The Principle of Proportionality: Collecting Only Necessary Data in Your Company Data Privacy Policy

For any organization that collects and handles personal information, the Principle of Proportionality is a fundamental legal requirement. This principle demands a disciplined approach to data collection, ensuring that companies only gather the minimum amount of data needed to achieve a specific business goal. Integrating this rule into your company data privacy policy is essential for complying with laws like the Philippine Data Privacy Act (DPA). This guide explains why less data often means better compliance and lower risk.

The Core Rule: What is the Principle of Proportionality?

The Principle of Proportionality is the idea that the collection and processing of personal data must be "adequate, relevant, and not excessive" for the stated purpose. This means a company must carefully check every piece of data it collects against the reason it is being collected.

Defining "Necessary" vs. "Excessive"

To follow this rule, organizations must determine what data is truly necessary. For example, collecting an employee’s TIN (Tax Identification Number) is necessary for payroll and tax filing purposes. However, collecting a job applicant's social media login details or extensive data about their family's health history is generally considered excessive and violates the DPA.

The Danger of Data Over-Collection

Collecting data that you do not need is not only legally non-compliant; it also increases business risk. This practice, which is the opposite of data minimization, makes the company a larger target for cyberattacks. More unnecessary data means a potential data breach will do more harm, leading to bigger fines and worse damage to your reputation.

The Link to Purpose Limitation

The Principle of Proportionality is always judged against the specific reason for collection, known as Purpose Limitation. If a company collects an email address to send a receipt, it cannot then use that email address to send sales pitches to third parties without obtaining new consent. The data collected must only be used for the clear reason that was first given.

Compliance Benefits: Why Proportionality Strengthens the Business

Strictly limiting the data you collect does more than just ensure legal compliance; it brings clear strategic advantages to the business operation.

Building Trust with Employees and Clients

When a company commits to the "minimum necessary" rule, it shows respect for the individual's privacy. This openness helps build strong trust with both employees and clients. When people feel confident that your company data privacy policy is genuinely designed to protect them, they are more willing to share the specific data you actually need.

Lowering Legal and Money Risks

The sheer volume of data involved directly affects the severity of a data breach. By limiting collection to only necessary data, the company reduces the total amount of sensitive information stored. This smart choice automatically lowers the legal and money risks, ensuring that if a break happens, the number of affected people and data is as small as possible.

Improving Data Quality and Efficiency

A proportionate approach forces the business to eliminate "data waste." When HR, marketing, or IT teams stop collecting irrelevant, inaccurate, or duplicate data, their systems become much cleaner. This efficiency results in faster processing times and records you can rely on more, allowing the company to make better business decisions based on high-quality, relevant data.

Practical Steps: How to Implement Proportionality Daily

The Principle of Proportionality must be applied systematically throughout the entire organization, from the moment a new form is designed to the moment data is accessed.

Doing a Data Check and Creating a List

The first crucial step is a data audit. The company must carefully check all data it currently holds to make a list. This process asks: What data do we keep? Why is it being kept? Is its purpose still legitimate and necessary?  Any data that fails this necessity test should be securely destroyed.

Planning for Privacy When Making Forms

The most visible application of proportionality is in data collection forms, both online and physical. HR forms should be revised to ask only the minimum required fields for a job application or employee onboarding. For example, instead of using open text fields that invite excessive details, use drop-down menus or check boxes to limit the information provided.

Establishing Role-Based Access Controls

Proportionality does not just apply to collection; it also applies to access. The company data privacy policy must use a rule called Role-Based Access Controls (RBAC). This means that only personnel who need specific data to perform their job (such as a payroll manager needing salary details) should be able to view it. A general manager should not see a private employee medical file if it is not necessary for their work.

Key Takeaway

Implementing the Principle of Proportionality is a strategic decision that goes beyond simple compliance. By rigorously collecting only the necessary data, a company data privacy policy becomes legally stronger, operationally more efficient, and clearly focused on building and maintaining trust with its data subjects. This rule is the most effective way to reduce the digital footprint and minimize the impact of any potential data breach.