Requirements for privacy by design

You must ensure the personal data you are processing is:

• adequate – enough to properly fulfill your stated purpose
• relevant – has a rational link to that purpose
• limited to what is necessary – you do not hold more than you need for that purpose.

Accuracy

Generally, for personal data:

• You should take all reasonable steps to ensure the personal data you hold is not incorrect or misleading as to any matter of fact.
• You may need to keep the personal data updated, although this will depend on what you are using it for.
• If you discover that personal data is incorrect or misleading, you must take reasonable steps to correct or erase it as soon as possible.
• You must carefully consider any challenges to the accuracy of personal data.

Storage period limitation

• You must not keep personal data for longer than you need it.
• You need to think about—and be able to justify—how long you keep personal data. This will depend on your purposes for holding the data.
• You need a policy that sets standard retention periods wherever possible, to comply with documented requirements.
• You should also periodically review the data you hold, and erase or anonymize it when you no longer need it.
• You must carefully consider any challenges to your retention of data. Individuals have a right to erasure if you no longer need the data.
• You may keep personal data for longer if you are only keeping it for public interest archiving, scientific or historical research, or statistical purposes.