Recent advances in sensing and networking technologies, namely the Internet of Things (IoT), have become key enablers of data-intensive design processes. However, the recent introduction of the General Data Protection Regulation (GDPR) in Europe has raised concerns that the GDPR might hamper data-intensive design processes. In this paper, we map the challenges of enabling ethical and compliant design of product-service systems with personal IoT data. Specifically, we present a 4-year project led by EON, an international energy provider, to design innovative home energy systems that leverage emerging technologies such as solar panels, electric vehicles and home batteries. We present our 6-stage approach to design, centred on IoT data. We highlight the barriers of responsible design with data and identify three novel trust principles for compliant use of personal IoT data in design (private-by-default, analytics transparency and Accountable analytics).

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