In practice
The controls that matter are knowing where it is, limiting who can reach it, minimising what is collected in the first place, and redacting or tokenising it before it is sent anywhere it does not need to go. Documents are the usual blind spot: a contract or a CV sent to a model carries far more personal data than the database field anyone was worrying about.
Where it fits in a build
Relevant to any system handling customers, staff, applicants or the public. Special categories — health, biometrics, beliefs — carry stricter obligations and should be identified explicitly at design time.
Common mistakes
- Sending whole documents to a model when a redacted extract would do.
- Personal data in application logs, where it is retained far longer than the policy says.
- Copying production data into test environments.
Related terms
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