Privacy and security by design: Comparing the EU and Israeli approaches to embedding privacy and security

Policymakers in the European Union and Israel are searching for regulatory strategies on how to best protect their citizens informational privacy. More recently, the focus has shifted towards Privacy and Security by Design as a mean to address current privacy concerns. While Privacy and Security by Design in itself is not a new idea, its implementation has taken new forms within the General Data Protection Regulation, as well as in various Israeli laws, inter alia, the Privacy Protection Regulations on Data Security. In this article we first analyse these implementations of Privacy and Security by Design and then compare the European and Israeli approaches with one another. We address the question of which approach provides more guidance to developers with respect on how to embed Privacy and Security by Design measures into new services and products. We conclude by pointing to empirical research needed to further analyse the impact of the two different regulatory strategies.