By Laini Byfield
GDPR data minimisation
A practical standard for small data: do not collect, retain, or expose more than is necessary for the purpose.
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What minimisation means in small data
Three operational implications
Fields
Resist “just in case” columns. Every extra field increases identifiability and misuse potential. If you cannot name the decision it serves, remove it.
Retention
Keep data only as long as needed for payouts, audits, and appeals — then reduce or delete. Retention without a documented reason is exposure without a purpose.
Access
Small data requires tighter role-based access. Fewer people should see raw records. The person who runs the load should not be the same person who approves exceptions.
Reference: UK ICO guidance on data minimisation (UK GDPR).
How it fits Small Data Ethics
Minimisation is necessary but not sufficient
Small Data Ethics adds what minimisation cannot provide on its own:
- Contestability: a path to challenge decisions made on the data
- Traceability: what file, load date, and rule created the outcome
- Repair: correction and reprocessing when errors occur
“Nice to have” becomes risk in small systems. Every field you collect is a field that can be wrong, exposed, or used against the person it describes.