P4.1 SOC 2

SOC 2 P4.1: Privacy - Use of Personal Information Limited to Identified Purpose

What This Control Requires

The entity limits the use of personal information to the purposes identified in the entity's objectives related to privacy. Personal information is not used for purposes beyond those stated in the privacy notice unless additional consent is obtained.

In Plain Language

Collecting data properly is only half the battle. What you do with it afterwards matters just as much. Even legitimately collected data cannot be repurposed without authorisation.

In practice, this means controlling how personal data flows within your organisation. Just because the marketing team can technically query the production database does not mean they should. You need technical access controls, clear policies on who can use what data for which purposes, and monitoring to catch misuse. The classic failure here is customer data collected for service delivery quietly being used for marketing campaigns nobody consented to.

Auditors verify that you have actual mechanisms to enforce purpose limitation - not just a policy document, but real technical controls and audit trails. They will look for evidence that access is restricted by purpose, that usage is monitored, and that unauthorised use gets detected and addressed.

How to Implement

Define data use policies for each category of personal information. Map every data type to its authorised purposes and the teams or systems allowed to access it. Make these policies available to everyone who handles personal data - not buried in a wiki nobody reads.

Enforce purpose limitation with technical controls. Use access controls to restrict which teams and applications can reach specific data categories. Configure database views and API scopes to expose only what is needed. Use masking or tokenisation when the full personal data is not required for a given use case.

Create a data use approval process. When a team wants to use personal data for something not previously authorised, require a formal request covering what data they need, the intended purpose, the legal basis, and how long access is needed. Route these through your privacy team before granting access.

Monitor access patterns. Log all access to personal data repositories and look for anomalies: bulk exports, access by unauthorised teams, off-hours queries, or patterns that do not match the authorised purpose. Set up alerts for suspicious activity.

Run regular usage audits. Periodically review how personal data is actually being used across the organisation and compare it to what is authorised. When you find misuse, address it and document both the finding and the corrective action.

Train your teams on purpose limitation. Make it clear that having access to data does not mean having permission to use it for anything they want. Provide straightforward guidance on what is permitted and how to request authorisation for new uses.

Evidence Your Auditor Will Request

Data use policies defining authorized purposes for each category of personal information
Access control configurations restricting personal data access to authorized teams and purposes
Data use approval records for requests to use personal data for new purposes
Data access monitoring logs and anomaly analysis reports
Periodic data usage audit results verifying compliance with purpose limitation requirements

Common Mistakes

No policies define permitted uses for different categories of personal information
Personal data is accessible to teams and applications without purpose-based restrictions
Customer data collected for service delivery is used for marketing without authorization
No monitoring of data access patterns to detect unauthorized or excessive use
Personal data usage audits are not conducted, allowing unauthorized uses to persist undetected

Related Controls Across Frameworks

Framework	Control ID	Relationship
ISO 27001	A.5.34	Partial overlap
ISO 27001	A.5.12	Related

Frequently Asked Questions

Can we use personal data for internal analytics without additional consent?

Check your privacy notice first. If analytics is listed as a purpose, you may be covered. But apply data minimisation: can you achieve the same insight with aggregated or anonymised data? If you genuinely need individual-level data, make sure the specific type of analytics is disclosed and consented to. Document why anonymised data would not suffice - auditors will ask.

How do we enforce purpose limitation in a data warehouse?

Implement purpose-based access controls. Use views and row-level security to limit what each team can query. Tag columns with their authorised purposes and enforce access based on the requestor's stated need. Build data access request workflows that require justification. Then monitor query patterns - if someone authorised for customer support analytics is running marketing-style queries, that is a red flag.

What if we need to use personal data for a legal proceeding?

Legal proceedings are generally a valid basis for using personal data beyond original purposes. Most privacy regulations include exceptions for legal obligations and proceedings. Document the legal basis clearly, limit data access to what is strictly necessary for the case, restrict access to authorised personnel only, and get specific guidance from legal counsel. This is one area where erring on the side of caution is always the right call.

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