TL;DR

Led cross-functional efforts to embed Privacy by Design principles into enterprise healthcare products—creating scalable UX patterns, aligning with legal and compliance teams, and shaping early product strategy to ensure privacy was built into the foundation, not bolted on.

Background

In 2018, the General Data Protection Regulation (GDPR) was introduced, marking a pivotal moment as consumers became more aware of how their personal data was being collected, traded, and sold online. With a growing emphasis on privacy, trust between consumers and digital entities started to erode. The adoption of GDPR was a game-changer for online privacy, prompting businesses to scramble for compliance.

At Crossover Health, we saw this as an opportunity to build trust with our users, especially as we were launching a new care model through our digital healthcare platform. As a California-based company, we also had to comply with the California Consumer Privacy Act (CCPA), which added another layer of complexity in ensuring that our designs adhered to privacy guidelines.

Understanding privacy laws

The CCPA applies to for-profit organizations that collect personal data from California residents, while GDPR applies to any organization collecting data on individuals in the European Union, regardless of the organization's location.

The key difference is that CCPA is a statutory law, whereas GDPR is a regulatory framework. However, the fundamental requirement of both laws is transparency: businesses must notify users if their data is being collected, explain the reason behind this collection, and inform users of their rights in relation to their data.

Understanding privacy laws

The CCPA applies to for-profit organizations that collect personal data from California residents, while GDPR applies to any organization collecting data on individuals in the European Union, regardless of the organization's location.

The key difference is that CCPA is a statutory law, whereas GDPR is a regulatory framework. However, the fundamental requirement of both laws is transparency: businesses must notify users if their data is being collected, explain the reason behind this collection, and inform users of their rights in relation to their data.

Privacy design rulebook

To ensure compliance with privacy laws, it was crucial that our product design team fully understood these regulations and how they influenced our design decisions. A privacy design rulebook was created to guide our work and ensure privacy-conscious interactions.

These guidelines became our foundation for designing user-friendly, privacy-compliant features. Key principles included:

  • Active Opt-In: Users must actively opt in to have their data collected and used.
  • Consent for Data Processing: Users must give consent for every specific type of data processing activity.
  • Easy Withdrawal of Consent: Users should have the ability to easily withdraw consent at any time.
  • Transparency with Third Parties: Users must be able to see which organizations and third parties will handle their data.
  • Clear Separation of Consent: Consent to process data must be distinct from agreeing to terms and conditions—these should be separate actions.

Revisiting design solutions

We were fortunate to be in the early stages of design, which allowed us to quickly revisit our work and make necessary adjustments for privacy compliance.

During our initial review, we identified where updates were needed to address consent and privacy concerns. The following screens and flows were updated to reflect these changes:

  • Member Signup. We separated the privacy policy and terms and conditions, adding tooltips to explain why specific data was being collected.
  • Member Account & Settings. We incorporated options for users to delete their accounts, export their data, and control preferences (e.g., text reminders, notifications).
  • Creating an Episode of Care. We added consent requests when users created an episode of care, ensuring privacy compliance during key actions.

Revisiting design solutions

We were fortunate to be in the early stages of design, which allowed us to quickly revisit our work and make necessary adjustments for privacy compliance.

During our initial review, we identified where updates were needed to address consent and privacy concerns. The following screens and flows were updated to reflect these changes:

  • Member Signup. We separated the privacy policy and terms and conditions, adding tooltips to explain why specific data was being collected.
  • Member Account & Settings. We incorporated options for users to delete their accounts, export their data, and control preferences (e.g., text reminders, notifications).
  • Creating an Episode of Care. We added consent requests when users created an episode of care, ensuring privacy compliance during key actions.

Expanding the experience

Using plain language

Plain language was a core focus to make the privacy policy and data consent process easy for users to understand. We optimized the privacy policy, which was originally a dense wall of text, by breaking it into labeled sections with expandable text for easier scanning and comprehension.

Using plain language

Plain language was a core focus to make the privacy policy and data consent process easy for users to understand. We optimized the privacy policy, which was originally a dense wall of text, by breaking it into labeled sections with expandable text for easier scanning and comprehension.

Explaining why data is being requested

Whenever we asked for user data, we ensured that users understood why it was necessary and how it would be used. We also emphasized what the data would not be used for, reassuring users of their privacy.

Explaining why data is being requested

Whenever we asked for user data, we ensured that users understood why it was necessary and how it would be used. We also emphasized what the data would not be used for, reassuring users of their privacy.

Giving users granular choices

Instead of offering an “all-or-nothing” consent model, we ensured that users had granular control over their data. For example, when creating an episode of care or setting up a televisit, users were asked for consent for specific actions (e.g., accessing the microphone or camera for a televisit). Just-in-time prompts allowed users to make informed decisions at every stage.

Just-in-time notices

We provided users with relevant privacy information at the right moments in their journey. For example, after the user clicked “Send” to create an episode of care, they were immediately asked for consent before their data was processed.

Just-in-time notices

We provided users with relevant privacy information at the right moments in their journey. For example, after the user clicked “Send” to create an episode of care, they were immediately asked for consent before their data was processed.

Pre-ticked boxes are a no-go

To ensure full compliance with privacy laws, we avoided pre-ticked checkboxes, allowing users to actively make decisions about their data. This approach ensured that users were fully informed before consenting.

Pre-ticked boxes are a no-go

To ensure full compliance with privacy laws, we avoided pre-ticked checkboxes, allowing users to actively make decisions about their data. This approach ensured that users were fully informed before consenting.

Takeaways & next steps

Takeaways

Privacy-by-design is not just a regulatory requirement—it’s a fundamental part of creating a trustworthy and user-centered experience. Privacy should never be an afterthought but rather an intrinsic part of the product design process. By embedding privacy practices early, we not only ensure compliance but also prevent potential issues in the future.

At its core, privacy-by-design is about building trust. Trust in digital products mirrors the trust users have in the businesses behind them. The more a customer trusts a product, the more likely they are to remain loyal. Building trust takes time, but it can be lost in an instant.

Next steps

Our next steps focused on further improving the privacy experience, especially around televisits. We had already wireframed a consent process before entering a televisit, along with just-in-time prompts for microphone and camera access.

One key area that required more exploration was the waiting room feature before a televisit. This feature would include a checklist that users must tick off, ensuring they are prepared for the visit and aware of guidelines and etiquette before the session begins.