# Privacy Goals for the Data Lifecycle
## 6 Step 3-Aligning the Privacy Goals to GDPR and the Data Lifecycle
### 7-DL-3-Transformation  
At transformation stage, decisions regarding data processing and use, and any restrictions placed on how data is processed must be considered. For the life logging scenario, transformation concerns handling of the data (part of the act of _processing_ under GDPR, Article 4(2)). In terms of processing, this refers to those who manage the data and the app and how they process the data which means a lot of decisions will need to be made around how the data is processed (including by whom and to what extent). First of all, those who process the data on behalf of the project, will need to be trained on GDPR and the privacy goals, to ensure they understand their obligations. This, arguably, could also be considered a governance decision as any such training will need to encompass all aspects of data processing and sharing. However, this is the first of potential interactions for those who work with the data while processing. There are a number of potential risk in this phase (sometimes referred to as insider threat) that can be avoided by ensuring those who work with the data understand what they can and cannot do with the data and how this might affect both themselves, their employer and the data subjects whose data they are processing.  
Next, each of the principles within GDPR will apply to data processing. Lawfulness requires that data is processed in accordance with GDPR principles, in a fair and transparent manner (Article 5(1)(a)), while purpose limitation (Article 5(1)(b) seeks to ensure that data is only processed in accordance with agreed terms (Privacy Goals 8 and 9). This means whatever decisions have been made at the data collection stage by the citizens must be respected and followed. So, if for example, the citizen has opted to not share their location details beyond the time spent in the building, a facility must be made available to select what data can be shared, with whom and for what period of time (e.g., only while in the building, continually, or not at all). Data minimisation requires that only strictly necessary data is processed (Article 5(1)(c)). This means that, if the citizen is not in the building, they do not need to receive a notification of the incident. Accuracy requires that data is kept up to date (Article 5(1)(d)), and integrity and confidentiality (Article 5(1)(e)) requires that data is processed securely including, for example, implementing effective access controls to ensure data cannot be accessed without authorisation. This means that data should be available as needed to those who are authorised to handle the data (Privacy Goal 3), while maintaining all of the other privacy goals. It also means that Confidentiality (Privacy Goal 1) and integrity (Privacy Goal 2) must be maintained, while ensuring unlinkability (Privacy Goal 4) and unobservability (Privacy Goal 5) to any user not authorised to view or process the data. This may require data to be anonymised (Privacy Goal 6) or pseudonymised (Privacy Goal 8) as part of the processing. Finally, interveneability (Privacy Goal 8) and transparency (Privacy Goal 9) requires that either the citizen (or indeed, the supervisory authorities) must be able to intervene at any point should the need arise or, if they so wish.