Minimum Personal Data Determination Guideline – First: Minimum Collection of Personal Data emphasizes that entities should collect only the personal data strictly necessary for a specific and justified purpose. Controllers must avoid gathering extra or unrelated data, ensure the collection method is ethical and lawful, and regularly assess what data they hold, keeping only what is essential. Once the purpose is fulfilled, the data should be securely deleted.
Collect only what’s essential, ensure it serves a valid and specific purpose, and regularly clean up unnecessary data.
First: Minimum Collection of Personal Data
The minimum collection of Personal Data refers to the practice of collecting only the Personal Data that is strictly necessary and directly relevant to the purpose for which it is being collected. This entails avoiding the collection of unnecessary data, adhering to the following principles:
Actual Need:
1. Actual Need: Each element of Personal Data should be evaluated to determine whether it is directly necessary to achieve the purpose of its collection and processing.
Purpose Alignment:
2. Purpose: The purpose for which Personal Data is collected must be directly linked to the data itself and directly relevant to the Controller’s purposes. It must not conflict with the provisions of other applicable regulations in the Kingdom. The Controller must exercise due diligence in achieving the purpose of processing without collecting unnecessary Personal Data.
Collection Integrity:
3. Collection Methods: Personal Data collection methods must be direct, clear, secure, and appropriate to the Data Subject’s circumstances. They must also be free from any means that could lead to deception, misleading, or extortion and must not contravene or conflict with the provisions of applicable regulations in the Kingdom.
Data Content:
4. Content: The content of Personal Data should be adequate and limited to the minimum necessary to achieve the purpose of its collection, whether it is collected directly from the Data Subject or others. If the Controller achieves the purpose of its collection, the contentshall not include anything that could lead to the identification of the Data Subject.
Timely Destruction:
5. Destruction: Personal Data that is no longer necessary to achieve the purpose for which it was collected shall be destroyed, following secure procedures to ensure the permanent removal of the data.
Minimal Retention:
6. Retention: The Controller shall retain the minimum amount of Personal Data necessary to achieve the purpose of processing, in addition to restricting logical and physical access rights to Personal Data to the minimum privileges and actual need.
Ongoing Assessment:
Controllers are required to conduct regular assessments to evaluate the Personal Data they retain. This involves the identification and destruction of data that is no longer necessary to fulfill the purposes for which it was collected. Similarly, data that is not relevant to the primary purpose of collection shall also be destroyed. These assessments shall consider the following:
Relevance Verification:
1. Verify that the collected Personal Data is directly relevant or essential for a specific, justifiable purpose.
Strict Limitation:
2. Ensure that the amount of Personal Data collected is limited to what is strictly necessary to achieve the identified and justified purpose.
Defined Retention Period:
3. Personal Data shall be retained for a clearly defined period that is necessary to fulfill the purpose of its collection.
Mandatory Deletion:
4. The Controller must delete Personal Data upon the expiration of the purpose for which it was collected.
Explanation of First: Minimum Collection of Personal Data
Only collect what’s necessary:
Minimum Personal Data Determination Guideline – First: Minimum Collection of Personal Data says that every personal data item must be clearly tied to achieving the purpose it was collected for.
Link data to lawful, defined purposes:
Minimum Personal Data Determination Guideline – First: Minimum Collection of Personal Data also says that the data must directly relate to the controller’s objective and comply with local regulations.
Ensure transparent and secure collection:
Minimum Personal Data Determination Guideline – First: Minimum Collection of Personal Data also says that data must be gathered through fair, secure, and appropriate means without misleading the subject.
Limit content to the minimum:
Minimum Personal Data Determination Guideline – First: Minimum Collection of Personal Data also says that even if collected directly or indirectly, data should not include anything unnecessary.
Securely remove unneeded data:
Minimum Personal Data Determination Guideline – First: Minimum Collection of Personal Data also says that once data is no longer needed for its intended purpose, it must be destroyed securely.
Retain only the bare minimum:
Minimum Personal Data Determination Guideline – First: Minimum Collection of Personal Data also says that access and retention must be restricted to what’s strictly required.
Review retained data regularly:
Minimum Personal Data Determination Guideline – First: Minimum Collection of Personal Data also says that Controllers must routinely identify and remove irrelevant or outdated data.
Validate necessity of all data held:
Minimum Personal Data Determination Guideline – First: Minimum Collection of Personal Data also says to confirm that all data relates directly to a specific, justified purpose.
Keep only the needed volume:
Minimum Personal Data Determination Guideline – First: Minimum Collection of Personal Data also says that personal data volume must match the minimum required to meet the original purpose.
Set timelines for keeping data:
Minimum Personal Data Determination Guideline – First: Minimum Collection of Personal Data also says that personal data must only be kept as long as needed to serve the stated objective.
Erase data post-purpose expiration:
Minimum Personal Data Determination Guideline – First: Minimum Collection of Personal Data also says that once the reason for collection ends, the data must be permanently deleted.
