Data Minimization and Purpose Limitation

Many data subjects are comfortable with businesses that want to use their personal data for one specific, disclosed, and limited purpose. The trouble comes when organizations hold onto their data indefinitely and use it for a multitude of purposes that aren’t disclosed. At the same time, premature deletion of data can hinder operations. A mature privacy program supports the management of personal information (PI) collection, use, and retention in such a way that data is used according to the purpose declared upon its collection. Consent must be secured before PI can be used for any secondary purpose, and PI must be deleted or anonymized when its purpose has been fulfilled.

And of course, prevention is better than cure. Taking steps to minimize data collection can help you in the long term if there is a data breach.

Less Mature

Immature data minimization and purpose limitation practices may involve collecting more data than necessary or using data for purposes outside the original intent. It may be the case that you and other stakeholders lose track of personal data as it moves through and outside of the organization. PI may be transferred to third parties without proper consent or disclosure, even without internal stakeholders’ knowledge.

More Mature

Mature data minimization and purpose limitation practices involve identifying the minimum amount of personal data required to achieve the intended purpose and ensuring the data is only used for that purpose. This includes regularly reviewing and updating data retention policies, limiting access to personal data, and implementing technical controls such as pseudonymization to protect personal data. Furthermore, any data that is transferred to third parties must be carefully tracked and monitored, and agreements must be in place that limit how third parties can use PI. Your organization will inform data subjects about any transfers, their purpose, and what rights they hold in regard to data transfers.

Recommended Next Steps

Before you can optimize your PI collection, use, and retention practices, you’ll need to understand where and how your organization collects and processes personal data. For this reason, a data inventory and/or RoPA should be your first step. Ask yourself why:

• Why am I collecting this?
• Why am I sharing this?
• Why am I storing this here?
• Why am I keeping this for so long?

Your privacy policy should also be clear about why you collect PI, and your colleagues who work with personal information should understand that they may only use PI for those specific purposes. Work with your IT and operations team members to ensure that only individuals who need to access personal data can access it, and regularly review and update policies and procedures to ensure data is only used for stated purposes unless permitted by the data subject.