Privacy and the switch to Windows 11

Sam Peters at ISMS.online describes how Windows 11 presents a powerful privacy upgrade opportunity

 

With support for Windows 10 set to officially end in October 2025, organisations that haven’t already made the switch will face the inevitable migration to Windows 11.

 

For compliance purposes, it’s a must. However, rather than treating this as a box-ticking exercise, the transition can provide an opportunity for organisations to reimagine their privacy strategies. Indeed, forward-thinking data protection officers are already learning that Windows 11’s enhanced privacy features can transform a required upgrade into a genuine privacy enhancement initiative. 

 

The key lies in approaching this change strategically, focusing on the privacy opportunities rather than simply meeting technical requirements. 

 

 

Privacy features that matter

Windows 11 introduces privacy-by-design elements that go beyond the superficial tweaks of previous iterations. The mandatory TPM 2.0 hardware requirement, whilst initially frustrating for many IT departments, creates a foundation for enhanced data protection through hardware-level security. Secure Boot functionality prevents unauthorised modifications during the boot process, whilst visualisation-based security features isolate critical processes from potential threats.

 

These aren’t simply technical badges to tick off during audits. TPM 2.0, for example, provides cryptographic attestation that can verify system integrity – this is crucial for maintaining the trust chains that GDPR’s accountability principles demand. The stricter default security configurations mean that organisations can achieve better privacy protection with less manual intervention, thereby reducing the risk of human error in security configurations.

 

The granular privacy controls embedded throughout Windows 11 represent a fundamental shift from the all-or-nothing approach of earlier versions. These controls align naturally with GDPR principles of data minimisation and purpose limitation, which makes compliance less of a retrofit exercise and more of an inherent system characteristic.

 

 

Telemetry control revolution

The most significant privacy improvement between Windows 10 and 11 lies in how telemetry data is categorised and controlled. Where Windows 10 offered broad categories of diagnostic data collection, Windows 11 provides distinct separation between ‘required’ and ‘optional’ telemetry. This granular approach supports the GDPR principle of data minimisation by allowing organisations to precisely define what data Microsoft collects.

 

Windows 11’s improved privacy dashboard provides enhanced visibility into what data is being shared and for what purpose. The Diagnostic Data Viewer offers real-time insights into telemetry collection, making it significantly easier to demonstrate transparency to users and auditors alike. This represents a practical implementation of GDPR’s transparency requirements – organisations can now show, not just tell, users what data processing occurs.

 

The improved categorisation also simplifies privacy impact assessments. Where Windows 10 required extensive investigation to understand data flows, Windows 11 makes these processes more transparent. This transparency extends beyond compliance – it also enables organisations to make informed decisions about which data sharing aligns with their privacy objectives (and vice versa).

 

 

Privacy impact assessments

The architectural changes in Windows 11 make the revisiting of Data Protection Impact Assessments (DPIAs) an essential undertaking. The new security model, enhanced telemetry controls and modified default settings represent significant changes to how data is processed, stored and transmitted. This requirement shouldn’t be viewed as additional bureaucracy, but as an opportunity to strengthen privacy protections.

 

Windows 11’s enhanced security defaults often mean that previous risk assessments may be overly conservative. Features such as visualisation-based security provide stronger isolation between different data processing activities, which potentially reduces risks identified in Windows 10 assessments. This could lead to updated risk classifications and modified mitigation strategies that better reflect the actual security posture.

 

The process of updating DPIAs also forces organisations to reconsider their data processing activities holistically. Many discover that Windows 11’s new features allow them to reduce data collection or processing that was previously considered necessary for system operation. This alignment with Article 25’s data protection by design and default represents a genuine improvement in privacy.

 

 

Transparency and consent management

Windows 11’s redesigned Settings app and Diagnostic Data Viewer can transform how organisations communicate with users about data processing. The clearer interface design makes it easier for users to understand what permissions they’re granting and what data is being collected. Crucially, this improvement in user comprehension directly supports GDPR transparency requirements.

 

Implementing GDPR-compliant consent management in Windows 11 remains an organisational responsibility, despite Microsoft’s improved tools. However, the operating system now provides better mechanisms for managing this. Microsoft Endpoint Manager and enhanced Group Policy capabilities allow administrators to enforce consent preferences at scale while maintaining detailed documentation of user choices.

 

These tools enable organisations to create audit trails that demonstrate how consent was obtained, modified, and maintained throughout the system’s lifecycle. The improved visibility into data processing activities means that enterprises can provide more detailed and accurate information to users about how their consent choices impact system behaviour.

 

The key advantage is in user experience. When users can easily understand and control privacy settings, they are more likely to make informed decisions that reduce both privacy risks and compliance burdens for their organisations.

 

 

Implementation and next steps

Successfully leveraging Windows 11’s privacy opportunities requires an approach that goes beyond technical configuration. Data protection officers should focus on embedding privacy-by-design principles throughout the migration process, using the upgrade as an opportunity to refresh and improve existing privacy practices.

 

The most effective implementations tie Windows 11 deployment into broader compliance frameworks. Organisations with ISO 27001-certified information security management systems will find that the structured approach to change management naturally incorporates GDPR considerations. The framework’s requirements for risk assessment, asset management and change control align well with the systematic approach needed for a privacy-conscious Windows 11 deployment.

 

Key focus areas should include minimising unnecessary data collection, improving user transparency through Windows 11’s enhanced interface tools, and creating robust documentation of privacy decisions and configurations. Ultimately, this is about building user trust and demonstrating organisational commitment to privacy protection, as opposed to being a purely compliance-driven exercise.

 

Indeed, the Windows 11 transition represents more than a technical upgrade. It should be seen as an opportunity to strengthen privacy posture whilst naturally achieving compliance objectives. By approaching the migration strategically and focusing on the genuine privacy enhancements available, organisations can transform this mandatory change into a competitive advantage. 

 

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Sam Peters is Chief Product Officer at ISMS.online

 

Main image courtesy of iStockPhoto.com and Alexander Sikov