Privacy Review

Privacy Review

Purpose

Assess whether personal data is collected, used, stored, shared, and deleted responsibly and lawfully — minimization, consent, retention/erasure, and leak paths (logs, analytics, third parties). Privacy overlaps security but is distinct: data can be secure yet still mishandled.

When to Use

• When the system handles personal data, in ../../security-review or before launch.
• Not for pure access-control/injection security (other security skills) — though they intersect at data exposure.

Inputs

• The data-sensitivity map + data flows (../../backend/backend-security, threat-modeling).
• Third-party integrations receiving data (../../backend/third-party-integrations), applicable regulations.

Discovery Questions

• What personal data is collected, and is each field actually needed (minimization)?
• Is collection/use lawful and consented where required, and is the purpose limited?
• What are the retention periods, and does deletion (erasure) actually remove data — including backups and third parties?
• Where might PII leak: logs, analytics, error reports, dev seeds, exports, third-party sharing?
• Any cross-border transfer or regulatory regime (GDPR/CCPA/sector-specific) constraints?

Responsibilities

• Classify + minimize: inventory personal-data fields; flag data collected without a clear need — the least-risky data is what you never collect.
• Lawful basis + consent: verify collection/use has a basis and required consent; purpose limitation (data used only for what it was collected for) — especially for analytics/marketing use of operational data.
• Retention + erasure: retention periods defined and enforced; account/data deletion genuinely deletes or anonymizes (not a soft-delete flag), and the backup-retention interaction is a recorded, compliant policy (../../database/backup-recovery, ../../database/database-security).
• Leak paths: no PII in logs/metrics/error reports (../../devops/monitoring-logging redaction), analytics events, or dev/test seeds (../../testing/test-data-management); exports scoped and access-controlled.
• Third-party sharing: what personal data flows to which processors, under what agreement, and is it disclosed (../../backend/third-party-integrations)?
• Cross-border + compliance: transfers and regime-specific obligations (subject access, erasure, breach notification) surfaced at planning, not discovered at audit.
• Route findings to fixes + regression tests where testable (security-regression-testing).

Required Workflow

1. Inventory + classify personal-data fields; flag over-collection.
2. Verify lawful basis, consent, and purpose limitation.
3. Verify retention + real deletion/erasure (incl. backups, third parties).
4. Audit leak paths (logs, analytics, errors, seeds, exports).
5. Map third-party sharing + cross-border/compliance obligations.
6. Record findings; route to fixes/tests.

Decision Rules

• Don't collect what you don't need — minimization is the strongest privacy control.
• Deletion must be real: a soft-delete that retains PII fails erasure obligations.
• Purpose limitation matters: reusing operational PII for analytics/marketing without basis is a finding.
• PII in logs/analytics/seeds is a finding even if the store is "secure" — exposure is exposure.

Rules

• Never reproduce real personal data in findings — reference field/location only.
• Findings separated Confirmed vs Potential; compliance obligations surfaced explicitly.
• Deletion/erasure paths are verified, not asserted.

Anti-Patterns

• Collecting PII "in case it's useful."
• Soft-delete presented as erasure.
• PII flowing into analytics/logs/error trackers unredacted.
• Production PII in dev/test seeds.
• Third-party data sharing with no agreement or disclosure.
• Discovering GDPR/CCPA obligations at audit instead of design.

Validation Checklist

• Personal-data fields classified; over-collection flagged.
• Lawful basis, consent, purpose limitation verified.
• Retention + real erasure (incl. backups/third parties) verified.
• Leak paths (logs/analytics/errors/seeds/exports) clean.
• Third-party sharing + cross-border/compliance mapped.
• Findings → fixes/tests.

Definition of Done

A recorded privacy assessment — data minimization, lawful/consented use, retention and real erasure, leak-path audit, third-party sharing, and compliance obligations — with Confirmed/Potential findings routed to fixes, deletion paths verified, and no personal data reproduced in the report.

Related Skills

../../backend/backend-security, database-security, ../../database/database-security, ../../database/backup-recovery, ../../devops/monitoring-logging, ../../testing/test-data-management, ../../backend/third-party-integrations, security-regression-testing, ../../security-review, threat-modeling.

Related Knowledge

../../../knowledge/ (data inventory, regulatory regime, processors).

Related References

../../../references/security/ (privacy checklists, when populated).

Context Loading Guidance

• Requires: data-sensitivity map + flows, third-party sharing, regulations.
• Does not require: injection/access-control depth (other skills), real PII values.
• May load: database-security, ../../backend/third-party-integrations.
• Stop when: classification, retention/erasure, leak paths, and compliance are assessed.

Token Efficiency Guidance

The data-field table (field, needed?, basis, retention, erasure, shared-with) is the artifact; never reproduce actual personal data.