Overview
Minimum Personal Data Determination Guideline – First: Minimum Collection of Personal Data explains how Controllers must limit Personal Data collection to what is strictly necessary and directly relevant to a defined processing purpose. It establishes core data minimization principles, including necessity, purpose alignment, lawful collection methods, proportional content, controlled retention, and secure destruction.
This section also requires ongoing assessments to ensure that Personal Data collected and retained remains justified throughout the lifecycle of processing activities.
SDAIA's Official Text
The text below reproduces official PDPL law, regulation, or guideline issued by the Saudi Data & AI Authority, verified against the original SDAIA source. No changes or reinterpretation applied.
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: 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: 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 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.
- 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 content shall not include anything that could lead to the identification of the Data Subject.
- 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.
- 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.
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:
- Verify that the collected Personal Data is directly relevant or essential for a specific, justifiable purpose.
- Ensure that the amount of Personal Data collected is limited to what is strictly necessary to achieve the identified and justified purpose.
- Personal Data shall be retained for a clearly defined period that is necessary to fulfill the purpose of its collection.
- The Controller must delete Personal Data upon the expiration of the purpose for which it was collected.
Plain-Language Explanation
The explanation below is provided to help you understand the SDAIA’s legal text and does not replace or override the official PDPL law, regulation, or guideline.
