The article says that privacy by design but then goes on to list examples of privacy by policy: - "Don’t track anyone’s search histories" This can simply be changed by changing you policy and deciding to start tracking it - "Be careful that anonymized data really is anonymized, and is minimized to provide the most benefit with the least data." A bad actor can always save a non-anonymized copy for "law enforcement" purposes - "Keep nothing if users select the “Do not track” option in their browser." Again more privacy policy, since it relies on you not changing your mind about DNT

A real example of privacy by design is duckduckgo's hidden service since it cannot, by nature, know who is using it.

I found most of the courses of action suggested by the article to be privacy by policy, which is laudable but it aint privacy by design.