Skip to content

feat(skills): add privacy-by-design skill with PbD 7 Foundation Principles assessment - #2635

Open
Yogi (yogitasrivastava) wants to merge 7 commits into
microsoft:mainfrom
yogitasrivastava:feat/privacy-by-design-skill
Open

feat(skills): add privacy-by-design skill with PbD 7 Foundation Principles assessment#2635
Yogi (yogitasrivastava) wants to merge 7 commits into
microsoft:mainfrom
yogitasrivastava:feat/privacy-by-design-skill

Conversation

@yogitasrivastava

Copy link
Copy Markdown

Summary

Adds a new privacy-by-design skill under .github/skills/project-planning/ that encodes the Cavoukian 7 Foundation Principles of Privacy by Design as structured, agent-consumable assessment references.

What this delivers

File Purpose
SKILL.md Skill entrypoint with when-to-use, layout, integration notes, attribution

|
eferences/00-principle-index.md | Principle catalog with regulatory cross-reference matrix |
|
eferences/01-07 | One file per PbD principle with checklist, controls, anti-patterns, regulatory mappings |
|
eferences/data-retention-and-disposal.md | Principle 05 deep-dive: retention schedules, disposal methods, legal holds |
|
eferences/cross-jurisdictional-mapping.md | GDPR / CCPA-CPRA / APP equivalence matrix |

Key differentiators

  • Structured assessment criteria — each principle has observable PASS/FAIL/PARTIAL indicators with severity ratings
  • Cross-jurisdictional coverage — maps all 7 principles across GDPR Art. 25, CCPA/CPRA, and Australian Privacy Principles (APP)
  • Data retention and disposal — full lifecycle guidance under Principle 05 including legal holds, backup considerations, disposal verification
  • Agent-ready architecture — feeds Privacy Reviewer and Privacy Planner without agent modification (same pattern as owasp-* skills feeding security-reviewer)
  • Complements privacy-standards — extends the NIST PF/GDPR/CCPA/OWASP backbone with principle-level assessment

Value proposition

Without this skill With this skill
Privacy Reviewer assesses only against NIST PF, GDPR, CCPA, OWASP Privacy Risks Also assesses against PbD principles, retention/disposal compliance, and APP
No structured checks for 'is privacy the default?' or 'is data disposed securely?' Principle-by-principle structured findings with severity ratings
No Australian Privacy Principles coverage Cross-jurisdictional coverage (GDPR + CCPA + APP)

Checklist

  • Follows existing skill structure (mirrors secure-by-design, owasp-top-10 patterns)
  • Includes attribution and licensing posture
  • No executable scripts (markdown knowledge-base skill)
  • Cross-references privacy-standards skill for integration context

Refs: #2594

…iples

Add a new privacy-by-design skill under project-planning that encodes
the Cavoukian 7 Foundation Principles as structured, agent-consumable
assessment references. Includes:

- SKILL.md entrypoint with when-to-use guidance and integration notes
- Per-principle references (01-07) with checklists, controls, anti-patterns,
  and cross-references to GDPR Art. 25, CCPA/CPRA, and Australian APP
- Data retention and disposal deep-dive (Principle 05 expansion)
- Cross-jurisdictional regulatory equivalence matrix
- Finding severity and verdict conventions for PASS/FAIL/PARTIAL assessment

Complements privacy-standards skill; loaded by Privacy Reviewer and
Privacy Planner agents on demand without agent modification.

Refs: microsoft#2594
@yogitasrivastava
Yogi (yogitasrivastava) requested a review from a team as a code owner August 9, 2026 14:02
@codecov-commenter

Codecov Comments Bot (codecov-commenter) commented Aug 9, 2026

Copy link
Copy Markdown

Codecov Report

✅ All modified and coverable lines are covered by tests.
✅ Project coverage is 83.01%. Comparing base (8aa6b21) to head (cfeb0dc).

Additional details and impacted files

Impacted file tree graph

@@            Coverage Diff             @@
##             main    #2635      +/-   ##
==========================================
- Coverage   83.14%   83.01%   -0.13%     
==========================================
  Files         183      185       +2     
  Lines       34028    34605     +577     
  Branches       27       27              
==========================================
+ Hits        28291    28729     +438     
- Misses       5734     5873     +139     
  Partials        3        3              
Flag Coverage Δ
docusaurus 90.60% <ø> (ø)
pester 83.41% <ø> (-0.43%) ⬇️

Flags with carried forward coverage won't be shown. Click here to find out more.
see 9 files with indirect coverage changes

🚀 New features to boost your workflow:
  • ❄️ Test Analytics: Detect flaky tests, report on failures, and find test suite problems.
  • 📦 JS Bundle Analysis: Save yourself from yourself by tracking and limiting bundle sizes in JS merges.

…tion patterns

Deepen the privacy-by-design skill with operational references that make
it agent-ready and pragmatic:

- assessment-protocol.md: 5-phase protocol (scope, principle assessment,
  retention check, cross-jurisdictional check, synthesis) with verdict
  rules, severity rules, evidence expectations, and stop rules
- finding-schema.md: YAML-based structured output schema with finding
  records, assessment summaries, retention extensions, and backlog
  handoff templates compatible with hve-core review workflow
- implementation-patterns.md: code-level and config-level verification
  patterns agents can check (consent mechanisms, default settings,
  encryption, retention enforcement, CI/CD privacy checks, IaC patterns)

Update SKILL.md to hve-builder outcome-first standards:
- Add Goal, Success criteria, and Stop rules sections
- Add Overall assessment verdicts table
- Add Interaction with other skills cross-reference table
- Reference new operational documents in skill layout

Refs: microsoft#2594
…nfig

Add industry-privacy-profiles.md mapping PbD principles to sector-specific
contexts (telco, healthcare, financial services) with:

- Per-industry principle priority weighting (which principles matter most)
- Industry-specific assessment checks beyond universal checklists
- Key regulatory references per sector
- .pbd-config.yml schema for project-level customization:
  - Industry selection
  - Principle priority overrides with justification
  - Custom checks (org-specific requirements)
  - Suppressions for inapplicable checks

Integration: Privacy Reviewer loads config, adjusts checklist weighting,
adds industry checks, and elevates findings based on sector priorities.

Refs: microsoft#2594

@jkim323 Jamie Kim (jkim323) left a comment

Copy link
Copy Markdown
Collaborator

Choose a reason for hiding this comment

The reason will be displayed to describe this comment to others. Learn more.

Requested changes

I ran the skill through the hve-builder tester and here are some findings worth considering. The simulated behavior assessment identified four required corrections to the assessment contract and evidence handling:

  1. Support incomplete assessments (F01). Define explicit outcomes for insufficient evidence, with consistent principle verdicts, overall verdicts, summary counts, and unknown-baseline handling. The current contract forces unsupported null values when all checks are unknown. Missing evidence must not be treated as a failed control.

  2. Support CRITICAL severity end to end (F02). Industry profiles require CRITICAL escalation, but the finding schema, severity distribution, and backlog mapping do not support it. Add CRITICAL consistently across these outputs. Map CRITICAL and HIGH to P1, ordering CRITICAL first, without introducing P0 or downgrading severity.

  3. Separate deficiency severity from data sensitivity (F03). PASS results currently receive MEDIUM or HIGH severity because of the data involved, even though those severity definitions imply a deficiency. Use N/A when no deficiency is established, including PASS results, and align the entrypoint, assessment protocol, finding records, and summaries. Unknown evidence alone must not generate fictitious remediation work.

  4. Reconcile contradictory evidence before transparency PASS (F04). A documented retention promise cannot justify an unqualified PASS when current operational evidence contradicts it. The test promised eSIM destruction within 30 days but showed recoverability at day 120. Record and assess that discrepancy while preserving credit for unaffected transparency controls.

Coverage and follow-up

  • Add regression coverage for healthcare and financial profiles, plus suppression of a check that would otherwise apply under the active profile (F05). Excluding unrelated checks does not demonstrate effective suppression. This is a coverage gap, not proof those features are defective.
  • Consider consistently including the known retention_category and retention_gap citation fields in retention findings (F06). This is advisory because the current schema does not clearly require them.
  • After implementation, rerun the corrected scenarios and preservation checks. Keep simulation results distinct from evidence of native activation, live privacy controls, or legal compliance.

Sign up for free to join this conversation on GitHub. Already have an account? Sign in to comment

Labels

None yet

Projects

None yet

Development

Successfully merging this pull request may close these issues.

4 participants