Data Privacy, GDPR, Privacy

Privacy by Design for Small Businesses: Where to Start

June 25, 2025

A U.S. Legal Perspective on Building Data Protection into Your Operations Early

Why Small Businesses Can’t Afford to Wait

Privacy isn’t just a concern for Big Tech anymore. In 2024 and 2025, U.S. state laws like the California Privacy Rights Act (CPRA), Colorado Privacy Act (CPA), and Virginia Consumer Data Protection Act (VCDPA) began requiring businesses—regardless of size—to protect consumer data proactively.

One of the best strategies? Privacy by Design: embedding data protection into your workflows, products, and vendor relationships from day one.

This blog breaks down what that means specifically for small businesses operating in the U.S., with real examples, and how Curated Privacy LLC can help you meet legal obligations without getting buried in red tape.

What is Privacy by Design?

Originally coined by Dr. Ann Cavoukian in the 1990s, Privacy by Design (PbD) is a framework that integrates privacy into the design and architecture of Information Technology (IT) systems and business processes—rather than applying fixes after the fact.

Under U.S. laws, this has shifted from best practice to legal expectation.

Key Legal Source:

California Privacy Rights Act (CPRA), §1798.100 – Requires “reasonable security procedures and practices”
🔗 CPPA CPRA Regulations Summary

Where to Start: Practical Steps for Small U.S. Businesses

1. Map Your Data Flows

Start by understanding what personal data you collect, where it’s stored, and who has access. This step helps you meet data minimization and purpose limitation obligations under the Colorado Privacy Act (CPA).

Example: A small B2B SaaS company maps customer signup data (name, email, IP address), sees it’s stored in Google Sheets, and decides to shift to a secure Customer Relationship Management (CRM) with access controls.

Source: Colorado Attorney General – CPA Guidance

2. Apply Data Minimization from Day One

Only collect the data that’s strictly necessary for your service. The Virginia Consumer Data Protection Act (VCDPA) and Texas Data Privacy and Security Act (TDPSA) explicitly require this.

Example: A small marketing agency removes the birthdate field from its lead gen form after realizing it’s not needed for lead scoring.

Source: Virginia VCDPA §59.1-575

3. Embed Privacy into Vendor Selection

Use Data Processing Agreements (DPAs) and check if your vendors comply with state privacy laws. Under the CPRA and the CPA, you’re liable for vendor mishandling of personal data.

Example: A boutique e-commerce business updates contracts with its email marketing vendor to include data security clauses aligned with the CPRA requirements.

Source: IAPP – U.S. Vendor Management Toolkit

4. Design for Consumer Rights

Ensure your systems allow users to:

Access their data
Request deletion
Opt out of data sales or targeted advertising

These are mandated under all major U.S. privacy laws including the Connecticut Data Privacy Act (CTDPA).

Example: A small Human Resource (HR) tech company builds a “Request My Data” button into its client dashboard to automate access requests.

Source: Connecticut Office of the Attorney General – CTDPA Overview

5. Train Your Team from the Start

Your team should understand the basics of data privacy as part of onboarding—especially if they handle customer data. The CPRA and the CPA require documented security awareness programs.

Example: A small software development firm includes a 30-minute privacy training in new hire onboarding.

Source: California CPRA Final Regulations

How Curated Privacy LLC Can Help

At Curated Privacy LLC, we help small and medium-sized businesses embed Privacy by Design into their foundation. We understand your bandwidth is limited—so we build privacy workflows that are lightweight, scalable, and 100% compliant.

Our Services Include:

Privacy by Design consulting
Data mapping & process audits
Vendor risk review & DPA drafting
CPRA, CPA, and VCDPA compliance setup
Custom privacy training for small teams

🔗 Learn more: www.curatedprivacy.com/services

Get Privacy-Ready Before You Scale

The earlier you implement Privacy by Design, the less risk you carry—and the less you’ll spend fixing things later. With regulators like the California Privacy Protection Agency (CPPA) and Colorado Attorney General’s Office increasing enforcement, there’s no better time to build privacy into your operations.