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Privacy by Design Framework

The organization shall establish a privacy by design framework that defines the structures, processes, and practices for embedding privacy protections into systems, products, and services from the earliest stages of development. The framework shall articulate how privacy requirements are identified, how privacy controls are integrated, and how privacy by design is governed.

Requirement ID
DAT-011-R001
Parent Control
DAT-011
Domain Code
DAT

Requirement Details & Guidance

DAT-011-R001 · DAT-011
Why This Requirement Exists

To establish a consistent, accountable foundation for privacy by design, ensuring activities are governed, documented, risk-aligned, and performed consistently.

Implementation Guidance

Define scope, objectives, roles, governance, processes, approval authority, review cadence, and supporting documentation for the privacy by design. Align it with enterprise risk, data governance, security, and applicable privacy obligations.

Practical Application & Audit Readiness

DAT-011-R001 · Field Guidance

Business Examples

    Common Audit Findings

      Common Mistakes

        Best Practices & Ownership

        DAT-011 · Recommended Approach

        Recommended Practices

          Typical Owner

          Cross-Mapped Regulatory Frameworks

          Harmonized Control Mappings
          FRAMEWORK CODE FRAMEWORK NAME & DETAILS FAMILY / CATEGORY VERSION ACTION
          IRDAI IRDAI Information & Cyber Security Guidelines IRDAI information and cyber-security requirements... Clause: §2.1-3.5 – Data Privacy
          India
          Guideline
          		 vLatest View →
          SEBI-CSCRF SEBI Cyber Security & Cyber Resilience Framework SEBI’s Cybersecurity and Cyber Resilience Framewor... Clause: 1.1 GV.OC: Organizational Context; 3.3 PR.DS: Data Security
          India
          Regulation
          		 vLatest View →
          DORA Digital Operational Resilience Act The EU Digital Operational Resilience Act establis... Clause: Article 9(2) – ICT security policies, procedures, protocols and tools for resilience and data security Article 9(3) – ICT solutions/processes for secure data transfer and prevention of loss, unauthorised access and data compromise Article 12(1)(a) – Backup policies/procedures based on data criticality or confidentiality
          EU
          Regulation
          		 vCurrent View →
          ISO27002 ISO/IEC 27002 ISO/IEC 27002 is a guidance standard containing a... Clause: 5.34 – Privacy and protection of PII
          ISO
          Standard
          		 v2022 View →
          COBIT2019 COBIT COBIT is an enterprise governance and management f... Clause: 4.2 – Align, Plan and Organize (APO) > APO13 – Managed Security > APO13.01 – Establish and maintain an information security management system.
          COBIT
          Governance Framework
          		 v2019 View →
          NIST-CSF NIST Cybersecurity Framework (CSF) The NIST Cybersecurity Framework provides high-lev... Clause: GV.OC – Organizational Context | GV.OC-03 – Legal, regulatory, and contractual requirements regarding cybersecurity — including privacy and civil liberties obligations — are understood and managed
          NIST
          Framework
          		 v2 View →
          NIST80053 NIST SP 800-53 NIST SP 800-53 Rev. 5 presents control families, i... Clause: 3.12 – PLANNING, 3.16 – RISK ASSESSMENT; PL-5 – PRIVACY IMPACT ASSESSMENT, RA-8 – PRIVACY IMPACT ASSESSMENTS
          NIST
          Control Catalog
          		 vRev. 5 View →
          GDPR General Data Protection Regulation (GDPR) The General Data Protection Regulation is a bindin... Clause: Article 25(1) – Data protection by design and by default
          EU
          Regulation
          		 vCurrent View →
          NPCI-ISR NPCI Information Security Requirements NPCI information-security requirements define cont... Clause: Security Measures / Controls; Data Privacy
          India
          Standard
          		 vLatest View →
          SOC2 SOC 2 Trust Services Criteria SOC 2 is an independent examination and reporting... Clause: CC5.1 – Control Activities – COSO Principle 10: The entity selects and develops control activities that contribute to the mitigation of risks to the achievement of objectives to acceptable levels. P1.1 – Privacy: Notice and Communication of Objectives – The entity provides notice to data subjects about its privacy practices to meet the entity’s objectives related to privacy. The notice is updated and communicated to data subjects in a timely manner for changes to the entity’s privacy practices, including changes in the use of personal information, to meet the entity’s objectives related to privacy.
          AICPA
          Audit Framework
          		 vLatest View →
          ISO27701 ISO/IEC 27701 ISO/IEC 27701 provides requirements and guidance f... Clause: A.7.4.1; A.7.4.2; A.7.4.4; A.7.4.5; A.7.4.9; A.7.4.1 – Limit collection; A.7.4.2 – Limit processing; A.7.4.4 – PII minimization objectives; A.7.4.5 – PII de-identification and deletion at end of processing; A.7.4.9 – PII transmission controls
          ISO
          Privacy Standard
          		 v2019 View →

          Parent Domain Context

          Governance Domain Baseline
          Domain Name:
          Data Protection & Privacy (DAT)
          Purpose:
          To protect data throughout its lifecycle and ensure compliance with privacy regulations.
          Scope:
          Enterprise
          View

          Parent Control Context

          Control Baseline
          Control Name:
          Privacy by Design (DAT-011)
          Summary:
          Establishes processes to integrate privacy requirements, controls, and assessments into the design, development, and operation of business processes, products, systems, and services.
          Business Description:
          Integrate privacy requirements into business processes, projects, products, systems, and services throughout their lifecycle.
          View