Privacy by Default (GDPR Article 25(2)) requires organisations to implement privacy-friendly default settings as standard. Only the personal data necessary for each specific purpose may be processed by default – covering quantity, scope, retention period and accessibility. ADVISORI supports the systematic implementation of this requirement across all your systems and processes.
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Privacy by Design & Default are not optional but mandatory GDPR principles. Organizations must be able to demonstrate that they have integrated these principles into their development and business processes.
Years of Experience
Employees
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We follow a systematic approach to implementing Privacy by Design & Default that addresses both technical and organizational aspects.
Analysis of existing development and business processes
Development of a tailored Privacy by Design strategy
Gradual integration into all relevant processes
Training and change management for all stakeholders
Continuous monitoring and optimization of implementation
"Implementing Privacy by Design & Default with ADVISORI has transformed our entire product development. Data protection is now a natural part of our innovation, no longer a downstream compliance check."

Head of Information Security, Cyber Security
Expertise & Experience:
10+ years of experience, CISA, CISM, Lead Auditor, DORA, NIS2, BCM, Cyber and Information Security
We offer you tailored solutions for your digital transformation
Development of a comprehensive strategy for integrating data protection into all organizational processes.
Systematic implementation of privacy-friendly default configurations across all systems and applications.
Choose the area that fits your requirements
A comprehensive GDPR data protection analysis identifies weaknesses in your current data protection measures and highlights concrete areas for action. Our gap assessment provides you with a clear roadmap to full GDPR compliance.
Establish an effective data protection organization with clear roles, responsibilities, and professional DPO coordination for optimal GDPR compliance.
Article 25(2) GDPR requires controllers to implement technical and organisational measures ensuring that, by default, only personal data necessary for each specific processing purpose is processed. This obligation covers the amount of data collected, the extent of processing, the storage period and accessibility. In particular, data must not be made accessible to an indefinite number of persons without the data subject's intervention.
Typical measures include: opt-in rather than opt-out for marketing consent, minimal mandatory fields in forms, shortest retention period as default, restricted profile visibility, deactivated tracking cookies on first use, anonymous usage as standard, and automatic data deletion after purpose fulfilment. The EDPB Guidelines 4/2019 describe seven design principles as a binding reference framework.
Privacy by Design (Article 25(1) GDPR) requires integrating data protection into systems from the development stage, for example through pseudonymisation or data minimisation in the architecture. Privacy by Default (Article 25(2) GDPR) demands that default settings ensure only the data necessary for each specific purpose is processed. Design secures the architecture; Default protects users who do not actively change settings.
Data minimisation (Article 5(1)(c) GDPR) is the principle limiting collection to what is necessary. Privacy by Default is the technical tool to implement data minimisation in practice: default settings ensure only purpose-specific data is collected without requiring users to actively intervene. Together they form the foundation of a privacy-friendly system.
Article
25 GDPR applies to all processing operations, including legacy systems. Controllers must assess whether existing default settings meet the current state of the art and retrofit where necessary. Supervisory authorities expect continuous adaptation to new risks and technological capabilities. A one-time setup is not sufficient.
Violations of Article
25 GDPR can be sanctioned under Article 83(4) GDPR with fines of up to EUR
10 million or 2% of worldwide annual turnover. Supervisory authorities have imposed fines where software solutions lacked privacy-friendly default settings or personal data was collected without purpose limitation.
The seven principles developed by Ann Cavoukian are: (1) Proactive not reactive, (2) Privacy as the default setting, (3) Privacy embedded into design, (4) Full functionality with positive-sum approach, (5) End-to-end lifecycle security, (6) Visibility and transparency, (7) Respect for user privacy. These principles have been incorporated into the EDPB Guidelines 4/2019 on Article
25 GDPR.
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