A privacy lead is mapping the principles in Article 5(1) GDPR to the concrete questions they answer. She needs to identify which principle governs how long personal data may be kept in a form permitting identification of data subjects. Which principle answers that question?
- APurpose limitation, which restricts the further use of data to purposes compatible with those for which it was originally collected.
- BData minimisation, which requires data to be adequate, relevant and limited to what is necessary in relation to the purposes.
- CAccuracy, which requires data to be kept up to date and inaccurate data to be erased or rectified without delay.
- DStorage limitation, which requires that data be kept in identifiable form no longer than is necessary for the purposes of processing. Correct
Why A is wrong: Purpose limitation is a real Article 5(1)(b) principle, and retention is often justified by reference to a purpose, which makes this tempting. However, purpose limitation governs the reasons data may be used, not the maximum period it may be retained in identifiable form.
Why B is wrong: Data minimisation under Article 5(1)(c) is plausibly confused with retention because both turn on necessity. But minimisation concerns the volume and scope of data collected, not the length of time identifiable data may be retained.
Why C is wrong: Accuracy under Article 5(1)(d) mentions erasure of inaccurate data, which makes it look related to retention. But it targets the correctness of data, not the duration for which correct data may lawfully be stored.
Why D is correct: Article 5(1)(e) is the storage limitation principle, and it directly addresses retention by requiring that personal data be kept in a form permitting identification for no longer than necessary for the purposes for which it is processed.