAA, FERPA, and state-level privacy laws in a unified documentation set.
  • The SbD/PbD addresses engineering-side controls: embedding security and privacy requirements into the SDLC from the earliest design stages.
  • Both products pair well with the CDPP/SCRP for organizations building comprehensive privacy and engineering programs.
Category Overview

Privacy & Secure Engineering Documentation

When you "peel back the onion" and prepare for an audit, there is a need to address "the how" for certain topics, such as how Security by Design (SbD) and Privacy by Design (PbD) principles are managed. While policies and standards are designed to describe WHY something is required and WHAT needs to be done, many companies fail to create documentation to address HOW the policies and standards are actually implemented. We did the heavy lifting and created a program-level document to address this need and the Secure Engineering & Data Privacy (SEDP) is that solution.

Privacy program documentation addresses the organization's handling of personal data across its lifecycle, from collection through retention and disposal. With GDPR, CCPA/CPRA, state-level laws, and sector-specific regulations like HIPAA and FERPA, a robust privacy program is now table-stakes for most organizations.

Secure engineering documentation addresses the other side of the coin: how security and privacy requirements are embedded into the software development lifecycle, product design, and architecture decisions. This is the "shift-left" discipline of ensuring that products and systems are designed with security and privacy as first-class requirements.

Flower ComplianceForge Privacy Secure Engineering
The Easy Path

Managing Data Privacy & Cybersecurity Principles Does Not Have To Be Hard

If you can use Microsoft Word and Excel, then you can perform both Security by Design (SbD) and Privacy by Design (PbD) by simply following the instructions and editing the template to suit your specific requirements. While this is a template, we did the hard work of creating the formatting, bringing together the correct scope of information that needs to be addressed!

 Operationalize Security by Design (O-SbD)  

Data Privacy Security By Design FedRAMP OWASP HIPAA DFARS FAR NIST CSA PCI ISACA ISO

Security by Design (SbD) requirements come from numerous sources. In this context, the most important are:

  • International Organization for Standardization (ISO)
  • National Institute for Standards & Technology (NIST)
  • US Government (HIPAA & FedRAMP)
  • Information Systems Audit and Control Association (ISACA)
  • Cloud Security Alliance (CSA)
  • Center for Internet Security (CIS)
  • Open Web Application Security Project (OWASP)

 Operationalize Security by Design (O-SbD)  

Data Privacy By Design OASIS FIPP HIPAA FTC NIST ISO ISACA GDPR

Privacy by Design (PbD) requirements come from numerous sources. In this context, the most important are:

  • Fair Information Practice Principles (FIPPs)
  • European Union (EU) General Data Protection Regulation (GDPR)
  • Organization for the Advancement of Structured Information Standards (OASIS)
  • International Organization for Standardization (ISO)
  • National Institute for Standards & Technology (NIST)
  • Information Systems Audit and Control Association (ISACA)
  • US Government (HIPAA & FTC Act)
Available Products

Available Privacy & Secure Engineering Products

Two focused products. Purchase individually or combine for comprehensive privacy-and-engineering documentation coverage.

$ 3,300.00 USD
Data Privacy Program (DPP)
The Data Privacy Program (DPP) is an editable "privacy program template" that exists to ensure data protection-related controls are adequately identified and implemented across your systems, applications, services, processes and other initiatives, including third-party service providers. The DPP prescribes a comprehensive framework for the collection, creation, use, dissemination, maintenance, retention, and/or disclosure of Personal Data / sensitive Personal Data (PD / sPD).
Contains:
Word
Excel
PowerPoint
PDF
Examples:
Word Example
Excel Example
$ 4,235.00 USD
Secure Engineering & Data Privacy (SEDP) Program
The SEDP Program is designed to support your company’s existing policies and standards. It serves as expert-level guidance that is meant to run a specific capability or function within an organization's cybersecurity department to help communicate user needs and system characteristics to developers, integrators, sponsors, funding decision makers and other stakeholders.
Contains:
Word
Excel
PowerPoint
PDF
Examples:
Word Example
Excel Example
$ 4,235.00 USD
Information Assurance Program (IAP)
The IAP is focused on pre-production testing and based on established processes used by the US Government (e.g., FISMA, DIACAP, DIARMF) to validate the existence and functionality of controls, prior to a system, application or service going into production. It is not only the right thing to do from a security and privacy perspective, but it is serious job security.
Contains:
Word
Excel
PowerPoint
PDF
Examples:
Word Example
Excel Example
Contact Us

Comprehensive Coverage

Give us a call or send us an email - we are happy to help you find the right solution for your needs!

There are a lot of choices to pick from when selecting a cybersecurity framework. If you are not sure what works best for you, you can read more here. The most common frameworks are NIST 800-53, ISO 27002, the NIST Cybersecurity Framework and the Secure Controls Framework (SCF). To do NIST CSF, ISO 27002 or NIST SP 800-53 properly, it takes more than just a set of policies and standards. While those are foundational to building a cybersecurity program aligned with that framework, there is a need for program-specific guidance that helps operationalize those policies and standards (e.g., risk management program, third-party management, vulnerability management, etc.). It is important to understand what is required to comply with NIST CSF vs ISO 27002 vs NIST SP 800-53, since there are significantly different levels of expectation.

It is important to understand that picking a cybersecurity framework is more of a business decision and less of a technical decision. Realistically, the process of selecting a cybersecurity framework must be driven by a fundamental understanding of what your organization needs to comply with from a statutory, regulatory and contractual perspective, since that understanding establishes the minimum set of requirements necessary to:

  • Not be considered negligent with reasonable expectations for cybersecurity & data protection;
  • Comply with applicable laws, regulations and contractual obligations; and
  • Implement the proper controls to secure your systems, applications and processes from reasonable threats, based on your specific business case and industry practices.

This understanding makes it easy to determine where on the "framework spectrum" (shown above) you need to focus for selecting a set of cybersecurity principles to follow. This process generally leads to selecting the NIST Cybersecurity Framework, ISO 27002, NIST SP 800-53 or SCF as a starting point.

Common Questions

Frequently-Asked Questions

Here are answers to common questions about privacy and secure engineering documentation:

Is privacy by design a legal requirement?
Under the EU GDPR, yes. Article 25 requires controllers to implement appropriate technical and organizational measures for data protection by design and by default, including processing by default only the personal data necessary for each specific purpose. Outside the EU, requirements vary by law, so organizations should confirm what each applicable privacy law expects. Documenting how privacy is built into systems gives evidence that the obligation is being met.
How do you implement privacy by design in software development?
Implement privacy by design by defining privacy requirements at the start of a project and carrying them through each phase of the development lifecycle. That includes data minimization, limiting purposes, privacy-protective defaults, privacy risk reviews during design, and testing controls before release. The ComplianceForge Secure Engineering & Data Privacy (SEDP) Program documents this shift-left approach, and we drew on sources such as the Fair Information Practice Principles, EU GDPR, ISO, NIST and OWASP to build it.
What is the difference between a privacy program and a privacy policy?
A privacy program is the internal governance structure that defines how personal data is collected, used, retained, shared and disposed of, who is responsible, and how compliance is measured. A privacy policy or notice is the external statement telling individuals how their data is handled. The program is what makes the public notice true. For the program side, the ComplianceForge Data Privacy Program (DPP) addresses how personal data is created, used, disseminated, maintained, retained and disclosed.
How does NIST define privacy engineering?
NIST describes privacy engineering as a specialty discipline of systems engineering focused on achieving freedom from conditions that can create problems for individuals with unacceptable consequences as a system processes personally identifiable information (PII). NIST IR 8062 sets out three privacy engineering objectives: predictability, manageability and disassociability. In practice, privacy engineering turns principles such as data minimization, which the EU GDPR names in its data protection by design requirement, into design requirements that developers can build and test.
Why test security controls before a system goes into production?
Pre-production testing confirms that required security and privacy controls exist and work before a system, application or service is exposed to real users and data. Finding a missing or misconfigured control during testing keeps that weakness away from production information. Testing results should be documented so they serve as evidence for system owners and auditors, and so any accepted gaps are tracked to remediation instead of being forgotten after go-live.