Intro (role perspective)
As a Security Architect I translate GDPR obligations into concrete design constraints and controls—below are concise architectural implications and when to consult the DPO.
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Data minimization
Architectural implication: Design systems to collect, store, and retain only the minimal attributes required (use attribute-based access, tokenization, and schema-level pruning).
Consult DPO: Before changing data models or adding new data collection to validate necessity.
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Purpose limitation
Architectural implication: Enforce purpose-tagging of data at ingestion and policy-driven access controls that prevent secondary uses.
Consult DPO: When introducing new data uses, analytics, or sharing that may deviate from declared purposes.
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Data subject rights
Architectural implication: Build auditable workflows, subject-access APIs, and reversible pseudonymization to support access, rectification, erasure, portability.
Consult DPO: When designing erasure/portability processes or automated fulfillment that may impact systems.
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Data Protection Impact Assessments (DPIA)
Architectural implication: Integrate DPIA checkpoints into design lifecycle; require threat models and mitigation mapping for high-risk processing.
Consult DPO: At project start for any high-risk processing, new technologies, or large-scale profiling.
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Lawful bases for processing
Architectural implication: Implement consent management, recordkeeping, and conditional processing gates tied to legal basis metadata.
Consult DPO: When defining which lawful basis applies or changing processing that may affect legal basis.
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Cross-border transfer constraints
Architectural implication: Architect data residency controls, encryption-in-transit/at-rest, and contractual/SCC mechanisms with selectable storage regions.
Consult DPO: Before sending data outside the EEA or using third‑party cloud regions.
If needed I map these into controls (encryption, logging, consent stores, access policies) and incorporate them into threat models and architecture review checklists.
