Implementing Data Minimization Architecture

Overview

Data minimization is a core principle of the GDPR under Article 5(1)(c), requiring that personal data be "adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed." Article 25(1) mandates that controllers implement appropriate technical and organisational measures, such as pseudonymisation, designed to implement data-protection principles effectively and to integrate necessary safeguards into the processing.

The European Data Protection Board (EDPB) Guidelines 4/2019 on Article 25 Data Protection by Design and by Default clarify that data minimization applies across four dimensions: the amount of data collected, the extent of processing, the period of storage, and the accessibility of data. ENISA's 2019 report on pseudonymisation techniques provides the technical foundation for implementing these requirements at scale.

Data Minimization Architecture Layers

Layer 1: Collection Minimization

Reduce data at the point of ingestion before it enters backend systems.

Techniques: