ISACA Journal
Volume 2, 2,018 


Complying With GDPR: An Agile Case Study 

Mina Miri, Farbod H. Foomany, Ph.D., CISSP and Nathanael Mohammed 

Designed to give European Union residents better privacy rights, the EU General Data Protection Regulation (GDPR) comes into force in May 2018. It will replace the Data Protection Directive (Directive 95/46/EC).1 GDPR consists of 99 articles that outline regulations and 173 recitals that provide conceptual and legal context for the articles.2 Applying to all organizations that offer goods or services within the European Union or monitor EU residents’ personal data, it will be enforced even if the personal data processing occurs outside of Europe.3 Therefore, any organization handling an EU citizen’s personal information must comply with GDPR. Uncompliant organizations can be subject to fines of up to EU €20 million, or 4 percent of their annual turnover—whichever is greater.4

This article presents a case study of a smart bracelet that bears many of the privacy challenges of a typical Internet of Things (IoT) project. As the number of organizations that adopt faster development methodologies increases, aligning the efficiency of the Agile model5 with GDPR compliance can be daunting without guidance. To address this, a novel privacy-tagging approach as described in this article can be used along with state-of-the-art Agile methodologies to fulfill all the requirements of GDPR for developers, simplify auditing for compliance officers and ensure data protection for end users.

GDPR and the Software Development Life Cycle

GDPR redesigns personal data protection with the understanding that processing personal data is beneficial to society and that it must be balanced with a person’s fundamental rights and freedoms.6

The regulation places the responsibility of personal data protection on developers and expects that they will incorporate data protection into their applications by design at the technical and organizational levels.7 Additionally, for personal data processing that may pose a risk to the rights of individuals, as may be the case for data collection associated with new technologies, a data protection impact assessment is mandatory. This assessment determines to what extent the data processing of these technologies may impact the individuals who use them.8 Consequently, many IT organizations will have to reevaluate how they build software so they can integrate GDPR compliance into their applications’ life cycles.

The software development life cycle (SDLC) is divided into the following six phases: requirements, design, development, testing, deployment and maintenance.9 Various methodologies provide different approaches to the development of a software product. In older methodologies, such as the waterfall model, one phase completes before the other phase begins.10 However, more than half of IT organizations today use the Agile model, which is more flexible and realistic.11 As such, the chief challenge for software companies is to create a solution throughout the development and deployment phases that is GDPR compliant. Likewise, the challenge for privacy analysts is to evaluate and audit compliance with the regulation.

Implementing a solution that facilitates how software developers comply with GDPR is not a simple matter. To address this challenge, a list of 16 requirements to formulate the stipulations of GDPR for software development has been created.12 Similarly, with more emphasis on deployment and operation, the International Association of Privacy Professionals (IAPP) has provided information on 10 operational impacts of GDPR.13 This article proposes a different approach to GDPR-compliant software development based on a tagging method.

A Tagging Initiative for Building Privacy Into Agile Methods

In an approach presented to the Privacy Symposium 2017 at IAPP Canada,14 a tagging method in which GDPR’s text is coded in a way that is similar to the qualitative research methods of open coding, axial coding and selective coding was proposed.15 The tagging approach consists of the following steps:

  1. Identify tags for each GDPR mandate, where tags capture and code the essence of the mandate.
  2. Review, merge and classify tags.
  3. Assign tags to available privacy and security controls.
  4. Generate privacy and security tasks for tags with missing controls.
  5. Map tasks to GDPR mandates through tags.

This approach allows for the generation of tasks based on tags, and the auditing of tasks related to each tag, which ensures that the requirements of mapped mandates are met.

Epics, user stories and tasks are essential to an Agile framework and need to be defined carefully to develop a group of activities that can take advantage of the efficiency of Agile sprints. Sprints are timeboxed units of development, such as two weeks, and are also called iterations. For an Agile GDPR framework, tags and articles can be used to define user stories, as demonstrated in the following figures. User stories express software requirements in a few short sentences. They are a simple description of a feature required by a person who is usually a user, customer or administrator. User stories often have the following structure:

As a <who>, I want <what> so that <why>.

User stories can then be organized into epics. An epic is a group of user stories with the same goal, and it is labeled to reflect that goal. An epic can usually be created for a group of user stories that fall under the same class of tags. Figure 1 shows these elements, and how they are derived from tags.

Figure 1

Case Study Project Description

A smart, wearable fitness-tracking device is developed as a bracelet and watch. This device collects personal data and health information from the user, including name, email address, height and weight. The device processes that information, transfers it to other devices via Bluetooth, and makes the wearer’s location and ID available to a beacon or local transmitters. Some versions of this device also provide web applications for displaying information and further processing data. Figure 2 shows the components of such a solution.

Figure 2

GDPR Tags, User Stories and Requirements

GDPR includes several articles and recitals that apply to devices that collect personal data. Using these mandates as a foundation, figure 3 and figure 4 were compiled. These figures demonstrate the results of tagging, article/recital mapping, user story writing and organizing of user stories into epics. In the case of the smart bracelet project, the GDPR requirements are clearly outlined, and the same strategy can be used for any project. Figure 3 functions as a universal stepping stone for creating a complete Agile project by simply placing project-specific tasks under each user story. By using this strategy that weaves together the Agile methodology with GDPR compliance, any company developing any Agile project can track its GDPR compliance and prepare for compliance auditing and assessment.

Figure 3

Figure 4

Figure 3 provides the user stories for the core features required for the smart-bracelet project. Other user stories less central to the smart-device project are provided in figure 4. Based on the type of application being developed, the user stories in figure 4 can also be relevant to other projects. The user stories in figure 3 and figure 4 are copyrighted by Security Compass 2018.

The next step is to assign tags to the privacy tasks of each phase and to then tie these tasks to user stories and their tags. Figure 5 shows three privacy tasks that are grouped under a user story using the appropriate tag. Also shown in figure 5 is a list of available privacy and security controls, such as those that are available in Application Security Requirements and Threat Management (ASRTM) solutions. These controls can be easily organized using tags so that protecting sensitive data is directly related to completing tasks in a repository of security controls.

Figure 5


Integrating GDPR compliance with the SDLC is a major challenge for many IT organizations. This article presents a new approach to help development teams address the challenge in Agile environments. It presents an Agile GDPR template consisting of user stories, epics, relevant GDPR mandates and tags. The template and tags provide a list of GDPR mandates that apply to software/hardware development and deployment. This novel privacy-tagging approach can facilitate generating tasks and auditing for compliance so that GDPR compliance works in tandem with the efficiency of Agile development rather than against it.


1, “GDPR Portal: Site Overview,”
2 SecureDataService, “EU General Data Protection Regulation (EU-GDPR),”
3 SecureDataService, Article 3: Territorial Scope,
4 SecureDataService, Article 83: General Conditions for Imposing Administrative Fines,
5 Agile Alliance, “What is Agile Software Development?”
6 SecureDataService, Recital 4: EU GDPR,
7 SecureDataService, Article 25: Data Protection by Design and by Default,
8 SecureDataService, Article 25: Data Protection Impact Assessment,
9 International Software Testing Qualifications Board Exam Certification, What Are the Software Development Life Cycle (SDLC) Phases?
10 Half, R.; “Six Basic SDLC Methodologies: Which One Is Best?” 21 November 2017,
11 Computer Economics Inc., “Agile Development Use Increases, But Barriers Remain,” January 2017,
12 Reid, G.; “How to Navigate the Software Development Life Cycle Under the GDPR,” International Association of Privacy Professionals, 24 January 2017,
13 Heimes, R., et al.; “Top 10 Operational Impacts of the GDPR,” International Association of Privacy Professionals Privacy Symposium 2017, May 2017,
14 Karbaliotis, C.; F. Foomany; A Tagging Initiative for Building Privacy Into IoT Systems, International Association of Privacy Professionals Privacy Symposium 2017, May 2017,
15 Jaccard, J.; J. Jacoby; Theory Construction and Model-Building Skills: A Practical Guide for Social Scientists, Guilford Press, USA, 2010

Mina Miri
Is an application security researcher at SD Elements/Security Compass. She is particularly attuned to the need for applications to have well-developed security characteristics. In her current position, she researches secure development techniques in various security and privacy contexts. She has recently presented an Agile framework for building GDPR requirements into the software development life cycle at the Open Web Application Security Project (OWASP) AppSec USA 2017 and published an article in the IAPP Privacy Tech on a tagging approach to protection impact assessments (PIAs) in Agile software development.

Farbod H. Foomany, Ph.D., CISSP
Is lead application security researcher at SD Elements/Security Compass. He has been involved in various academic research and industry projects in the areas of privacy and security in software development, secure design of enterprise applications (Java EE), signal processing and evaluation of various aspects of biometric identification. Foomany has published and presented his work on signal processing and security in several IEEE conferences and journals, crime science conferences and networks, the International Association of Privacy Professional (IAPP) conference, and OWASP AppSec Conferences.

Nathanael Mohammed
Is a technical writer at SD Elements/ Security Compass. He specializes in communicating about technology, with a focus on security and privacy. He has recently been involved with projects concerning GDPR requirements in Agile software development and published an article on a tagging approach to PIAs in IAPP Privacy Tech.


Add Comments

Recent Comments

Opinions expressed in the ISACA Journal represent the views of the authors and advertisers. They may differ from policies and official statements of ISACA and from opinions endorsed by authors’ employers or the editors of the Journal. The ISACA Journal does not attest to the originality of authors’ content.