In our contribution to the EDPB’s draft guidelines on Data Protection by Design and by Default, we ask the EDPB to address a number of issues in relation to the examples provided in the document. In particular, in connection to the examples under “Lawfulness” i.e. a bank plans to offer a service to improve efficiency in the management of loan applications; under “Accuracy” i.e. a bank wishes to use artificial intelligence (AI) to profile customers applying for bank loans as a basis for their decision making; and under “Storage limitation” i.e. a controller that administers a membership. We also ask the EDPB to take into account some additional recommendations to provide the necessary legal certainty to credit reference agencies.