Privacy Engineering for Domestic IoT: Enabling Due Diligence

The EU’s General Data Protection Regulation (GDPR) has recently come into effect and insofar as Internet of Things (IoT) applications touch EU citizens or their data, developers are obliged to exercise due diligence and ensure they undertake Data Protection by Design and Default (DPbD). GDPR mandates the use of Data Protection Impact Assessments (DPIAs) as a key heuristic enabling DPbD. However, research has shown that developers generally lack the competence needed to deal effectively with legal aspects of privacy management and that the difficulties of complying with regulation are likely to grow considerably. Privacy engineering seeks to shift the focus from interpreting texts and guidelines or consulting legal experts to embedding data protection within the development process itself. There are, however, few examples in practice. We present a privacy-oriented, flow-based integrated development environment (IDE) for building domestic IoT applications. The IDE enables due diligence in (a) helping developers reason about personal data during the actual in vivo construction of IoT applications; (b) advising developers as to whether or not the design choices they are making occasion the need for a DPIA; and (c) attaching and making available to others (including data processors, data controllers, data protection officers, users and supervisory authorities) specific privacy-related information that has arisen during an application’s development.