Data trusts have been conceived as a mechanism to enable the sharing of data across entities where other formats, such as open data or commercial agreements, are not appropriate, and make data sharing both easier and more scalable. Although the form and purposes of data trusts are currently a topic of much academic discussion, a broadly accepted definition has not yet emerged. The concept of the ‘data trust’ requires further disambiguation from other facilitating structures such as data collaboratives. Irrespective of the terminology used, attempting to create trust in order to facilitate data sharing, and create benefit to individuals, groups of individuals, or society at large, requires at a minimum a process-based mechanism, i.e. a workflow, that should have a trustworthiness-by-design approach at its core. Data protection by design (DPbD) should be a key component of such an approach.