Compare the proposed use with the original purpose: Which approach best addresses the explicit purpose
Reuse requires comparing the new purpose with the original context and confirming that the lawful basis supports it.
The question
Under the GDPR, a retailer collected loyalty-purchase data to administer rewards and now proposes using it to train a workforce scheduling model. The original notice did not mention workforce analytics. Which approach best addresses the explicit purpose constraint?
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- Ask the analytics vendor to confirm that scheduling benefits customers.A vendor’s benefit assertion does not establish compatibility with the original purpose or support the retailer’s lawful basis.
- Proceed because the same retailer remains the data controller.Controller identity does not by itself make a materially different use compatible or establish that the existing lawful basis covers it.
- Compare the proposed use with the original purpose and lawful basis. ✓Purpose compatibility analysis determines whether reuse aligns with the original collection context and whether the existing lawful basis supports it.
- Replace names with pseudonyms and treat the reuse as anonymous.Pseudonymization can reduce exposure, but pseudonymized information remains personal data and does not resolve purpose compatibility.
The trap
Compare original and proposed purposes, context, expectations, and lawful basis; pseudonymization does not answer compatibility. How to remember it
Reuse requires comparing the new purpose with the original context and confirming that the lawful basis supports it.
How many of these would you get right?
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