Purpose limitation: Under data-protection law, which principle most directly challenges this secondary use?
Purpose limitation restricts reusing data collected for one purpose for an incompatible new purpose such as model training.
The question
A company collected customer-service transcripts to resolve support tickets, then later wants to reuse them to train a new AI product model. It obtained no consent or notice for training use. Under data-protection law, which principle most directly challenges this secondary use?
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- Data portability, since customers may demand their transcripts be exported to a competitor in a machine-readable format.Plausible but wrong: portability is a data-subject right about moving data, not a bar on secondary use.
- Storage limitation, since the transcripts must be deleted the very moment each support ticket is marked fully resolved.Plausible but wrong: storage limitation concerns retention duration, not compatibility of a new purpose.
- Accuracy, since the company must correct any factual mistakes the transcripts contain before it can train a model on them.Plausible but wrong: accuracy addresses data correctness, not whether reuse is a compatible purpose.
- Purpose limitation, since data gathered for support cannot be freely reused for an incompatible new training purpose. ✓Correct: purpose limitation bars reusing data for purposes incompatible with those it was collected for.
The trap
Assuming holding data lawfully for one purpose permits reusing it for any later AI-training purpose. How to remember it
Purpose limitation restricts reusing data collected for one purpose for an incompatible new purpose such as model training.
How many of these would you get right?
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Every answer, right and wrong, comes with its own explanation.