feat(skills): add privacy-by-design skill with PbD 7 Foundation Principles assessment - #2635
Conversation
…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
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…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
Jamie Kim (jkim323)
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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:
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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
nullvalues when all checks are unknown. Missing evidence must not be treated as a failed control. -
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.
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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/Awhen 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. -
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_categoryandretention_gapcitation 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.
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
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eferences/00-principle-index.md | Principle catalog with regulatory cross-reference matrix |
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eferences/01-07 | One file per PbD principle with checklist, controls, anti-patterns, regulatory mappings |
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eferences/data-retention-and-disposal.md | Principle 05 deep-dive: retention schedules, disposal methods, legal holds |
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eferences/cross-jurisdictional-mapping.md | GDPR / CCPA-CPRA / APP equivalence matrix |
Key differentiators
Value proposition
Checklist
Refs: #2594