Researchers Supreeth Shastri, Melissa Wasserman, and Vijay Chidambaram from the University of Texas at Austin have published a study that delves into the challenges of achieving compliance with the General Data Protection Regulation (GDPR) in modern data processing systems. Their work, titled “The Seven Sins of Personal-Data Processing Systems under GDPR,” offers a critical examination of how GDPR regulations clash with the design, architecture, and operation of contemporary systems.
The study identifies seven key conflicts, which the researchers term the “seven sins.” The first sin is the practice of storing data indefinitely. Modern systems are often designed to retain data for extended periods, which conflicts with GDPR’s emphasis on data minimization and timely deletion. The second sin involves the indiscriminate reuse of data. Many systems process data for purposes beyond their original intent, which GDPR restricts to ensure user privacy and consent.
The third sin, walled gardens and black markets, refers to the isolation of data within proprietary systems or illegal data trading platforms. This practice undermines GDPR’s goal of transparency and user control over personal data. The fourth sin, risk-agnostic data processing, highlights how systems often process data without adequate consideration of associated risks, which GDPR seeks to mitigate through risk assessments and impact evaluations.
The fifth sin is the tendency to hide data breaches. Many organizations delay or conceal breach notifications to avoid reputational damage, contrary to GDPR’s requirement for prompt disclosure. The sixth sin involves making unexplainable decisions. Systems that rely on complex algorithms without providing clear explanations for their outcomes can infringe on users’ rights to understand and challenge decisions affecting them.
Finally, the seventh sin is treating security as a secondary goal. Many systems prioritize functionality and performance over robust security measures, which GDPR mandates as a fundamental requirement for protecting personal data. The researchers argue that addressing these sins requires comprehensive, systemic solutions rather than piecemeal fixes. They emphasize the need for a ground-up redesign of data processing systems to align with GDPR’s principles, ensuring that privacy and security are integral to system architecture and operation.
The study underscores the deep-rooted tensions between regulatory requirements and technological evolution. By identifying these conflicts, the researchers aim to guide developers, policymakers, and organizations toward creating more compliant and secure data processing systems. Their findings highlight the importance of integrating privacy and security considerations from the outset, rather than as afterthoughts, to achieve meaningful compliance with GDPR. Read the original research paper here.