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Privacy & Data Protection

Purpose Limitation

The principle that personal data must be collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those original purposes.

Purpose limitation is one of the core data protection principles under GDPR Article 5(1)(b). It requires organizations to clearly define and communicate the specific reasons for collecting personal data before or at the time of collection, and to refrain from using that data for unrelated purposes afterward. This principle ensures transparency and accountability — individuals can make informed decisions about sharing their data when they understand exactly how it will be used, and organizations are held to their stated commitments.

The purpose limitation principle has significant implications for how organizations design systems and manage data flows. When collecting data, organizations must document the specific purposes in their privacy notices, data processing records, and data protection impact assessments. Any new processing activity that was not originally envisioned must be evaluated for compatibility with the original purpose. GDPR provides some flexibility through a compatibility test that considers the relationship between the original and new purposes, the context of collection, the nature of the data, possible consequences, and the existence of appropriate safeguards. However, processing for entirely unrelated purposes generally requires obtaining new consent or identifying a different legal basis.

For SaaS companies and technology platforms, purpose limitation is particularly relevant when considering product analytics, feature development, or machine learning applications that might use customer data in ways beyond the original service delivery purpose. Organizations should maintain a clear record of processing activities (as required by GDPR Article 30) that documents each purpose, ensure that internal data governance processes include purpose compatibility assessments before new data uses are implemented, and design technical controls that enforce purpose-based access restrictions. ISO 27001's information classification controls and SOC 2's Privacy criteria both support purpose limitation by requiring organizations to manage data according to its intended use and sensitivity.

Related frameworks

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