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Privacy programs increasingly depend on systems that can verify key aspects of data handling: confirming user consent, controlling access to data, tracking data lineage, and maintaining audit trails. In fact, the EU General Data Protection Regulation requires organizations to demonstrate valid consent, provide data access, maintain processing records, and secure personal data.
These verification capabilities rely on cryptographic tools, like encryption and digital signatures, to prevent tampering and enable reliable audits. However, the common public key algorithms used today — Rivest-Shamir-Adleman, a system based on the difficulty of factoring large numbers and Elliptic Curve Cryptography, which uses mathematical curves to secure data — are mathematically vulnerable to future quantum attacks like those enabled by Shor’s algorithm. In 2020, the European Data Protection Supervisor warned that this quantum threat “could break currently used cryptography and undermine the protection of personal data.” And in April 2024, the European Commission cautioned that quantum computing could be “capable of breaking today’s encryption” and urged organizations to switch to post-quantum methods “as swiftly as possible.”
While large-scale quantum computers capable of breaking existing public-key cryptosystems remain hypothetical, the National Institutes of Standards and Technology has noted that some experts expect such devices within the next decade, and Europol‑led advisory groups point to a credible 10 to 15-year timeline for post‑quantum risks. For privacy professionals, these warnings signal that crucial compliance functions — proving consent, preserving data integrity, demonstrating lawful processing — must remain viable even after cryptography changes.
One solution is to design post-quantum trust architectures that keep systems accountable and verifiable, even as their cryptographic underpinnings evolve. Below are five design principles of such an architecture, aligned to different phases of a system’s lifecycle from design to data retention. The aim is to ensure privacy safeguards like consent logs, access controls and audit trails stay trustworthy throughout the coming cryptographic transition.
Principles for post-quantum resilience
Below are five core principles designed to help privacy professionals future-proof key functions such as consent tracking, audit logs and data integrity — even as cryptographic algorithms evolve.
Agility: Design stage
Build systems flexible enough to swap out cryptographic algorithms without a complete overhaul. Using modular cryptographic libraries or interfaces, rather than hard-coding algorithms into software, makes it easier to upgrade today’s ciphers to tomorrow’s quantum-safe alternatives.
Post-quantum readiness: Deploy stage
Don’t wait for quantum computers to arrive before acting. Organizations should begin introducing quantum-safe encryption or hybrid approaches that combine classical and quantum-resistant algorithms into their systems. For example, the U.S. government in 2024 approved new cryptographic standards, Federal Information Processing Standards 203–205, that mandate quantum-resistant algorithms for federal agencies. The European Commission has urged organizations in the EU to start preparing now by integrating post-quantum migration into their security strategies.
Continuity: Operate stage
Maintain an unbroken chain of trust for records and data logs as cryptography is upgraded. The idea is to layer new protections on top of old ones so that even if an older algorithm becomes insecure, the past records are still covered by a newer signature or timestamp. For example, a consent log that was signed with an old algorithm can be timestamped or re-signed using a post-quantum algorithm, extending its integrity. Another approach is to run legacy and new encryption systems side by side during transitions, such as keeping the old and new certificate authorities both valid temporarily. Such measures ensure that audit trails and evidence remain verifiable across algorithm changes.
Upgradeability: Transition stage
Plan for a smooth replacement of cryptographic keys and certificates, especially root trust anchor keys, without breaking the systems. Upgradeability means legacy keys or certificate authorities can be safely replaced with quantum-safe alternatives without disrupting the systems that rely on them. Practically, this might involve adding the new algorithm or root key in parallel with the old one and phasing the old one out once everything recognizes the new trust anchor. The goal is that users and dependent systems never notice the change.
Forward secrecy: Retain stage
Protect long-term data so that even if a cryptographic key is compromised in the future, any previously collected data remains secure. Forward secrecy is already a standard feature of modern protocols like Transport Layer Security 1.3, where each session uses a unique temporary key that is discarded immediately; this means an attacker who steals the server’s main key still cannot decrypt old sessions. Organizations should apply the same principle to stored data: use short-lived encryption keys and periodically re-encrypt or re-sign sensitive archives with newer algorithms. By not relying on one static key for years on end, the impact of any single key being cracked is minimized.
A privacy‑led implementation road map
While the technical work of changing encryption will be handled by IT and security teams, privacy professionals have a crucial role in governance and planning. Here are some proactive steps privacy teams can take to future-proof their programs against quantum threats.
Map cryptographic dependencies
The organization should identify where it currently uses encryption for privacy or compliance functions. For example, pinpoint systems that rely on cryptography to record consent, control access, or preserve audit logs. This mapping will highlight which processes might be affected by an encryption change, so the organization knows where to focus transition efforts.
Update governance documents
Incorporate post-quantum considerations into the risk assessments, data protection impact assessments and security policies. Acknowledge that encryption algorithms have a finite lifespan. For systems that must protect personal data for many years, e.g., long-term archives, note the need to revisit and update their cryptographic safeguards over time.
Engage vendors
Ask vendors and service providers about their crypto-agility and post-quantum readiness. Ensure that contracts allow necessary cryptographic updates — for instance, an organization should have the ability to switch to a vendor’s post-quantum solution or introduce their own encryption modules if standards change. Vendors should be partners in the transition, providing support for new encryption when the time comes.
Pilot and test early
Work with IT to experiment with quantum-safe or hybrid encryption in a test environment. For example, enable a post-quantum cipher suite on a staging server or trial a VPN that uses a post-quantum key exchange. Early testing can uncover performance or compatibility issues in a low-risk setting, informing the planning before any real-world deployment.
Bridge the legal-technical gap
Translate the quantum risk into business and compliance terms to get buy-in beyond the IT department. Explain, for instance, that if today’s encryption is broken in the future, the organization might lose the ability to prove who consented to what or to guarantee data confidentiality, undermining legal compliance. Framing the issue in terms of regulatory obligations and business continuity helps leadership and legal teams understand why investing in a timely cryptographic transition is essential.
Conclusion
Privacy programs rely on a foundation of trust that must remain solid even as technology evolves. The eventual rise of quantum computing will require replacing many of the cryptographic tools that currently safeguard personal data and privacy. By embedding principles like agility, continuity, post-quantum readiness, upgradeability and forward secrecy into today’s systems, privacy professionals can ensure that core protections — from consent records to audit logs — stay intact when that shift occurs.
Ultimately, privacy infrastructure must be designed to adapt — resilient, flexible, and future-ready. Proactively testing and adopting quantum-resistant techniques now, before quantum threats become real-world risks, will allow organizations to transition smoothly without compromising compliance or trust. In doing so, privacy leaders reaffirm their roles as guardians of trust — keeping privacy and data integrity resilient across generations of technology.
Claudia Koon Ghee Wee, AIGP, is based in Australia and specializes in AI engineering, AI assurance and governance.
