The 7 GDPR Principles: Foundation of Data Protection

Key Takeaways

Point	Summary
7 principles	Lawfulness/Fairness/Transparency, Purpose Limitation, Data Minimization, Accuracy, Storage Limitation, Integrity/Confidentiality, Accountability
Accountability is key	You must prove compliance, not just claim it
Data minimization	Collect only what you need, nothing more
Purpose limitation	Use data only for originally stated purposes
Storage limitation	Delete data when no longer needed; define retention periods

Quick Answer: GDPR has 7 principles: (1) lawful/fair/transparent processing, (2) collect for specific purposes only, (3) minimize data collected, (4) keep data accurate, (5) don't keep it forever, (6) keep it secure, (7) prove your compliance.

Overview of GDPR Principles

1. Lawfulness, Fairness & Transparency. Have a legal basis, be fair, be clear
2. Purpose Limitation. Use data only for stated purposes
3. Data Minimization. Collect only what you need
4. Accuracy. Keep data correct and current
5. Storage Limitation. Don't keep data forever
6. Integrity & Confidentiality. Keep data secure
7. Accountability. Prove your compliance

Principle 1: Lawfulness, Fairness, and Transparency

This foundational principle has three components:

Lawfulness

You must have a valid legal basis before processing any personal data.

Legal Basis	When to Use
Consent	User actively agrees to processing
Contract	Processing needed to fulfill a contract
Legal Obligation	Required by law
Vital Interests	Protecting someone's life
Public Task	Official government functions
Legitimate Interests	Business need balanced against user rights

Fairness

Processing must not be detrimental, unexpected, or misleading to data subjects.

Examples that may raise fairness concerns:

• Using data in ways users wouldn't reasonably expect
• Processing that causes unjustified harm
• Exploiting vulnerabilities or power imbalances
• Hidden or obscured data collection practices

Transparency

Individuals must know what data you collect and how you use it.

Transparency requirements:

• Clear, plain language privacy notices
• Information provided before or at collection time
• Easy-to-find privacy policies
• Disclosure of third-party sharing

Principle 2: Purpose Limitation

Data can only be collected for specified, explicit, and legitimate purposes.

Allowed:

• Collect email to send purchase receipts
• Collect address for shipping
• Analyze usage to improve product

Not Allowed:

• Use that email for marketing (without separate consent)
• Sell address to third parties
• Share usage data with advertisers

Implementing Purpose Limitation

Action	Implementation
Define Purposes	Document why you collect each data type
Communicate Purposes	Include in privacy policy
Limit Usage	Don't use data for undisclosed purposes
New Purposes	Get new consent or ensure compatibility

Compatible Purposes

You may use data for purposes compatible with the original purpose without new consent:

• Statistical analysis
• Scientific research
• Historical archiving (with safeguards)

Principle 3: Data Minimization

Collect only the personal data that is adequate, relevant, and limited to what is necessary.

Data Minimization Checklist

Question	Action Required
Do you need this data?	If no, don't collect it
Is this the minimum needed?	Reduce scope if possible
Can you achieve the purpose with less?	Find alternatives
Are you collecting "just in case"?	Stop. Not allowed

Practical Examples

Registration Form

Field	Necessary?	Recommendation
Email	Yes	Required for account
Password	Yes	Required for security
Name	Maybe	Only if needed for service
Phone	Usually no	Make optional or remove
Date of Birth	Rarely	Only for age verification
Gender	Usually no	Remove unless essential

Analytics Data

• Collect: Page views, session duration, conversion events
• Question: Full IP addresses, detailed location data
• Avoid: Unnecessary personal identifiers

Principle 4: Accuracy

Personal data must be accurate and, where necessary, kept up to date.

Accuracy Requirements

Requirement	Implementation
Verify at Collection	Validation rules, confirmation emails
Enable Corrections	Self-service profile editing
Regular Reviews	Periodic data accuracy checks
Update Processes	Clear procedures for updates
Source Documentation	Track where data came from

Handling Inaccurate Data

If reported by user:

• Verify the correction
• Update within reasonable time
• Notify any recipients of original data

If discovered internally:

• Correct immediately
• Assess impact of inaccuracy
• Update related records

Principle 5: Storage Limitation

Don't keep personal data longer than necessary for the purposes for which it was collected.

Retention Best Practices

Data Type	Typical Retention	Basis
Active User Data	Duration of account + grace period	Service provision
Inactive Users	2-3 years then delete/anonymize	Legitimate interest
Transaction Records	7 years	Legal/tax requirements
Marketing Consent	Until withdrawn + proof period	Consent
Support Tickets	2-3 years	Service quality
Analytics	Anonymize after 14-26 months	Data minimization

Implementing Retention

• Create a data retention policy
• Document retention periods for each data type
• Implement automated deletion where possible
• Regular reviews of stored data
• Secure deletion procedures
• Exception processes for legal holds

Principle 6: Integrity and Confidentiality

Personal data must be processed securely with appropriate technical and organizational measures.

Security Measures Required

Category	Measures
Technical	Encryption, access controls, firewalls, MFA
Organizational	Policies, training, access management
Physical	Secure offices, locked cabinets, clean desks
Procedural	Incident response, backup procedures

Security Implementation

Data at Rest:

• Database encryption
• Encrypted backups
• Secure key management

Data in Transit:

• TLS/HTTPS everywhere
• Encrypted APIs
• Secure file transfers

Access Control:

• Role-based access
• Principle of least privilege
• Multi-factor authentication
• Regular access reviews

Monitoring:

• Audit logging
• Intrusion detection
• Anomaly alerts
• Regular security assessments

Principle 7: Accountability

You must be able to demonstrate compliance with all GDPR principles.

Documentation Requirements

Document	Purpose
Privacy Policy	Transparency to users
Processing Records (ROPA)	Internal documentation
Data Protection Impact Assessments	Risk evaluation
Consent Records	Proof of valid consent
Data Processing Agreements	Third-party compliance
Training Records	Staff awareness evidence
Security Policies	Organizational measures

Demonstrating Accountability

• Maintain comprehensive documentation
• Conduct regular compliance audits
• Keep records of processing activities
• Document decision-making rationale
• Train staff on data protection
• Implement privacy by design
• Appoint DPO if required
• Respond promptly to data subject requests

Principles in Daily Operations

Operation	Principles Applied
New Feature Development	Minimization, Purpose Limitation, Privacy by Design
Marketing Campaign	Lawfulness (consent), Purpose Limitation
Customer Support	Accuracy, Security, Access Rights
Data Analytics	Minimization, Purpose Limitation, Storage Limitation
Vendor Selection	Accountability, Security
Employee Onboarding	Transparency, Training

How Bastion Helps

Embedding GDPR principles into daily operations requires both expertise and ongoing attention. Working with experienced partners helps ensure your approach is thorough and sustainable.

Challenge	How We Help
Policy Documentation	Proven templates aligned with GDPR principles
Technical Implementation	Guidance on appropriate security measures for your context
Ongoing Compliance	Continuous monitoring and periodic compliance reviews
Staff Training	GDPR awareness programs tailored to different roles
Evidence Collection	Streamlined processes for maintaining accountability documentation

Our managed services approach brings additional hands to help with the heavy lifting, ensuring that principles are implemented correctly from the start rather than requiring costly corrections later.

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