Position: GDPR Compliance by Construction

Abstract

© 2019, Springer Nature Switzerland AG. New laws such as the European Union’s General Data Protection Regulation (GDPR) grant users unprecedented control over personal data stored and processed by businesses. Compliance can require expensive manual labor or retrofitting of existing systems, e.g., to handle data retrieval and removal requests. We argue for treating these new requirements as an opportunity for new system designs. These designs should make data ownership a first-class concern and achieve compliance with privacy legislation by construction. A compliant-by-construction system could build a shared database, with similar performance as current systems, from personal databases that let users contribute, audit, retrieve, and remove their personal data through easy-to-understand APIs. Realizing compliant-by-construction systems requires new cross-cutting abstractions that make data dependencies explicit and that augment classic data processing pipelines with ownership information. We suggest what such abstractions might look like, and highlight existing technologies that we believe make compliant-by-construction systems feasible today. We believe that progress towards such systems is at hand, and highlight challenges for researchers to address to make them a reality.