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FIGURE 4-4: THE DATA MINIMIZATION PATH BEFORE SENDING
What to notice: The path begins by determining what the task needs, then classifying the
data, deleting what is unnecessary, replacing identifiers, and sending only the minimum.
Source: Prepared by the author, drawing on published privacy framework guidance [3].
TABLE 4-9: DATA MINIMIZATION QUESTIONS
The question What to do if the answer is no
Does the result genuinely
Delete the field or replace it with a general description.
need this field?
Can the purpose be achieved
Use dummy data or compute the result locally.
without real data?
Could the person be re-
Reduce rare details or group values into categories.
identified from the context?
Is the tool appropriate for this Use an approved organizational channel, or do not
data classification? send.
Do you know where the data
will be stored and who can Set a retention period and a clear deletion procedure.
reach it?
✓ Practical tip: create a safe working copy
Create a safe working copy of a document before uploading it: delete signatures,
identifiers, and hidden notes, replace names with codes, and review the file properties
and any appended pages, not only the visible text.
• Keep the original separate from the working copy.
• Review the metadata and the attachments.
• Keep the code map outside the tool.
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