Compliance privacy

Compliance & Privacy Engineering

Turn regulatory obligations into engineering requirements — before an auditor, a regulator, or a deletion request does it for you. This skill covers the engineering of compliance (what to build and how); it is not legal advice, and material decisions (lawful basis, DPAs, breach notification) need counsel — flag them explicitly rather than silently deciding. Boundary with its siblings: security-audit finds technical vulnerabilities, threat-modeling analyzes attacker paths in a design; this skill handles what regulations oblige you to do with data regardless of attackers.

Workflow

Step 1: Map the Data — You Can't Comply with What You Can't Find

Build the data inventory first; every obligation hangs off it:

• What personal data exists — direct identifiers (name, email, phone), indirect (IP, device IDs, location), sensitive categories (health, biometrics, children's data — these carry stricter rules).
• Where it lives — every store, including the ones people forget: logs, analytics, backups, data warehouses, third-party processors, caches, error trackers.
• Where it flows — which services touch it, which vendors receive it (each is a processor needing a DPA), and whether it crosses borders.

Grep the codebase and schemas for it; the inventory that only reflects the architecture diagram misses the PII in logs and analytics events.

Step 2: Determine What Applies

Which regimes govern you follows from the data and the users, not the company's location: EU/UK users → GDPR/UK-GDPR; California residents → CCPA/CPRA; health data in the US → HIPAA; card data → PCI-DSS; enterprise customers asking for audits → SOC 2. Verify specifics against current official sources — regulations and thresholds change; don't answer from memory. Then extract the engineering obligations (see references/obligations-map.md for the regulation → engineering-requirement mapping).

Step 3: Design for Minimization and Purpose

The cheapest data to protect is data you don't have:

• Collect less: challenge every field — what breaks if we don't collect it?
• Retain less: every data class gets a retention period and an automated deletion path; "keep forever by default" is a finding, not a policy.
• Expose less: pseudonymize/tokenize where full identity isn't needed (analytics, testing — see test-data-strategy for GDPR-safe test data); scope access per purpose.
• Log less: PII in logs inherits none of your database's controls and all of its obligations — scrub at the logging layer, not in post-processing.

Step 4: Build the Rights Machinery

Data-subject rights are engineering features with deadlines (typically ~30 days), not support tickets to improvise:

• Access/export: produce all of a person's data across every Step-1 store.
• Deletion: erase or anonymize across primary stores, caches, search indexes, analytics, and a documented stance on backups (usually: excluded from immediate erasure, purged on backup expiry — state it in the policy). Deletion that misses a store the inventory forgot is the classic failure.
• Consent: record what was consented to, when, and which version; make withdrawal as easy as granting; gate the relevant processing on it.

Test the deletion path like a feature — run it against a seeded user and verify every store — because the first real request is a terrible time to discover it doesn't work.

Step 5: Implement the Control Layer (SOC 2 lens)

The controls auditors verify are mostly good engineering hygiene made demonstrable: least-privilege access with a review cadence, change management (PRs + reviews + CI — which you likely have; the gap is usually evidence), append-only audit logging of sensitive-data access and admin actions (overlaps threat-modeling's repudiation counters), encryption in transit and at rest, offboarding that provably revokes access, and vendor review for every processor in the Step-1 flow map. Wire evidence collection into the systems themselves — screenshots gathered the week before an audit don't scale.

Step 6: Make It Continuous

Compliance decays with every feature that adds a data flow. Add a lightweight privacy check to the definition of done for features touching personal data (new data collected? new vendor? retention set? deletion path covers it?), keep the data inventory in version control next to the code, and re-run the Step-1 mapping when architecture changes — same living-document discipline as a threat model.

Principles Applied

• Minimization is the master control: every other obligation scales with how much data you hold.
• Rights are features: access, deletion, and consent need designs, tests, and deadlines — not runbooks of manual SQL.
• Evidence or it didn't happen: an undocumented control fails the audit even when it works.

Cross-Skill References

• security-audit — technical vulnerability review (confidentiality controls overlap)
• threat-modeling — design-time attack analysis; shares the data-classification step
• data-modeling — schema-level retention, soft-delete vs erasure, PII isolation
• test-data-strategy — GDPR-safe test data, anonymization
• configuration-strategy — secrets and access to production data
• observability-design — keeping PII out of logs, traces, and metrics