Privacy’s "Safety by Design" Framework: A Path to Safer, Privacy-First Products

"Privacy is Safety" - Debbie Reynolds “The Data Diva”

In the digital age, with the ever-growing amount of personal data generated about humans, privacy should be seen as much more than a legal checkbox exercise—it’s a fundamental issue of personal safety.

As cyberstalking, location tracking misuse, and online harassment become more prevalent, it is critical to treat privacy as a safety concern. With this approach in mind, I created the "Safety by Design" Privacy Framework to empower privacy professionals, technology developers, and implementors to consider integrating privacy as a safety measure directly into their product development lifecycle. By following this framework, companies can ensure their users’ privacy is safeguarded for compliance and genuine protection.

This article outlines the Safety by Design Framework’s principles and provides actionable guidelines for implementing these measures. This article will explain each area of the framework in detail, provide examples of recent incidents where privacy breaches have led to real-world harm, and highlight companies that have successfully implemented similar practices to strengthen user safety.

The Critical Need for Safety by Design

Cyber harassment and misuse of location tracking are not hypothetical threats — they are real dangers that affect people every day. According to SafeHome.org, 80% of all stalking victims report being tracked using technology. Apps designed to foster connectivity and convenience can be misused for stalking and harassment, with dire consequences. For example:

  • Bluetooth Tracking Devices: Devices like Apple's AirTags were intended to help users locate lost items. However, these devices have been misused for stalking, leading to safety alerts on both Android and iOS devices, where users are notified if an unknown AirTag is tracking them.

  • Data Broker Practices: Certain data brokers collect and sell precise location data from mobile apps, potentially exposing individuals who frequent sensitive locations, like health clinics. This data exposure poses real safety risks, prompting the Federal Trade Commission (FTC) to take action against data brokers like Kochava, which allegedly sold data that could track people’s movements.

These incidents emphasize the importance of designing digital products with privacy and safety intertwined. The Safety by Design Framework proposes the following pillars: Data Collection and User Consent, Data Minimization and User Control, and Location Privacy and Data Masking.

1. Data Collection and User Consent

Collecting user data should be transparent and limited to what is necessary. Users must understand what data is being collected, why it’s needed, and the associated risks. The following principles ensure consent is informed and user-friendly.

  • Context-Based Incremental Consent Collect consent only when it’s relevant and understandable to users. For instance, prompt users to opt-in for location sharing when they use a map function within the app, rather than requesting it at installation. Incremental consent helps users understand specific data uses at relevant moments, reducing the likelihood of overcollection and increasing trust.

  • Clear Visual Cues for Data Collection Users should see real-time visual indicators when sensitive data, such as location or microphone access, is in use. This transparency helps build trust and keeps users informed about ongoing data collection.

  • Limit Sensitive Data Collection and Transfers in App Integrations and APIs Sensitive data transfers through third-party integrations should be minimized. Integrate only essential and rigorously audited third-party tools. The more touchpoints with sensitive data, the greater the risk of misuse or breaches.

  • Prevent Cross-Device Tracking Without Explicit User Consent Tracking a user across multiple devices without their informed consent should be avoided. While cross-device tracking can provide convenience, it should never happen without the user’s explicit approval, as it can easily breach personal privacy and open avenues for stalking or harassment.

  • Transparent Consent Flows Consent screens should be clear, easy to navigate, and layered to provide users with essential information upfront, with the option to access additional details if they choose. This approach ensures that users can make well-informed decisions without being overwhelmed by technical language.

Implementation Ideas:

  • Introduce prompts at relevant points in the user journey, especially when high-risk data is being collected.

  • Use visible alerts (like icons or color-coded indicators) for sensitive data access.

  • Conduct regular audits of third-party APIs and integrations, limiting data exchange wherever possible.

  • Avoid cross-device tracking by default; ask for user consent in explicit terms if cross-device tracking is necessary.

  • Design simple, step-by-step consent flows, offering additional information as needed to maintain transparency.

2. Data Minimization and User Control

Reducing data collection to the minimum needed for functionality minimizes privacy risks and empowers users with greater control over their data. This framework area focuses on giving users clear, meaningful control over their personal information.

  • Privacy-Centric Defaults Configure all apps to begin with privacy-enhancing default settings, giving users control to adjust sharing options later. Defaults that prioritize privacy ensure users are not unknowingly sharing their data.

  • Customizable Privacy Controls for Contact Groups Many users interact with various groups (e.g., family, friends, coworkers). Allow users to manage privacy settings by group, offering a tailored approach to data visibility that matches users’ real-world social distinctions.

  • Mask or Hide Personal Information in Public Profiles and Customizable Privacy Settings Personal information should be easily masked or hidden, especially in public profiles, giving users control over what is visible. Implement privacy controls to allow users to manage the visibility of sensitive information on their profile.

  • Temporary Account Deactivation or Anonymization Without Full Deletion Sometimes, users may need a break from an app or want to temporarily pause their account. Providing a deactivation option without requiring permanent deletion can give users peace of mind while reducing privacy risks.

  • Time-Limited, Expiring Access Links for Sharing Sensitive Data For sensitive information, provide options to share data via time-limited links that automatically expire after a certain period. This ensures sensitive data does not remain accessible indefinitely.

Implementation Ideas:

  • Default all new user accounts to privacy-maximizing settings and allow users to adjust later.

  • Offer easy-to-use privacy controls for different contact groups, letting users adjust visibility.

  • Include profile privacy options to hide or mask personal details by default.

  • Provide options for temporary account deactivation or anonymization.

  • Develop expiring data-sharing links for sensitive information with adjustable expiration times.

3. Location Privacy and Data Masking

Location data is among the most sensitive information collected by apps. Misusing this data can easily lead to safety risks, especially with cyberstalking and real-time tracking. The following measures prioritize user control and security.

  • Opt-In for Location Tracking Location tracking should be opt-in, not opt-out. Users should have control over whether and when their location is shared, and permissions should be requested only when needed.

  • Time-Limited Permissions for Location and Data Sharing Apps should provide options for permissions that expire after a set period, requiring users to reauthorize access if they wish to continue sharing. This approach minimizes continuous tracking and helps users maintain control over location data.

  • Easy Options to Delete, Pause, or Disable Tracking Features Like Location History Users should be able to quickly disable or delete location history and pause tracking if they need temporary privacy. This feature is particularly important for preventing location-based risks like stalking or harassment.

  • Turn Off Real-Time Activity Broadcasting and Mask Real-Time Locations from Others Apps that involve social interaction or broadcasting should provide options to turn off real-time location sharing or mask real-time activities. This feature prevents unwanted tracking and gives users more privacy in their interactions.

  • Invisible Mode or Alias-Based Settings to Hide Online Presence or Activities An “invisible mode” or alias setting allows users to browse or interact without revealing their identity. This setting is crucial for high-risk apps like dating platforms, where real-time privacy can have safety implications.

Implementation Ideas:

  • Default all location tracking to opt-in; prompt for permissions only when essential.

  • Develop time-limited permissions that require periodic re-authorization for ongoing location sharing.

  • Provide easy-to-find options for deleting, pausing, or disabling location history.

  • Include toggles for disabling real-time activity broadcasting, with masking options for user safety.

  • Implement invisible mode or alias options where real-time privacy can impact user safety.

Real-World Success Stories: Google and Apple’s AirTag Safety Notifications

Google and Apple’s collaborative AirTag safety notifications provide a prime example of safety by design. When AirTags began being misused for stalking, both companies developed cross-platform alerts to notify users if an unknown AirTag was tracking them. This example illustrates the power of prioritizing safety in technology design. Not only did this measure protect users, but it also fostered trust by showing users that these companies take privacy and safety seriously.

This proactive measure is the industry response needed to keep up with privacy threats. Apple and Google’s collaboration proves companies can turn privacy issues into innovation and user trust-building opportunities.

Privacy as a Safety Imperative

The Safety by Design Framework isn’t just a recommendation; it’s a roadmap to help developers, designers, and implementors embed privacy into every layer of product design. By treating privacy as a fundamental safety issue, companies can reduce risks associated with cyber harassment, tracking, and unauthorized data use.

This proactive approach is essential because regulations provide important protections but can’t keep pace with every new technological risk. With The “Safety by Design” Privacy Framework, companies can build stronger, safer relationships with users and distinguish themselves as leaders in the privacy-first movement.

By prioritizing safety through privacy, they protect data and people. For organizations committed to real change, the “Safety by Design” Privacy Framework provides practical guidance for turning privacy into a core feature, not just a compliance measure.

This framework offers guidance on moving beyond seeing privacy as a hurdle and recognizing it as an essential safeguard. It helps protect people in a world where technology is increasingly integrated into daily life and helps companies make “Privacy a Business Advantage.”

Do you need Data Privacy Advisory Services? Schedule a 15-minute meeting with Debbie Reynolds, The Data Diva.

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