Active

Design Continuous Improvement

The organization shall drive ongoing enhancement of privacy by design through a continuous improvement process. The process shall use inputs from design reviews, stakeholder feedback, regulatory changes, and best practice benchmarking to identify, implement, and measure improvements.

Requirement ID
DAT-011-R010
Parent Control
Domain Code

Requirement Details & Guidance

DAT-011-R010 · DAT-011
Why This Requirement Exists

To systematically improve privacy by design using evidence from performance, incidents, reviews, audit findings, stakeholder feedback, and changes in requirements.

Implementation Guidance

Use review results, incidents, metrics, audit findings, regulatory changes, stakeholder feedback, and benchmarking to identify, prioritize, implement, and measure improvements.

Practical Application & Audit Readiness

DAT-011-R010 · Field Guidance

Business Examples

    Common Audit Findings

      Common Mistakes

        Best Practices & Ownership

        DAT-011 · Recommended Approach

        Recommended Practices

          Typical Owner

          Cross-Mapped Regulatory Frameworks

          Harmonized Control Mappings
          FRAMEWORK CODE FRAMEWORK NAME & DETAILS FAMILY / CATEGORY VERSION ACTION
          ISO27001 ISO/IEC 27001 ISO/IEC 27001 specifies auditable requirements for... Clause: 10.1 – Continual improvement
          ISO
          Standard
          v2022 View →
          SEBI-CSCRF SEBI Cyber Security & Cyber Resilience Framework SEBI’s Cybersecurity and Cyber Resilience Framewor... Clause: 1.1 GV.OC: Organizational Context; 3.3 PR.DS: Data Security
          India
          Regulation
          vLatest View →
          DORA Digital Operational Resilience Act The EU Digital Operational Resilience Act establis... Clause: Article 9(2) – ICT security policies, procedures, protocols and tools for resilience and data security Article 9(3) – ICT solutions/processes for secure data transfer and prevention of loss, unauthorised access and data compromise Article 12(1)(a) – Backup policies/procedures based on data criticality or confidentiality
          EU
          Regulation
          vCurrent View →
          ISO27002 ISO/IEC 27002 ISO/IEC 27002 is a guidance standard containing a... Clause: 5.34 – Privacy and protection of PII
          ISO
          Standard
          v2022 View →
          NIST-CSF NIST Cybersecurity Framework (CSF) The NIST Cybersecurity Framework provides high-lev... Clause: ID.AM – Asset Management | ID.AM-07 – Inventories of data and corresponding metadata for designated data types are maintained PR.DS – Data Security | PR.DS-01 – The confidentiality, integrity, and availability of data-at-rest are protected
          NIST
          Framework
          v2 View →
          NIST80053 NIST SP 800-53 NIST SP 800-53 Rev. 5 presents control families, i... Clause: 3.12 – PLANNING, 3.16 – RISK ASSESSMENT; PL-5 – PRIVACY IMPACT ASSESSMENT, RA-8 – PRIVACY IMPACT ASSESSMENTS
          NIST
          Control Catalog
          vRev. 5 View →
          GDPR General Data Protection Regulation (GDPR) The General Data Protection Regulation is a bindin... Clause: Article 24(1) – Responsibility of the controller; Article 25(1) – Data protection by design and by default
          EU
          Regulation
          vCurrent View →
          NPCI-ISR NPCI Information Security Requirements NPCI information-security requirements define cont... Clause: Security Measures / Controls; Data Security
          India
          Standard
          vLatest View →
          SOC2 SOC 2 Trust Services Criteria SOC 2 is an independent examination and reporting... Clause: CC5.1 – Control Activities – COSO Principle 10: The entity selects and develops control activities that contribute to the mitigation of risks to the achievement of objectives to acceptable levels. P1.1 – Privacy: Notice and Communication of Objectives – The entity provides notice to data subjects about its privacy practices to meet the entity’s objectives related to privacy. The notice is updated and communicated to data subjects in a timely manner for changes to the entity’s privacy practices, including changes in the use of personal information, to meet the entity’s objectives related to privacy. CC4.1 – Monitoring of Controls – COSO Principle 16: The entity selects, develops, and performs ongoing and/or separate evaluations to ascertain whether the components of internal control are present and functioning. CC4.2 – Monitoring of Controls – COSO Principle 17: The entity evaluates and communicates internal control deficiencies in a timely manner to those parties responsible for taking corrective action, including senior management and the board of directors, as appropriate.
          AICPA
          Audit Framework
          vLatest View →
          ISO27701 ISO/IEC 27701 ISO/IEC 27701 provides requirements and guidance f... Clause: 5.2.4; 5.2.4 – PIMS
          ISO
          Privacy Standard
          v2019 View →

          Parent Domain Context

          Governance Domain Baseline
          Domain Name:
          Data Protection & Privacy (DAT)
          Purpose:
          To protect data throughout its lifecycle and ensure compliance with privacy regulations.
          Scope:
          Enterprise

          Parent Control Context

          Control Baseline
          Control Name:
          Privacy by Design (DAT-011)
          Summary:
          Establishes processes to integrate privacy requirements, controls, and assessments into the design, development, and operation of business processes, products, systems, and services.
          Business Description:
          Integrate privacy requirements into business processes, projects, products, systems, and services throughout their lifecycle.