Overview
Minimum Personal Data Determination Guideline – Second: What Constitutes “Minimum” Personal Data explains how Controllers must determine what constitutes the minimum amount of Personal Data necessary for processing under the Saudi Personal Data Protection Law (PDPL). It clarifies that while the PDPL does not prescribe a fixed calculation method, Controllers must rely on purpose limitation, direct relevance, and necessity when collecting Personal Data.
The section emphasizes designing processing activities to prevent unnecessary data collection and using technical and organizational controls to ensure ongoing compliance with the data minimization principle.
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.
Second: What Constitutes “Minimum” Personal Data?
- While the PDPL does not outline a specific mechanism for determining the "minimum" data necessary to achieve the purpose of processing, Article (11) of the Law stipulates that “the purpose for which Personal Data is collected shall be directly related to the Controller’s purposes, and shall not contravene any legal provisions. Moreover, the content of the Personal Data shall be appropriate and limited to the minimum amount necessary to achieve the purpose of the Collection. Content that may lead to specifically identifying the Data Subject once the purpose of Collection is achieved shall be avoided. The Regulations shall set out the necessary controls in this regard”.
- The connection between the collection of Personal Data and its predetermined purpose must be clearly and explicitly established. Personal Data shall be collected to the extent necessary to fulfill the collection purpose in accordance with the Data Minimization Principle. No additional data should be collected that is not necessary or directly relevant.
- Controllers must ensure that their data processing activities are designed to prevent the collection of any unnecessary Personal Data in relation to the specific purposes for which the Personal Data was collected. When designing data processing activities, Controllers must adopt appropriate data management software tools, including those that perform automated periodic reviews to ensure that data remains accurate and up-to-date and that any unnecessary data is destroyed.
Examples:
The following examples serve as guidance for Controllers in assessing their compliance with the Personal Data Minimization Principle:
Example (1)
A recruitment agency distributed details for several open positions that require applicants to provide some data, including health information. It is important to note that this company does not need to collect this type of data except for a limited number of jobs.
In this example, the collection of health information is deemed unnecessary, as the recruitment agency does not require such data for all job openings. Moreover, collecting Personal Data based on unsubstantiated or uncertain future needs or contingencies must be avoided.
Example (2)
The safety procedures in certain organizations mandate that employers collect the blood types of employees engaged in fieldwork that poses potential risks. This data is crucial for prompt and effective medical intervention in the event of an accident. While it is highly unlikely that this data will be utilized during the employees’ tenure, its collection and storage are deemed necessary to minimize the impact of accidents.
In this example, collecting blood type data for employees involved in hazardous fieldwork is deemed necessary and directly linked to the purpose for which it is collected. Therefore, it does not contravene the principle of Data Minimization. However, if blood type data were collected for all employees within the organization, regardless of their role (field, office, or non-risk), such data collection would be deemed inappropriate due to the absence of a compelling necessity.
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.
