Data minimization: Under GDPR, which requirement most directly | AIGP
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Data minimization: Under GDPR, which requirement most directly challenges this plan?

AIGP Understanding How Laws, Standards and Frameworks Apply to AI Medium

Ingesting attributes with no predictive value conflicts with data minimization, which permits only necessary personal data.

The question

A data science team plans to ingest every available customer field into a churn-prediction model, including many attributes with no demonstrated predictive value. Under GDPR, which requirement most directly challenges this plan?

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  1. Data minimization, limiting processing to personal data that is adequate, relevant and necessary for the aim ✓
    Correct: pulling in unnecessary attributes conflicts with the data-minimization requirement.
  2. Purpose limitation, requiring that personal data be collected for specified, explicit and legitimate purposes
    Plausible, but the issue is the volume of unnecessary fields, not whether the churn purpose is legitimate.
  3. Lawfulness, requiring that each processing activity rest on a valid legal basis such as consent or contract
    Important, but a valid legal basis does not by itself justify collecting fields that are not necessary.
  4. Transparency, requiring that data subjects be clearly informed about how their personal data is processed
    A genuine duty, yet informing people does not cure the collection of data beyond what is needed.
The trap
Believing that a valid legal basis or a clear notice authorizes collecting more data than is necessary.

How to remember it

Ingesting attributes with no predictive value conflicts with data minimization, which permits only necessary personal data.

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