The difference between data minimisation and storage limitation

The General Data Protection Regulation (GDPR) sets clear requirements for the handling of personal data. Two core principles are data minimisation and storage limitation. Although the terms are often conflated, they govern different aspects of personal data processing.

Minimise what you collect – from the outset

Data minimisation means an organisation may collect only those personal data that are adequate, relevant and limited to what is necessary for the specified purpose. It is not permissible to collect data “just in case” or for potential future use. The principle applies to all collection channels alike – for example forms, email, customer databases or HR processes.

Example: If the purpose is to send order confirmations, an email address is required, but not a national identification number. Organisations should therefore review the personal data they process and verify that they meet the data minimisation requirement.

Storage limitation – delete on time

Storage limitation means that personal data must not be retained for longer than is necessary for the purpose for which they were collected. As soon as the data are no longer needed, they must be erased, de-identified or anonymised. This applies to backups as well.

Example: An organisation that receives job applications by email should have a defined data retention period following the conclusion of the recruitment process. Thereafter, the applications should be erased.

Organisations need clear retention and disposal routines and must be able to justify retention periods. Referring merely to “administrative reasons” is insufficient – there must be a concrete link to the original purpose. Documented disposal routines and records of processing activities support compliance monitoring and audit, and facilitate effective data erasure and the ability to anonymise personal data where appropriate under the storage limitation principle.

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